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One more thing... on encryption export compliance for iPhone apps

Let me add an important thing to the previous posts (see our first blog post to start from the beginning):

Apple offers a three-step approval that allows you to start selling your application on the iTunes App Store (to limited markets) even before you went through the whole review and approval process with the Government.

Here it is:

If you confirm to Apple that you agree to go through with the CCATS review process, they offer:

1) To allow sales in the U.S. and Canada immediately. For that, first uncheck all the other countries in iTunesConnect (Manage your Application -> Edit Information -> Pricing). Btw. that's 75 clicks, folks. There is no 'uncheck all' button...

2) Now to the most important part of this post: upon receipt of your CCATS application by the Bureau of Information Security, Apple allows sale in the following 34 additional countries:

Australia Austria Belgium Bulgaria Cyprus
Czech Republic Denmark Estonia Finland France
Germany Greece Hungary Iceland Ireland
Italy Japan Latvia Lithuania Luxembourg
Malta Netherlands New Zealand Norway Poland
Portugal Romania Slovakia Slovenia Spain
Sweden Switzerland Turkey United Kingdom

That is BEFORE the approval of the Government, which should save you at least 30 days in the process. And I would say that is a significant amount of countries (and potential customers) that you can sell to prior to approval.

3) When you have got approval and therefore received your CCATS number, Apple will allow worldwide sales. (or to all countries your CCATS allows you to sell to)
More on Animail at:  http://theanimail.com

Posted by The Animail 

Comments (5)

Feb 04, 2010
Jeremy said...
Hi there,

Thanks very much for the information. Looks like we are in the same boat as you. :(

On iTunes Connect, how do you go through the process of confirming to Apple you will go through with CCATS but start selling in US and Canada right away? Once it asks "Does your product contain encryption used for protection of data or information security purposes?" we are FORCED to enter a CCATS PDF.

Do you say your product doesn't contain encryption and then Apple will add the ruling later?

Do you have an appropriate contact at Apple we could ask about this?

Thanks very much!

Jeremy

Feb 04, 2010
The Animail said...
Hi Jeremy,

we selected 'doesn't contain encryption' and then entered the process via e-mail with Apple. But I can't recommend that simply because we don't know yet if this means we have to resubmit our application data or if Apple can change these settings without affecting our existing application info and/or a binary that may already have been submitted in other cases. If you've got the time: it looks like you should only complete it when you've gone through the whole CCATS process.

What we did was sending an e-mail to itunesconnect[at]apple.com. They routed our request to an Export Compliance Specialist who took care of us and offered that 3-step-process. That was all by e-mail and not via iTunesConnect.

Oct 13, 2010
Johan Karlsson said...
Hi,

thank you for a nice article, as the rest of the compliance series. I am curious on how long the process did take.

There seems to be new rules regarding the export laws. Any comment on that? See link for more information.

http://www.bis.doc.gov/encryption/

Regards
Joham

Oct 13, 2010
The Animail said...
Hi Johan,

thanks for the link, I asked our contact at Apple about it and she wrote me that she will send info on the new, simplified process for 'standard encryption'. Sounds promising. I'll update the post as soon as I've got the material.

Florian

Oct 13, 2010
Johan Karlsson said...
Ok, I will wait for your answer then.

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