Export Compliance Information

(Updated March 2, 2020)

Export Compliance

Syncro Soft ("Syncro") software products may be subject to international rules that govern the export of software. The information contained on this page is provided to aid our channel partners and end customers in their export compliance efforts and it should not be considered a source of legal guidance or advice.

IMPORTANT

Before considering the export of a Syncro product, customers should review the End-User License Agreement (see "Export Regulations" clause) that came with the product to verify if the terms of the agreement allow the product to be moved out of a given country or region.

Laws and Regulations

Syncro products are considered “Country of Origin: Romania”. Even if the Syncro software products are developed outside the U.S, they contain controlled U.S-origin items and are subject to U.S. Export Administration Regulations (EAR). Therefore, the export or re-export of these products, or transfer of these technologies, is subject to the export laws and regulations of the United States. The primary agencies that administer and enforce these laws and regulations are the Bureau of Industry and Security("BIS") and the Office of Foreign Assets Control.

In addition to U.S. export and re-export controls, Syncro software products are also subject to European Union (EU) export controls if they are exported from an EU location to a destination outside the EU. Parties exporting Syncro software products from the EU should obtain proper export licenses as required under EU rules (Council Regulation (EC) No. 428/2009) and Member State laws.

Similar requirements may apply to Syncro software products exported from other countries, located outside the U.S.A. and the E.U., depending on the jurisdiction governing the company that exports Syncro software products.

Encryption products are also subject to import restrictions in certain countries, including prior notification and licensing requirements.

ECCN Information

An ECCN is an alphanumeric reference (for example, 5D992) that the United States Export Administration Regulations use to identify items for export control purposes. An ECCN is used to categorize products based on the type of commodity, technology, or software and its respective technical parameters, such as the encryption algorithm a product uses, the processing capabilities of an integrated circuit, or positioning accuracy in machine tools (reference: www.bis.doc.gov)

The following ECCN classifications are based on unmodified software products in original condition, as shipped by Syncro:

ECCN/EAR's Assigned to Syncro Soft software products

Software Product Name	ECCN	Eligible License Exception	CCATS
Oxygen XML Editor	5D992.c	Mass Market- NLR	Self-Classified (according to §740.17(a)(3))
Oxygen XML Developer	5D992.c	Mass Market- NLR	Self-Classified (according to §740.17(a)(3))
Oxygen XML Author	5D992.c	Mass Market- NLR	Self-Classified (according to §740.17(a)(3))
Oxygen XML Web Author	5D992.c	Mass Market- NLR	Self-Classified (according to §740.17(a)(3))
Oxygen XML SDK	5D002	ENC( §740.17)	Self-Classified (according to §740.17(a) (1))
Syncro SVN Client	5D992.c	Mass Market- NLR	Self-Classified (according to §740.17(a)(3))
Oxygen XML WebHelp	EAR99	NLR	Self-Classified
Oxygen PDF Chemistry	5D992.c	Mass Market-NLR	Self-Classified (according to §740.17(a)(1))

Note

Mass Market - identifies that the item meet the criteria for Mass Market status (742.15) as defined by the “Cryptography Note” of the Commerce Control List (CCL), see Note 3 to Category 5, Part 2.

According to EAR 742.15(b)(4)(ii), foreign products developed with or incorporating U.S.-origin encryption source code, components or toolkits (including products that are designed to operate with U.S. products through a cryptographic interface) that are subject to the EAR are exempted from submission of an encryption registration, classification request or self-classification report to BIS for export or re-export as mass market products, provided that the U.S.-origin encryption items have previously been classified or registered and authorized by BIS and the cryptographic functionality has not been changed. Oxygen XML Editor is a family of such foreign software products which are bundled with the following U.S-origin libraries with their respective classification, as per the following table:

ECCN Third-party libraries

Product Name	ECCN	Eligible License Exception	Owner
Java Platform Standard Edition 7 (JDK) Binary	5D992	NLR- Mass Market	Oracle
Apache HttpComponents Project	5D002	TSU EAR 742.15(b)	Apache Software Foundation
Apache POI	5D002	TSU EAR 742.15(b)	Apache Software Foundation
Apache WSS4J	5D002	TSU EAR 742.15(b)	Apache Software Foundation
Apache Commons Project	5D002	TSU EAR 742.15(b)	Apache Software Foundation
Apache Ant	5D002	TSU EAR 742.15(b)	Apache Software Foundation
Apache Shiro	5D002	TSU EAR 742.15(b)	Apache Software Foundation
Apache PDFBox	5D002.C.1	TSU EAR 742.15 (2)(b)	Apache Software Foundation
Eclipse Modeling Framework	5D002	ENC unrestricted (TSU)	Eclipse Foundation
Eclipse Web Tools Platform	5D002	ENC unrestricted (TSU)	Eclipse Foundation

All software products developed using Oxygen XML SDK are subject to the EAR and may have different export restrictions and require a different ECCN. These software products may require the submission of a classification request or encryption registration before sale, reexport or transfer, unless otherwise authorized by license or license exception.

IMPORTANT

However, without limitation, the Syncro software may not be exported or reexported:

(a) to certain prohibited countries (e.g.,Cuba, Iran, North Korea, Sudan, Syria and the Crimea region of Ukraine)
(b) to prohibited persons or entities, including those on the Bureau of Industry and Security’s Denied Persons List, Unverified List or Entity List, or on the Office of Foreign Assets Control’s list of Specially Designated Nationals and Blocked Persons, or other export control lists
(c) for any prohibited end-use, including, without limitation, nuclear, chemical or biological weapons proliferation, or development of missile technology

The U.S. government's consolidated export screening list is located at the following link: http://www.export.gov/ecr/eg_main_023148.asp. All parties to a transaction should be screened against this list prior to export or re-export.

Please note that end-users, end-use, and country of ultimate destination may affect your export licensing requirements. You are ultimately responsible for exporting Syncro products in accordance with the EAR. We encourage you to consult the BIS and any other appropriate sources before you export or reexport Syncro products.

Legal Note

Syncro provides this information page for your reference only. Since the export control laws are frequently amended, it is important to recognize that the information posted on this page may not include the most recent changes to these laws and how the changes may affect our products. As such, Syncro does not represent, warrant or guarantee that the posted information is complete, accurate or up-to-date. The information does not nor is it intended to be legal advice.

We encourage all parties exporting or re-exporting Syncro products to consult the EAR, contact BIS, and/or obtain appropriate legal advice related to their transactions. For more information regarding exports from or imports into the EU or other jurisdictions, it may be advisable to obtain legal guidance and/or contact the administrative body responsible for export and import requirements in the jurisdiction in question.

If you have any questions, please contact