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Export licence issues: (with for instance Firefox ESR) ECCN & EAR is our documentation up to date

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john.p....@gmail.com

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May 14, 2017, 10:06:02 AM5/14/17
to mozill...@lists.mozilla.org
We have a WikiMo article
Deployment:Deploying Firefox - 11 United States Export Control Information
https://wiki.mozilla.org/Deployment:Deploying_Firefox#United_States_Export_Control_Information
That article may well be out of date. The article certainly includes broken links.

I am prompted to ask this question because of a question an exporter asked in the Mozilla Sumo (Kitsune !! rollback) support forum:

Home => Support Forum => Firefox => EAR ECCN - Urgent Request
https://support.mozilla.org/questions/1159828

> Hi We are a company in the UK and we urgently require assistance to identify the Export Control Classification Number (ECCN) of your product under the EAR. After scouring your website the only information I have been able to find is from 2013 and references ECCN 5D002.c.1 and licence exception 740-13 (e) TSU Unrestricted. This information is however out of date and paragraph (e) of the TSU exemption no longer exists.
> Could you please confirm what the latest classification of your product should be? Many thanks

I do find documentation in the US BIS site e.g.
https://www.bis.doc.gov/index.php/policy-guidance/encryption
but I also note some internal links on that site are themselves broken.


I will leave it to those that understand such matters to decide what documentation we need and to update documentation if necessary.

Gervase Markham

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May 15, 2017, 4:35:31 AM5/15/17
to john.p....@gmail.com
On 14/05/17 15:05, john.p....@gmail.com wrote:
> I will leave it to those that understand such matters to decide what documentation we need and to update documentation if necessary.

Unfortunately, the set of such people may be empty :-(

The information here:
https://wiki.mozilla.org/Deployment:Deploying_Firefox#United_States_Export_Control_Information
was written by Frank Hecker a long time ago. If it's no longer accurate,
I don't know who would be able to update it. As Frank writes: "We
strongly caution you not to act on your personal reading of export
regulations. They are complex and loaded with history, precedent, and
context which often require interpretation from a qualified attorney."

I will ask the legal team, but the immediate response is "this is open
source software, and historically export regulations have not applied to
it. However, this is not legal advice."

Gerv

Gervase Markham

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Aug 1, 2017, 7:50:32 AM8/1/17
to john.p....@gmail.com
On 14/05/17 15:05, john.p....@gmail.com wrote:
> We have a WikiMo article
> Deployment:Deploying Firefox - 11 United States Export Control Information
> https://wiki.mozilla.org/Deployment:Deploying_Firefox#United_States_Export_Control_Information
> That article may well be out of date. The article certainly includes broken links.

This article has now been updated to contain current information about
the status of this matter.

Gerv
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