Quick Links: Download Gideros Studio | Gideros Documentation | Gideros Development Center | Gideros community chat
Gideros Lua Encryption - could this create problems with export compliance? - Gideros Forum

Gideros Lua Encryption - could this create problems with export compliance?

moopfmoopf Guru
edited March 2013 in General questions
A thought occurred to me today about Gideros' built-in Lua encryption - does using this require us to get an ERN (export registration with the US government)? It applies to all developers, not just those in the US looking to sell abroad, due to how Apple operate. I believe it may meet the exemptions provided by updated legislation in the US, specifically Category 5 Part 2 Note 4. Search for 'encryption' on the following page and you'll see the questions you have to answer:

http://developer.apple.com/library/ios/#documentation/LanguagesUtilities/Conceptual/iTunesConnect_Guide/8_AddingNewApps/AddingNewApps.html

Also, Category 5 Part 2 and Note 4 are explained here: http://www.bis.doc.gov/encryption/question1.htm

And then we have the whole French thing as well, which is outlined here in something that Apple sent out in 2011:
"Starting in the first week of July, apps that meet the following criteria are required to comply with French Encryption Laws/Regulations if you intend to distribute your app in France.

This requirement applies to apps that use, access, implement, or incorporate:

(a) any encryption algorithm that is yet to be standardized by international standard bodies such as IEEE, IETF, ISO, ITU, ETSI, 3GPP, TIA, etc. or not otherwise published; or

(b) standard (e.g., AES, DES, 3DES, RSA) encryption algorithm(s) instead of or in addition to accessing or using the encryption in iOS and/or Mac OS X

Apple will require you to upload a copy of your approved French declaration when you submit your app to the App Store.

Relevant French encryption regulations can be found at:

http://www.legifrance.gouv.fr/affichTexte.do?cidTexte=LEGITEXT000005789847&dateTexte=#LEGIARTI000006421577

http://www.ssi.gouv.fr/archive/fr/reglementation/regl_crypto.html

http://www.ssi.gouv.fr/site_article195.html

http://www.ssi.gouv.fr/site_article197.html

Regards,

Apple Export Compliance"

So @atilim can you comment on this please so I know where we stand if I use the Lua encryption both in terms of US export restrictions and French laws. I know you're not a lawyer but presumably you paid notice to these laws when incorporating the encryption?

Cheers,

Gareth

Comments

Sign In or Register to comment.