iOS Question App Store asks for Export Compliance Information

[Martin Larsen]

When submitting my app, App Store asks for Export Compliance Information. The question is asked here but little information is given.

Apple's info page says: Use of encryption includes, but is not limited to: Making calls over secure channels (i.e. HTTPS, SSL, and so on).

So I guess the answer to Does your app use encryption? is yes.

But then comes a number of other questions:

Does your app qualify for any of the exemptions provided in Category 5, Part 2 of the U.S. Export Administration Regulations?
I guess No.

Does your app implement any encryption algorithms that are proprietary or not accepted as standards by international standard bodies (IEEE, IETF, ITU, etc.)?
I guess No.

Does your app implement any standard encryption algorithms instead of, or in addition to, using or accessing the encryption within Apple’s operating system?
Well, yes? https?

Is your app going to be available on the App Store in France?
Hmm, although it is in Danish only, there could be Danes in France wanting to use the app. So yes.

Version 1.0 (1.0) cannot be submitted at this time because the build does not have associated export compliance documentation.
What ???

If I answer No to France, I get:
If you are making use of ATS or making a call to HTTPS, you are required to submit a year-end self classification report to the US government
What classification report? Really?

Please, what should I ask to all these questions? It's a nightmare!

 

[Erel]

This is a question for lawyers and I'm not one.
This might be useful:

Complying with Encryption Export Regulations | Apple Developer Documentation

Declare the use of encryption in your app to streamline the app submission process.

developer.apple.com

Search for: "Typically, the use of encryption that’s built into the operating system"

 

[Martin Larsen]

Thanks. What do B4i users typically answer to these questions? I guess you all needed to answer?

 

[Semen Matusovskiy]

There is an 'explanation' - https://help.apple.com/app-store-connect/#/devc3f64248f

Your app uses ATS or makes a call to HTTPS

No documentation required in App Store Connect. Submit a Self Classification Report to the U.S. Bureau of Industry and Security (BIS) directly.

As I understand, Does your app use encryption? Yes
Does your app qualify for any of the exemptions provided in Category 5, Part 2 of the U.S. Export Administration Regulations? Yes, because
Limited to authentication, digital signature, or the decryption of data or files

 

[Martin Larsen]

Thanks, Semen. It makes sense.