Does my application "contain encryption"?

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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.

14 Answers

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.

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.

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

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"

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