Using Proguard on api, what 's about ECCN and EAR99, not affected by

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1

Hi, for legal, should my code after ofuscation be declared (US government to be or not subject to EAR encryption controls Likely classified as EAR99)?

We used Proguard on sub-module with strategic core business (java api).
We don’t have encryption source code but our code is obfuscated.

Do you think our api because is obfuscated is concerned by ECCN ( Encryption Classification Process Flow) ?

2

Hi OChantereau,

Processing your software application or SDK with ProGuard will not impact the Export Administration Regulations (hereinafter - EAR) applicability of your product.

ProGuard does not embed cryptography in the Final Product. According to Part 772 of the EAR, ProGuard embeds Fixed compression and coding techniques, which are not in scope of cryptographic information security.

I hope this helps, but please let me know if you want me to elaborate.