appstore and cryptography

With the onset of copy/paste in the 3.0 version of the Iphone OS i figured i would write some software providing a facile way of encrypting text with a password for sending via sms , email and whatnot, it is called TXTcrypt after a long struggle it is now both on the appstore and as a free desktop version which is legal to download.

Enter the 1996 Wassenaar Arrangement signed by 41 states (see attached map) , requiring special permission to market/export encryption software with keys greater than 56 bits in size and 64 bits in length (Category 5 Part 2 5.A.2.a.1.a.) .

This limitation applies to symmetric key algorithms , and just determining what i stated above required me to study dozens of cumbersome and often confusing documentations (that use length and size interchangeably).

Moving on, as the Apple App Store is based in the US , and US is a signatory of said act , applications using cryptography for anything else than authentication purposes are subject to the regulations of the Wassenaar Arrangement body in the US , namely The Bureau of Industry and Security, US Department of Commerce (BIS) .

The regulations for the named (5.A.2.a.1.a.) category fall into the BIS ECCN (Export Control Classification Number) 5D992 , and can be exported under the EAR to most destinations with No License Required (“NLR”) but a NLR Notification 742.15(a)(i)

For software exceeding 56/64 bits the classification is ECCN is 5D002 742.15(b) , and a export license if required in the form of a Commodity Classification Automated Tracking System (CCATS) number , luckily BIS has the conveniently named Simplified Network Application Process Redesign (SNAP-R) application for that , but just registering your company to request a PIN to access that turned into a monthly long enterprise , about the time when i abandoned this approach.

Because as it turns out , Apple does have a process handy shall you abandon or be stuck for a very long time in the claws of BIS , ECCN 5D002 rated applications without a export license can be posted to the app store for the U.S. and Canada only , just set it as so in itunesconnect and send the completed form (U.S.Canada Only Form.pdf attached) to the Apple Export Department.


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