FAQ: What is the U.S. Export Control Classification Number (ECCN) for the Viewer software?

LockLizard Viewers do not have an ECCN number.

Hardware or software implementing cryptographic functions can be considered to fall within Export Controls implemented in the Wassenaar Arrangement (WA, see www.wassenaar.org).  This is because they may have military application.

However, there are many examples where cryptography implemented in software is necessary for general commercial use (SSL for instance) and therefore where export control would be counter-productive.  As a result, software based cryptography is listed as dual-use goods that may be exported without a general license provided that a number of tests have been met, including:

– that the encryption scheme cannot be changed by the end user;
– that the product is sold or provided to the public from commercial premises or Internet web site.

The LockLizard Viewers do not enable their user(s) to encrypt information, and, as such, fall outside the scope of the WA.  Thus no license or declaration is required for the export of the Viewers.  That should not be taken to mean that they can be freely imported into all countries, but no restrictions of that nature have been brought to our attention.

The LockLizard Writer applications and the Server applications do provide functionality that allows the user to encrypt information.  However, they also fall within the exemption tests for dual-use goods under the WA, and are exported from the United Kingdom on that basis.

At the same time, there are a number of nation states (Cuba, Iran, North Korea, Sudan, and Syria at the time of writing but this should be checked) to which export is not permitted, and LockLizard examine purchase requests to check that these countries (as varied from time to time) are not evidently the intended destination.  If that is found to be the case at the time or subsequently, LockLizard retain the right to cease service without notice or redress.  Purchasers of LockLizard products who subsequently ship or otherwise transfer them to embargoed destinations are advised that they may be liable to prosecution both for breach or contract and by their own government for breach of export regulations.