App Export Compliance using the Dropbox API?

If your app uses SSL (HTTPS), then yes it does include encryption. The export compliance rules changed last year though, so you will need an Encryption Registration Number instead of a CCATS number. See this blog post for details.

This seems to be the deciding factor as to whether or not the form is needed. – craig Feb 1 at 2:10 As far as I know, the DropBox API uses 256-bit SSL (I may be wrong, but in that case it would still be a minimum of 128 bits). – Johnny Grass Feb 1 at 3:09 Yea, I heard back from the Dropbox folks as well.

ERN is definitely required. What a pain! – craig Feb 7 at 23:25 Getting an ERN shouldn't take more than 2 weeks though, although having to report every year is a little annoying.

– Johnny Grass Feb 8 at 20:33 Yea, I actually obtained my ERN today. Going to submit an update to Apple soon! – craig Feb 9 at 2:01.

As it happens I'm working on this right now on a related project. The Apple position is clarified in the FAQ in iTunesConnect; (my bold) If your App contains, uses or accesses standard cryptography for purposes other than those listed in questions 2-4, you need to submit for an ERN authorization. Examples of standard encryption are: AES, SSL, https.

This authorization requires that you submit an annual report to two U.S. Government agencies with information about your App every January. It's a pain in the neck, but that is the law if you want to be fully compliant. I'd love to hear that I'm wrong though!PS.

You could always ask for a direct opinion from the Government department concerned here; bis.doc.gov/forms/rpdform.html.

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