Re: ECCN number?

["Joe Smith" <unknown_kev_cat@hotmail.com>]

"MJ Ray" <mjr@phonecoop.coop> wrote in message 
[🔎] 47d5eb9e.ANxk03DtQyFcydXS%mjr@phonecoop.coop">news:[🔎] 47d5eb9e.ANxk03DtQyFcydXS%mjr@phonecoop.coop...
> "Paul Wise" <pabs@debian.org> wrote:
> > On Tue, Mar 11, 2008 at 1:45 AM, John Eric Clark <jec@jpl.nasa.gov> 
> > wrote:
> > >  Does Debian have an ECCN number for exporting? I am trying to get one
> > >  for the OS itself.
> >
> > From the list archives and our BXA notification template, it looks
> > like our ECCN is 5D002:
>
> As hinted by
> > http://lists.debian.org/debian-legal/2007/08/msg00073.html
> I suspect debian as a whole exceeds the limits of 5D002 according to
> http://www.access.gpo.gov/bis/ear/ear_data.html#ccl
> so the ECCN would be 4D003, but I've not seen official confirmation
> either way.

My concern is that 4D003 does not have the EI reason for control that former 
"Munitions" cryptographic software (5D002) does. It seems really strange to 
me that by including sufficient other software, the EI export control reason 
should just magically disappear. That sounds like it would be at best a 
major loophole, and at worst such a large loophole as to make the whole 
expert control system fail.