[Python-legal-sig] Export Python software

Zanette, Christina Christina.Zanette at bryancave.com
Fri Sep 13 16:27:12 CEST 2013


Good afternoon,

I have a client who plans to export Python software, specifically version 2.7.5., from the United States to another country.   I am trying to determine the correct Export Control Classification Number and authority for export for Python software.

Could you kindly confirm that this software contains or otherwise uses encryption (or other information security, e.g. hashing)?  If yes, could you please describe the encryption, including algorithms, key length, etc?    I believe the software may be classified as ECCN 5D002, however I would appreciate your confirmation for the two questions stated above.

In addition, is there a CCATS or encryption registration associated with this software?  Finally, if this product is 5D002, can you confirm if it qualifies for a license exception (for instance license exception ENC (Encryption Commodities, Software and Technology), under the requirements of (b)(1) - self classification, (b)(2) - Encryption restricted; or (b)(3) encryption unrestricted?

Many thanks in advance for any assistance you can provide.

Regards,

Christina Zanette
Bryan Cave LLP
Christina.zanette at bryancave.com<mailto:Christina.zanette at bryancave.com>
1155 F Street, NW
Washington, DC  20004
Tel:  202.508.6145
Fax:  202.220.7445


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