Notification is an approval document to be delivered to the customs authority when importing certain goods in the customs territory of the Customs Union of Russia, Belarus and Kazakhstan and when exporting goods from this territory as well.
According to p. 2.19 of “Unified List of Goods To Be Banned or Restricted on Import and Export by Member States of the Customs Union within Eurasian Economic Community for Trade with Third States”, restricted good are radio communication, electronics and telecommunication equipment and other devices, which contain cryptography (encryption). Notification shall be issued for products, which contain encryption algorithm, tools and TPM module.
Notification can be applied to be registered on behalf of:
- Russian manufacturer;
- Russian company that is representative of the foreign manufacturer based on apostilled power of attorney.
List of good (products) that are encryption (cryptographic) tools or contain encryption (cryptographic) tools, whose technical and cryptographic data to be notified.
1. Products with encryption (cryptographic) tools and containing any of following component:
- symmetric cryptographic algorithm using crypto key with the length max. 56 bits or
- asymmetric cryptographic algorithm based on any of the following methods:
a) factorization of integers that do not exceed 512 bits;
b) calculation of discrete logarithms in a multiplicative group of a finite field that do not exceed 512 bits; or
c) discrete logarithm in a group, that is different than the title in the above paragraph "b" size that do not exceed 112 bits.
- Parity bits are not included in the key length.
- The term “cryptography” is not related to fixed compression methods or data coding.
2. Products containing encryption (cryptographic) tools, with limited functions:
a) authentication, which includes all aspects of access control where there is no encryption of files or text except for encryption, which is directly related to the protection of passwords, personal identification numbers or similar data to prevent unauthorized access;
b) digital signature.
Functions of authentication and digital signature include related key distribution functions.
3. Encryption (cryptographic) tools, which are the software components of operating systems, whose cryptographic capabilities cannot be changed by users, which are designed for installation by the user without further substantial support provider and technical documentation (description of the algorithms of cryptographic transformations, communication protocols, interfaces, and so the description etc.) which is accessible.
4. Personal smart cards:
a) whose the cryptographic capability is restricted for use in equipment or systems referred to in paragraphs 5 - 8 of this list; or
b) for wide public use, whose the cryptographic capability is not accessible for user and which have a limited ability to protect the stored personal data on them as a result of a special design.
If the smart card can perform different functions, the control status of each function is determined separately.
5. Reception equipment for radio broadcast, commercial television or similar commercial equipment for broadcasting in limited audience, without digital encryption except when it is used solely for managing the encryption of video or audio channels and sending bills or return information related to program providers broadcast.
6. Equipment, whose cryptographic capability is not accessible for user, specially designed and limited to allow any of the following:
a) the software is executed in the form of a copy-protected;
b) access to any of the following:
• Copy-protected contents stored only readable storage medium;
• Information stored in encrypted form on medium when the medium is offered for sale in identical sets;
c) control of the copy of audio and video data protected by copyright.
7. Encryption (cryptographic) equipment specially designed and limited for banking use or money transactions.
Note. Financial transactions include fees and payment for transport services and lending.
8. Portable or mobile radio-electronic means of civil use (e.g. for use in commercial civil radio communications systems) that are not capable of end-to-end encryption (from subscriber to subscriber).
9. Wireless electronic equipment, encrypting the information only in the radio channel with a maximum range of wireless action without amplification and retransmission of less than 400 meters according to the manufacturer's specifications.
10. Encryption (cryptographic) means used to protect the technological channels of information and telecommunication systems and networks.
11. The goods for which the manufacturer disables the cryptographic function.
Terms of equipment import / export without notifying the FSS and license of the Ministry of Industry and Trade are determined by paragraph 8 of the Regulation "On the Procedure for Import into the Customs Territory of the Customs Union and Export from the Customs Territory of the Customs Union of Encryption (Cryptographic) Means." According to this point temporary (transit) import / export of the equipment without obtaining permits is possible:
- to repair equipment;
- to replace under the contract;
- to carry out technical expertise;
- for the purpose of scientific research;
- to participate in exhibitions;
- for the needs of the company (organization), without the right of equipment sales and services in the field of encryption.
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