Export Compliance in iTunes Connect

Report · Dec 09, 2011

Hey

i´m going to publish my first app for the app store.

Now i have some trouble with the "Export Compliance" in "iTunes Connect".

I use encryption in my app with the jpegencoder class to get a byte array. This byte array goes trough a base64 encoding on the iPhone.

var jpgEncoder:JPGEncoder = new JPGEncoder();
var ba:ByteArray = jpgEncoder.encode(bd);
var encoded:String = Base64.encodeByteArray(ba);

After this i send the encoded string to my server.

The server decrypt the string and creates an image file.

I send the url of the image back to my iPhone.

The e-mail client opens and the picture is visible in the mail via html mail.

I really don´t know how to answer the second question. Some ideas?

Is your product designed to use cryptography or does it contain or incorporate cryptography? <--- Yes

Does your product qualify for any of the exemptions provided in Category 5 part 2?

You are responsible for the proper classification of your product; make certain that it meets the criteria of the exemption (listed here). Otherwise you may be in violation of the US export laws and could be subjected to penalties including delisting of your app from App Store. Please go through the FAQ page thoroughly before attempting to answer the question.

You can answer "YES" to question #2, if the encryption in your app is: (a) is specially designed for medical end-use; (b) is limited to intellectual property or copyright protection; (c) is limited to authentication, digital signature or the decryption of data or files; (d) is specially designed and limited for banking use or 'money transactions'; (e) is limited to “fixed” data compression or coding techniques; or (f) if your app meets the descriptions provided in Note 4 to Category 5 Part 2.

Please visit the FAQ for additional guidance on the exemptions. <---- In my opinion i have to answer with "Yes" but i am not sure.

thanks in advance

Report · Dec 09, 2011

You should answer "no" to question one. Base64 is encoding, not encryption, anyone receiving the data can decode it without needing an encryption key. It doesn't involve encryption any more than XML or JSON would. Here's a short discussion on the topic:

http://stackoverflow.com/questions/1513552/is-base64-considered-encryption-in-an-iphone-app

Report · May 02, 2018

Old thread but same themed Q - we're using an encrypted SQLLite DB and EncrptedLocalStore - so I'm assuming that means we'll need export compliance, right?

If so, have you Colin, or has anyone else been through this process that can offer a few links or words of advice?

Much appreciated.