What is the Export Classification Number (ECCN) for Win32Disk Imager

Created by Tobin Davis on on 2013-08-27
Keywords:
ECCN Export
Last updated by:
Tobin Davis on on 2013-10-22

What is the Export Classification Number (ECCN) of Win32 Disk Imager?

Simple answer - there isn't one.

Until we are told otherwise, this program does not require an ECCN, as it is free open source software. It does not do any encryption/decryption other than to generate an MD5 hash to compare images with download sites' generated MD5 hashes.

The main function of this program is to read/write raw data on removable devices (USB Memory, SD/CF cards, etc). If the data is encrypted already, this program will have no effect on it. Like taking a document and making a copy on a photocopier. If the document is encrypted, the copy will be also.

Here is a more appropriate comment in legal-speak (from MD5.README):

   "... MD-5, N-HASH, and SHS are 'hashing routines' that perform
   a data authentication function and, by themselves, are not
   controlled for export under the ITAR because cryptographic software
   that is solely limited to a data authentication function is excluded
   from Category XIII(b) of the United States Munitions List.
   See 22 C.F.R. Section 121.1 XIII(b)(vi)."

   Source: Karn v. US Department of State,
   "JOINT STATEMENT OF FACTS NOT IN DISPUTE",
   Civ. A. No. 95-1812(CRR), US District Court for the District of Columbia.