Discussion:
Inquire about ECCN for Debian GNU/Linux and how to deal with revised EAR
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I***@cj.MitsubishiElectric.co.jp
2018-04-10 10:49:00 UTC
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Dear Paul and Osamu,

Thank you for the informations.
If you reach a conclusion, please let us know the results.
The results are as follows.
[1] Is the Debian operating system classified under ECCN 5D002 ?
On the USExportControl website (https://wiki.debian.org/USExportControl),
it has been described "may be" covered under ECCN 5D002.
This cannot treat as our confirmation,
so I had to ask a duplicate question as a procedure.
Is it still "may be"? Are there more clearly description?
Although it may not be necessary,
I sent a notification to BIS after self classification on our items.
[2] Can the Debian operating system be treated as out of EAR subject
under the current EAR ?
I think that paragraph Part 742.15(b) of the current EAR
is similar to paragraph Part 740.13(e) of the past EAR.
But there are some differences.
Are there no need to notify BIS again ?
It is explained in Note 1 on this page.
https://www.bis.doc.gov/index.php/policy-guidance/encryption/1-encryption-items-not-subject-to-the-ear

Sincerely,
Yuichi Ikeda

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