EAR99 vs. Category 5

How Exporters are Managing De-Controlled Encryption Products, the Internet of Things, and the Interplay with Foreign Requirements

March 27, 2018 4:15pm

Laura Webster Kersiek
Global Export Compliance Manager
Netflix (Los Gatos, CA)

Melissa L. Duffy
Hughes Hubbard & Reed LLP (Washington, DC)

  • How to determine whether encryption products may be de-controlled as EAR99
  • What types of products typically qualify for de-control
    • Evaluating examples such as medical products, industrial equipment controllers, entertainment items and more
  • Mismatch with US 5A/D992 mass market controls having no equivalent in other WASSENAAR countries
  • How to evaluate the product’s core or primary function to do business in China and Russia