Export Control Classification Number (ECCN) for OpenCV
I would like to use OpenCV in commercial software which will be sold in the U.S. For this reason, the legal department asks me about Export Control Classification Number (ECCN) for OpenCV library. From my understanding, the open sources software is not subject to Encryption and Export Administration Regulations (EAR). It is explicitly expressed in libpng README which is a part of OpenCV library:
I am not a lawyer, but I believe that the Export Control Classification Number (ECCN) for libpng is EAR99, which means not subject to export controls or International Traffic in Arms Regulations (ITAR) because it is open source, publicly available software, that does not contain any encryption software. See the EAR, paragraphs 734.3(b)(3) and 734.7(b).
Can anyone confirm that this applies also to OpenCv and library is not a subject to EAR or point a ECCN class for OpenCv?
Does OpenCv use any encryption functionality, which should be mention when applying for ECCN for software which uses the library?