Notice to exporters 2018/03: updates to controls on 'information security' products using cryptography

27 February 2018


Controls on ‘information security’ products, notably those using cryptography, are contained in Category 5 Part 2 ‘Information Security’ of the consolidated list of strategic export controls.

With the use of cryptography becoming more widespread, there has been an increase in the number of items controlled in this category. Simultaneously, there are also more products using cryptography that are excluded from control, both by longstanding ‘decontrol’ notes, listed at the start of Part 2 (such as Note 3, the cryptography note) and by more recent additions to the text.

It has been recognised that ‘information security’ in general is a complex section of controls. Following 2 years of multilateral negotiation between the Wassenaar Arrangement participating states, changes to the text were agreed at the end of 2016 and appeared in the Annex I to Council Regulation (EC) No. 428/2009 (as last amended by Regulation (EU) No. 2268/2017) in late 2017.

Some amendments to the regulation were made in 2016 in preparation for the further 2017 changes detailed in 0.1 below:

  • a new general ‘information security’ note incorporating the content of Note 1, which described the control status of information security equipment - Note 1 was subsequently deleted
  • new sections of control, 5A003 (non-cryptographic information security) and 5A004 (systems … for defeating, weakening or bypassing ‘information security’), have been broken out from the previous 5A002
  • renumbering and deletion of many sub-controls
  • deletion of 5A002.a.7 - ‘non-cryptographic information and communications technology (ICT) security systems and devices that have been evaluated and certified by a national authority to exceed class EAL-6 (evaluation assurance level) of the Common Criteria (CC) or equivalent’

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