Annual self-classification report is required for commodities exported or reexported under 740.17(b)(1) and 742.15(b)(1), effective June 25, 2010.
CCATS for commodities issued by or submitted to BIS prior June 25, 2010 and that are now described under 740.17(b)(1) or 742.15(b)(1) are not required to be listed in the Annual Self-Classification Report, provided the cryptographic functionality of the item has not changed. These items are grandfathered under the June 25th rule.
The following table provides an example of the various fields required within the Annual Self-Classification Report as required per 742.15(c) and demonstrates how various instructions & tips published in Supplement 8 to part 742 works out in practice.
- First line of the annual self-classification report must consist of the following six entries: PRODUCT NAME, MODEL NAME, MANUFACTURER, ECCN, AUTHORIZATION TYPE, ITEM TYPE
- No entry may be left blank
- PRODUCT NAME and ECCN must be completed
- For MODEL NUMBER and MANUFACTURER, if necessary, enter 'NONE' or 'N/A'"
- For AUTHORIZATION TYPE, enter ENC or MMKT.
- For ITEM TYPE, pick from the list of item types provided in the Supp. 8 to Part 742 (a)(6).
- The only permitted use of a comma is as the necessary separator between the 6 entries for each line item. The only commas allowed are the ones inserted automatically during spreadsheet conversion.
- An encryption self-classification report data table created and stored in spreadsheet format can be converted and saved into a comma delimited file (.CSV) format directly from the spreadsheet program.
PRODUCT NAME |
MODEL NUMBER |
MANUFACTURER |
ECCN |
AUTHORIZATION TYPE |
ITEM TYPE |
XtraGood VPN |
2010 |
ABC XYZ Manufacturing Inc |
5A002 |
ENC |
virtual private networking (VPN) |
XtraGood Firewall |
1100 |
SELF |
5A002 |
MMKT |
firewall |
XtraGood WLAN chipset |
XG-80211-xxxx |
MULTIPLE |
5A002 |
ENC |
wireless local area networking (WLAN) |
XtraGood Client Manager Suite |
1xx |
PDQ123 Software Services LLC |
5D992 |
MMKT |
network or systems management (OAM / OAM&P) |
XtraGood Connectivity AP |
300-xxx |
MULTIPLE |
5A992 |
MMKT |
access point |
XtraGood Connectivity Client Manager |
NONE |
PDQ123 Software Services LLC |
5D992 |
MMKT |
network or systems management (OAM / OAM&P) |
XclusiveAgent – Pro Ed. |
5xx |
SELF |
5D002 |
ENC |
file encryption |
XclusiveAgent – Home Ed. |
100 |
SELF |
5D992 |
MMKT |
file encryption |
Xclusive Agent Secure Storage Device |
XA-SHD-xxx |
MULTIPLE |
5A992 |
MMKT |
disk / drive encryption |
XclusiveAgent Enterprise Key Token |
XA-KT-xxx |
ABC XYZ Manufacturing Inc |
5A002 |
ENC |
key storage |
XclusiveAgent PKI |
NONE |
SELF |
5D002 |
ENC |
key management |
Xclusive Agent Secure USB Drive |
XA-SUSB-xxx |
MULTIPLE |
5A992 |
MMKT |
disk / drive encryption |
The following screen shots provide guidance on how to create the .csv file for submission:
1. Sample screen shot of spreadsheet including doing a "Save As..." [into .CSV format] from the spreadsheet application, like the exporter would do in creating their actual self-classification report for submission to BIS and NSA.
2. Sample screen shot of .CSV file as viewed in the spreadsheet application. This is the file that exporters will attach to their e-mails to BIS and NSA.
3. Sample .CSV file when viewed in Notepad. To check the validity of your CSV file, you may open the new file from a plain-text reading program such as Notepad or TextEdit.
Submit your annual self-classification report electronically to BIS as an email attachment to crypt-supp8@bis.doc.gov and enc@nsa.gov with subject “Self-classification report for ERN R######”, using your most recent Encryption Registration Number.
In your submission, specify the export time frame that your report spans and identify points of contact to whom questions or other inquires pertaining to the report should be directed.