Alternative way
Start by asking the user. For example, give them a button to skip that long introduction (and an easy way to get back there).
If it's a time-consuming step, allow them to email or export that data and give them a very easy way to get it back in there.
It would be helpful to know exactly what you're trying to achieve.
Clarification
Keychain will not function without encryption. All users having ICloud keychain storage enabled are transmitting your data in encrypted form over the Internet.
Currently (2022) when you assign an uploaded build to your app publication on Apple's appstoreconnect.apple.com, the Export Compliance Information dialog box asks:
Does your app qualify for any of the exemptions provided in Category 5, Part 2 of the U.S. Export Administration Regulations?
You can select Yes for this question if the encryption of your app is:
...
(a) Specially designed for medical end-use
(b) Limited to intellectual property and copyright protection
(c) Limited to authentication, digital signature, or the decryption of data or files
(d) Specially designed and limited for banking use or “money transactions”; or
(e) Limited to “fixed” data compression or coding techniques
If your usage isn't exempt per the above (etc.) then you'd need to submit the form.
Here's a discussion on this...
https://getonthestore.com/export-compliance/
...and a helpful form generator...
https://github.com/annual-self-classification-report/annual-self-classification-report.github.io
Lobbying
Further, why not contact Apple to request them to clarify the clearcut case of Keychain (etc.) and for them to lobby the US Government on behalf of developers to publish a more full list of scenarios, if you believe this is relevant? Be clear that you're not after legal advice per se.
https://developer.apple.com/contact/topic/select
⬅ The rabbit warren starts here.
https://www.apple.com/public-policy-advocacy/
⬅ An overview of Apple's public policy advocacy.