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BIS has created a new SNAP-R screen for encryption registrations. The instructions for submitting an encryption registration are found in paragraph (r) of Supplement No. 2 to Part 748.
In block 5 (Type of Application) of SNAP-R, selecting “encryption registration” will result in the appearance of the new encryption registration screen. On that screen blocks 1-5, 14, 15, 24, and 25 are to be completed, and a PDF must be attached that provides answers to Supplement No. 5 to Part 742.
Here is a link to an example view in SNAP-R.
When an encryption registration is submitted via SNAP-R, SNAP-R will issue an Encryption Registration Number (ERN), which will start with an “R” and will be followed by 6 digits, e.g., R123456. This registration number is confirmation that BIS has received your encryption registration.
A company that exports under the authorization of the encryption registration does not need to resubmit its encryption registration unless the answers to the questions in Supplement No. 5 to Part 742 changed during the previous calendar year.
How do I complete the Supplement 5 if I am filing on behalf of a manufacturer (or producer) of an encryption items (e.g., law firm/consultant)?
If you are filing as an agent for the exporter (e.g., a law or consulting firm), block 14 (applicant) must pertain to the company that seeks authorization to export. The agent may, however, list itself in block 15 (“other party authorized to receive the license”).
What if you are not the manufacturer or producer of the item or not filing directly on behalf of the manufacturer or producer (e,g., law firm/consultant)?
If the registrant is not the principal producer (or filing on behalf of the principle producer) of encryption items, the registrant may answer questions 4 and 7 as “not applicable.” For all other questions, an answer must be given, or if the registrant is unsure of the answer, the registrant may state that it is unsure and explain why.
Using a manufacturer’s Encryption Registration Number (ERN):
Once a manufacturer (or producer) of the encryption item submits its Encryption Registration (i.e., the information described in Supplement No. 5 to Part 742 of the EAR) to BIS, the manufacturer’s encryption items become eligible for export and reexport under the applicable provision of section 740.17(b) and 742.15(b) of the EAR, subject to the conditions and restriction of those sections.
Encryption Registration Numbers (ERN) issued to the manufacturer (or producer) authorize the export and reexport of the manufacturer’s encryption items by all persons, wherever located, who are eligible to use the applicable provisions of section 740.17(b) and 742.17(b) of the EAR.
If the manufacturer will not share its ERN, has not filed for an ERN, or you cannot locate the manufacturer’s ERN, then the exporter (non-producer) should file for the exporter’s own ERN.