I'm uploading a binary for the first time. iTunes Connect has asked me:
Export laws require that products containing encryption be properly authorized for export.
Failure to comply could result in severe penalties.
For further information, click here.
Does your product contain encryption?
I use https://, but only via NSURLConnection and UIWebView.
My reading of this is that my app doesn't "contain encryption," but I'm wondering if this is spelled out anywhere. "Severe penalties" doesn't sound pleasant at all, so "I think that's right" is a bit sketchy... an authoritative answer would be better.
Thanks.
UPDATE: Using HTTPS is now exempt from the ERN as of late September, 2016
https://stackoverflow.com/a/40919650/4976373
Unfortunately, I believe that your app "contains encryption" in terms of US BIS even if you just use HTTPS (if your app is not an exception included in question 2).
Quote from FAQ on iTunes Connect:
"How do I know if I can follow the Exporter Registration and Reporting (ERN) process?
If your app uses, accesses, implements or incorporates industry standard encryption algorithms for purposes other than those listed as exemptions under question 2, you need to submit for an ERN authorization. Examples of standard encryption are: AES, SSL, https. This authorization requires that you submit an annual report to two U.S. Government agencies with information about your app every January.
"
"2nd Question: Does your product qualify for any exemptions provided under category 5 part 2?
There are several exemptions available in US export regulations under Category 5 Part 2 (Information Security & Encryption regulations) for applications and software that use, access, implement or incorporate encryption.
All liabilities associated with misinterpretation of the export regulations or claiming exemption inaccurately are borne by owners and developers of the apps.
You can answer “YES” to the question if you meet any of the following criteria:
(i) if you determine that your app is not classified under Category 5, Part 2 of the EAR based on the guidance provided by BIS at encryption question. The Statement of Understanding for medical equipment in Supplement No. 3 to Part 774 of the EAR can be accessed at Electronic Code of Federal Regulations site. Please visit the Question #15 in the FAQ section of the encryption page for sample items BIS has listed that can claim Note 4 exemptions.
(ii) your app uses, accesses, implements or incorporates encryption for authentication only
(iii) your app uses, accesses, implements or incorporates encryption with key lengths not exceeding 56 bits symmetric, 512 bits asymmetric and/or 112 bit elliptic curve
(iv) your app is a mass market product with key lengths not exceeding 64 bits symmetric, or if no symmetric algorithms, not exceeding 768 bits asymmetric and/or 128 bits elliptic curve.
Please review Note 3 in Category 5 Part 2 to understand the criteria for mass market definition.
(v) your app is specially designed and limited for banking use or ‘money transactions.’ The term ‘money transactions’ includes the collection and settlement of fares or credit functions.
(vi) the source code of your app is “publicly available”, your app distributed at free of cost to general public, and you have met the notification requirements provided under 740.13.(e).
Please visit encryption web page in case you need further help in determining if your app qualifies for any exemptions.
If you believe that your app qualifies for an exemption, please answer “YES” to the question."
It's not hard to get approval for your app the proper way. SSL (HTTPS/TLS) is still encryption and unless you are using it just for authentication, then you should get the proper approval. I just received approval, and my app is in the store now for something that uses SSL to encrypt data traffic (not just authentication).
Here is a blog entry I made so that others can do this the proper way.
apple itunes export restrictions
Short answer: Yes, but you don't have to do anything
I was searching the web for this for some hours. Actually it is pretty easy and you can verify this in itunes connect:
1. All you have to do
If your app uses only HTTPS or uses encryption only for authentication, tokens, etc., there is nothing you have to do, just include
<key>ITSAppUsesNonExemptEncryption</key><false/>
in your Info.plist and you are done.
2. Verification
You can verify this in itunes connect.
select your app
chose features
chose encryption
click "+"
follow the dialog
for https or authentication the answer is yes and yes
In any case you should of course read yourself carefully through the dialog.
A very helpful article can be found here:
https://www.cocoanetics.com/2017/02/itunes-connect-encryption-info/
I asked Apple the very same question and got the answer (from a Sr. Export Compliance Specialist), that "sending information over https is forcing the data to go through a secure channel from SSL, therefore it falls under the U.S. Government requirement for a CCATS review and approval." Note that it doesn't matter that Apple has already done this for their SSL implementation, but for the government, if you USE encryption that is the same (to them) as you would've coded it yourself. I also updated our blog (http://blog.theanimail.com) since Tim linked to it with updates and details on the process. Hope that helps.
All of this can be very confusing for an app developer that's simply using TLS to connect to their own web servers. Because ATS (App Transport Security) is becoming more important and we are encouraged to convert everything to https - I think more developers are going to encounter this issue.
My app simply exchanges data between our server and the user using the https protocol. Seeing the words "USES ENCRYPTION" in the disclaimers is a bit scary so I gave the US government office a call at their office and spoke to a representative of the Bureau of Industry and Security (BIS) http://www.bis.doc.gov/index.php/about-bis/contact-bis.
The representative asked me about my app and since it passed the "primary function test" in that it had nothing to do with security/communications and simply uses https as a channel for connecting my customer data to our servers - it fell in the EAR99 category which means it's exempt from getting government permission (see https://www.bis.doc.gov/index.php/licensing/commerce-control-list-classification/export-control-classification-number-eccn)
I hope this helps other app developers.
If you use the Security framework or CommonCrypto libraries provided by Apple you do include crypto in your App and you have to answer yes - so simply because libraries were provided by Apple does not take you off the hook.
With regards to the original question, recent posts in the Apple Development Forums lead me to believe that you need to answer yes even if all you use is SSL.
As of September 20th, 2016, registering is no longer required for apps that use https (or perhaps other forms of encryption): https://web.archive.org/web/20170312060607/https://www.bis.doc.gov/index.php/informationsecurity2016-updates
In fact, on SNAP-R you can no longer choose 'encryption registration':
Specifically, they note:
Encryption Registrations no longer required – some of the information
from the registration now goes into the Supp. No. 8 to Part 742
report.
This means you may need to send an annual report to BIS, but you don't need to register and you can note when submitting your app that it is exempt.
Yes, according to iTunes Connect Export Compliance Information screens, if you use built-in iOS or MacOS encryption (keychain, https), you are using encryption for purposes of US Government Export regulations. Whether you qualify for an export compliance exemption depends on what your app does and how it uses this encryption. Attached images show the iTunes Connect Export Compliance Screens to help you determine your export reporting obligations. In particular, it states:
If you are making use of ATS or making a call to HTTPS please note that you are required to submit a year-end self classification report to the US government. Learn more
#hisnameisjimmy is correct: You will notice (at least as of today, Dec 1st 2016) when you go to submit your app for review and reach the Export Compliance walkthrough, you'll notice the menu now states that HTTPS is an exempt version of encryption (if you use it for every call):
I found this FAQ from the US Bureau of Industry and Security very helpful.
encryption
Question 15 (What is Note 4?) is the important point:
...
Examples of items that are excluded from Category 5, Part 2 by Note 4 include, but are not limited to, the following:
Consumer applications. Some examples:
piracy and theft prevention for software or music;
music, movies, tunes/music, digital photos – players, recorders and organizers
games/gaming – devices, runtime software, HDMI and other component interfaces, development tools
LCD TV, Blu-ray / DVD, video on demand (VoD), cinema, digital video recorders (DVRs) / personal video recorders (PVRs) – devices, on-line media guides, commercial content integrity and protection, HDMI and other component interfaces (not videoconferencing);
printers, copiers, scanners, digital cameras, Internet cameras – including parts and sub-assemblies
household utilities and appliances
Simple answers are Yes(App has encryption) and Yes(App uses Exempt encryption).
In my application, I am just opening my company's website in WKWebView but as it uses "https", it will be considered as exempt encryption.
Apple document for more info: https://developer.apple.com/documentation/security/complying_with_encryption_export_regulations?language=objc
Alternatively, you can just add key "ITSAppUsesNonExemptEncryption" and value "NO" in your app's info.plist file. and this way iTunes connect won't ask you that questions anymore.
More info: https://developer.apple.com/documentation/bundleresources/information_property_list/itsappusesnonexemptencryption?language=objc
You can follow these 3 simple steps to verify if your application is exempt or not: https://help.apple.com/app-store-connect/#/dev63c95e436
You may need to submit this annual-self-classification to US gov. For more info: https://www.bis.doc.gov/index.php/policy-guidance/encryption/4-reports-and-reviews/a-annual-self-classification
LOOKS LIKE HTTPS COUNTS
link to "Learn more":
https://www.bis.doc.gov/index.php/policy-guidance/encryption/4-reports-and-reviews/a-annual-self-classification
Just adding my personal interpretation of a very special case:
In my app the user has the option to go to a website themselves or let my app open Safari and Safari will call an HTTPS website. Could be any - own website, article etc etc. I interpret Safari making the actual HTTPS call, not my app and therefore answer the first question with No (or set the flag in the info.plist) and have no requirement to annually report.
If you're not explicitly using an encryption library, or rolling your own encryption code, then I think the answer is "no"
Related
This question is like two questions in one.
Firstly, did I choose the correct radio button for my case?
Secondly, where do I get the "French encryption declaration approval form"?
QUESTION 1
The following screenshots are from App Store Connect (in the "TestFlight" tab):
Now here^^ arises my first question.
The main purpose of my app is: language learning app
I myself have not programmed anything related to encryption, and I assume neither have the developers or the packages I'm using (* listed at the end of this question), so I think I can exclude radio-button 1 and 3.
My app uses firebase (backend) services, all of which encrypt data in transit using HTTPS, according to the official docs.
HTTPS IS a standard encryption algorithm, but the way the 2nd radio-button was phrased,
I don't know if I am supposed to choose the 2nd or the 4th radio-button.
QUESTION 2
I haven't tried proceeding with the 4th radio-button (yet).
I have tried with the 2nd radio button, which follows up with the question if my app is going to be available in France. I don't want to miss out on any market so I chose "yes" of course. Then I am lead to the "Encryption" page, where I eventually have to upload a "French encryption declaration approval form".
Now this is the problem. There is absolutely no information in app store connect or any of the apple docs on how to get this "French encryption declaration approval form". I have searched all across the web, and have found other people asking where to get this, but no one seems to have the answer.
In the meantime, I will be trying to contact Apple, Google and the French government, and if I get a useful answer from them, I will share it here.
*
The flutter packages which I'm using:
If you are sure you don't use any encryptiong algorithms, you can add below key to your info.plist file so you don't manually do this everytime :
<key>ITSAppUsesNonExemptEncryption</key>
<false/>
What technical detail should programmers consider while developing their own oAuth service?
Have been trying to find out guidelines, but found most of the oAuth related articles discuss as a consumer point of view (i.e. how to consume others service). I want to design my own oAuth system with my authorization service and resource service. What technical detail should I follow?
You probably have read the RFCs but just in case you haven't, they're the place you want to start:
oAuth 2.0 "core" (RFCs 6749 and 6750)
Proof Key for Code Exchange (PKCE) (RFC 7636)
The best 'packaged' guidance for oAuth implementers (client or otherwise) is available via IETF Best Current Practices (BCPs). Most people know about IETF RFCs and (confusingly) BCPs are published as RFCs with a RFC number. Despite that, they're best practices and not formal specifications:
The BCP process is similar to that for proposed standards. The BCP is
submitted to the IESG for review, and the existing review process
applies, including a "last call" on the IETF announcement mailing
list. However, once the IESG has approved the document, the process
ends and the document is published. The resulting document is viewed as having the
technical approval of the IETF, but it is not, and cannot become an official Internet Standard.
BCPs you want to review:
oAuth security (up to date as of this writing)
oAuth for browser-based apps (up to date as of this writing).
oAuth for native apps (published in 2017 as an update to "core" oAuth 2.0 RFC, still a good read)
JSON Web Tokens for oAuth (up to date)
These documents are framed in threat model terms - they cover attacks (or "security considerations" as a diluted format) and countermeasures. You might be looking for a more straightforward building blocks type of a roadmap and perhaps there should be one as an educational tool. Real-world oAuth implementations must be developed with a prima facie evidence of a threat model.
As one samurai said: ...swordsmanship untested in battle is like the art of swimming mastered on land.
I would also be interested to hear why you want to develop your own auth solution.
But putting that aside, there is an open source project that does exactly what you ask - Identity Server. You can check out their source code or fork it and build something on top of it.
Also, please check "identigral" answer on various docs.
my app has passed the first review (yay) - but has now been passed to Allion for 'hardware review'.
The issue is that I am not providing hardware, i've provided voice interactions for an open source HA system, which in turn can support 00s of device types.
The Amazon review process was happy for me to provide them credentials to my service, which had access to a subset of device types, to then QA the interactions.
Is this normal for the review process?
Thus far many of the supported services have been direct hardware partners who own their own hardware and cloud. If your integration is done in a slightly different way it may require special instructions to your reviewer that may be different from normal.
I have had further comment from Google. Unless I can provide 1 of every type of physical device that the underlying HA system supports, they will not review, or certify my app. What this tells me is that either Google aren't committed to small SaaS providers & HA enthusiasts, or that this comment is not true. I note that there are several equivalent services listed on Smart home app list, which do exactly the same thing as mine. I rather doubt they provided one of every manufacturers zwave switch/light etc etc. Very disappointing, Amazon have a more welcoming approach –
I originally posted this question as an 'answer' to:
Can a single company really not use QB API?...Semi Rant
but am reposting, because it is a question.
The original poster and I face a similar problem wanting to use the QBO API for an application designed for a single company. What would be the disadvantage of connecting my app to my QBO account using the intuit development server indefinitely, i.e., never take my app through the production qualification process?
Thank you.
I believe that is possible but then you can use at max 10 developer connections.
As we already mentioned we do not not support custom integrations at this time.
Even we wouldn’t recommend moving you to production as it would cost us $1k per year to security review it, and we would only recover about $60 per year in connection fees.
So, the disadvantage for you will be in terms of number of connections, limited support and your app vulnerability since it has not gone through the security review process.
Please read the policy docs mentioned here:
https://developer.intuit.com/docs/0025_quickbooksapi/0005_introduction_to_quickbooksapi/z_developer_policies_and_guidelines
Edit for the question asked:
When you login into developer.intuit.com, Go to Manage My Apps, then click your app.
You will see the number of connections for that app under Test connections.
It refers to the numbers of company files your app is associated with or has been authorized to access data.
I don't know how to answer the question:
Export laws require that products containing encryption be properly authorized for export.
Failure to comply could result in severe penalties.
For further information, click here.
Is your product designed to use cryptography or does it contain or incorporate cryptography?
Yes No
I am not a lawyer, but the question is related to 'are you implementing/using encryption explicitly'. If you're only making use of https, then the answer to this question is no.