#3 Publish U.S. Export Control Classification Number ECCN for secondstring

[Chris Lott]

Please publish an Export Control Classification Number (ECCN) for the secondstring library. To figure out the right ECCN for software, you read the Commerce Control List (CCL) (Supplement No. 1 to Part 774 of the EAR) and try to figure out where the software best fits. In the happiest possible outcome, you will find an exemption (this is better than an exception) that applies to your situation, so that piece of software is not subject to export control, and therefore it has an ECCN of "EAR-99".

Because secondstring has no encryption whatsoever, you will probably wind up writing a statement something like this:

The [XYX Software] primary functions do not include information security; sending, receiving or storing information; or networking; and it is not a computer, operating system, or parts or components therefor. Hence, [XYZ Software], excluding 3rd party software, is not controlled for export per Note 4 to Category 5, Part 2 (Supplement No 1 to Part 774)

This may help:
https://www.bis.doc.gov/index.php/licensing/commerce-control-list-classification/export-control-classification-number-eccn

Thanks for considering it. This will be a big help for those of us who use your libary and have to determine the effective ECCN for the entire package.