Good afternoon,
I am looking for the Export Control Classification Number (ECCN) for the following product: TortoiseSVN 1.14.1.29085 (64 bit) 1.14.29085. Can someone please advise on this? I was directed to another posting in the Google group, but that posting is almost 15 years old. An updated response from the company would be helpful to confirm the company still is under the determination that this product is not subject to the Export Administration Regulations and thus doesn’t have an ECCN. Any updated information would be helpful.
Please let me know if you have any questions.
Thank you,
Madeline J. Orlando |
Greenberg Traurig, LLP |
|
Good morning Madeline,
Subversion is an international open source project, see
https://en.wikipedia.org/wiki/Apache_Subversion
Tortoise Subversion is a frontend for it, see
https://tortoisesvn.net/about.html
A company that creates TortoiseSVN and exports it does not exist (to my knowledge). So probably nobody ever tried to find out the correct ECCN.
If so, it would have been mentioned here.
At my company, we probably never would distribute TortoiseSVN for exactly this reason. We would advise the customer (how and where) to download it himself.
(I am neither a lawyer nor an export professional, so I may be wrong.)
But not only the fact that cryptographic libraries are used (and AFAIK compiled in), but also, that an American product (MS Visual Studio) is used to create the binary,
complicate things.
So ask your export professional how to find out the correct ECCN, and come back with specific questions like the country of origin of the code or whatever determines the ECCN which he/she is going to ask you.
With best regards
Hartmut
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