ECCN Classification of Debian GNU/Linux
Devincenzi, Ronald P
I ran across the thread related to the question of ECCN and have a few questions:
· Is the Debian OS that is freely downloadable source or object code
· Based on the information you provided, I presume the Debian OS contains some embedded encryption functionality. Is this correct? If so, does this functionality come standard as part of the free download?
Thanks for your assistance………….Ron
Ron Devincenzi
Export Compliance Manager
JPMorgan Chase Global Trade Services
Ph: 845.297.0040
Cell: 845.527.5965
email: ronald.p....@jpmchase.com
"Diehl Markus" <Markus...@vierling.de> wrote in message 7FB9A405F330794B932C...@vg-ms-2.Vierling.corp">news:7FB9A405F330794B932C...@vg-ms-2.Vierling.corp...
Hello,
on one of our VoIP GSM gateways we use Debian/GNU Linux.
For export issues according to US law we require a so called ECCN code
for the gateway.
The ECCN code of our VoIP GSM gateway will be determined by the ECCN
codes of the used sub components (e.g. a ECCN code of the Linux system).
Is there an ECCN code for Debian/GNU Linux?
Best regards + Many thanks!
Markus
First of all, I am not a laywer. So the following is not legal advice, but only what i know.
I'm not aware of any ECCN that would cover an operating system as a whole. However, parts of Debian may be covered under ECCN 5D002. However, those parts fall under the TSU licence exception, so no licence is required for that component. I'm not sure of any other applicable ECCN. Also note that the ECCN of a GNU/Linux distribution can vary depending on what components of it are exported. (Your GSM gateway presumably does not use every component of Debian GNU/Linux).
Your safest bet would be to submit a classification request for the entire system to BIS, as described in the answer to question 3 at http://www.bis.doc.gov/Licensing/Do_I_NeedAnECCN.html
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Ben Finney
> I ran across the thread related to the question of ECCN and have a few
> questions:
<URL:http://www.bis.doc.gov/licensing/exportingbasics.htm>, a USA
Department Of Commerce term.
> * Is the Debian OS that is freely downloadable source or
> object code
Debian is downloadable in both object (executable) form and source form.
The whole of Debian is free software.
> * Based on the information you provided
I don't know what this refers to. Who is “you”, and what information was
provided, to whom?
> I presume the Debian OS contains some embedded encryption
> functionality. Is this correct? If so, does this functionality come
> standard as part of the free download?
Debian, and they are installed like any other package from the same
repositories as the rest of the operating system.
For more information on Debian and US export control, you may be
interested in the page at <URL:https://wiki.debian.org/USExportControl>.
Note that, like that wiki page, this forum does not constitute official
legal advice.
--
\ “I think Western civilization is more enlightened precisely |
`\ because we have learned how to ignore our religious leaders.” |
_o__) —Bill Maher, 2003 |
Ben Finney
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