HUAWEI DEVELOPER QUESTIONNAIRE

HUAWEI DEVELOPER QUESTIONNAIRE, updated 12/9/19, 11:28 PM

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MOBILE APP DEVELOPER QUESTIONNAIRE
This questionnaire is provided by and for Huawei Mobile Service platform and as such does not represent an
agreement nor contract between the App developer and Huawei Mobile Services and/or any Huawei affiliate. This
questionnaire also does not obviate the App developer’s need to seek legal advice nor any obligations of the App
developer with regards to any legal matter.
Content Partner Name:
Name of App or Game:
Content Partner Contact Name:
Content Partner Email:

For clarification any app that originates in the US is likely to be subject to Export Administration Regulations (“EAR”)
unless it is distributed for free to the public and does not use encryption for confidentiality (or that encryption has
been properly notified to the US government). In addition, foreign developed apps that include US-origin content are
subject to the EAR unless US-origin content accounts for less than 25% of the app’s value.

1. For what business models does your App require support and what is the charging approach if you have a
paid app or premium subscription?
Business Model
Mark
YES or
NO
Charging Approach
(Detail payment approach)
Free App


Paid App


Premium
Subscription


In-App Purchases



The following two questions will help to determine US and other export control requirements for upload of your
app(s) to Huawei App Gallery servers (which are expected to be located outside the US) and for downloads of the
app(s) to device owners around the world. Under the US Export Administration Regulations (“EAR”), there are three
basic questions that need to be answered when software is made available to end users (e.g., Huawei device owners):
(1) is the app developed and made available outside the US “subject to the EAR”?; (2) what is the “export control
classification number” assigned to the app?; and (3) what are the country(ies) of destination?

Your answers to those questions must be your own, based on your own information and your own understanding of
export control rules. To learn more about those rules, you can visit the website of the US Bureau of Industry and
Security, which administers US export control rules. This website includes the regulations related to export control,
including EAR Sections 734.2 and 734.3 for “subject to the EAR” and the Commerce Control List for export
classification. This website also includes guidance on what is “subject to the EAR” (such as advisory opinions, FAQs,
and BIS training), and on how to classify items for export purposes (such as an order of review decision tool). For
more information, BIS contact information may be found here.

THIS INFORMATION IS NOT LEGAL ADVICE. IT IS THE DEVELOPER’S RESPONSIBILITY TO MAKE ACCURATE EXPORT
CONTROL DETERMINATIONS TO SUPPORT BUSINESS COLLABORATION WITH HUAWEI.

2. What is the Export Control Classification Number (ECCN) of your App, based on the Commerce Control List
(CCL)? Please see the chart below for summary guidance on possible ECCNs.1
ECCN
Explanation

5D002


ECCN 5D002 controls certain, specified software related to ECCN 5A002
(cryptographic information security), 5A003 (non-cryptographic information
security), or 5A004 (defeating, weakening or bypassing information security).
This includes software that (i) uses encryption for confidentiality of
communications or storage of data and (ii) has not been classified as “mass
market” software, with certain exceptions (including in some cases where
information security is not the primary function of the software, as explained
in Note 3.b to Category 5 - Part 2 of the US Export Administration Regulations
(EAR)).


5D992

ECCN 5D992 controls:

information security software having functions not falling under ECCN
5D002;

software that would fall under ECCN 5D002 but is classified as mass
market encryption software in accordance with §§ 740.17(b) &
740.17(e)(3) of the EAR through appropriate submissions to the US
Bureau of Industry and Security – items that qualify as “mass market”
are explained in Note 3.a to Category 5 - Part 2 of the EAR (see link
above under 5D002).


Other CCL Categories


If the App provides specialized functions that are listed in another category of
the CCL, you should identify the appropriate ECCN. Some CCL categories that
you may wish to consider are Category 4 (Computers) and Category 5, Part 1
(Telecommunications), but note that neither of these categories is applicable
simply because your App is designed for mobile communications devices.


EAR99

If the App falls under US Department of Commerce jurisdiction and is not
listed on the CCL, it is designated as EAR99.


Not Subject to the EAR

This includes Apps with no US-origin content (except that such Apps become
subject to the EAR when brought to the United States). Other items not
subject to the EAR are described in EAR Part 734. Under § 734.3(b)(3), for
example, information and software that are “published” are not subject to
the EAR. For more information regarding “published” software, see EAR §
734.7 (including § 734.7(b), which states that published encryption software
classified under ECCN 5D002 remains subject to the EAR, absent certain
required actions).



1 This chart provides an incomplete summary of US law. You may wish to confirm the correct ECCN classification of your
App with your legal advisor.
3.
If you are not based in the United States, does your App include US-origin software or technology? If yes,
please provide a brief description of the US software or technology, how it is used in your app, whether it is
open source or not, and what the ECCN is (if you know the source it may be possible to receive the ECCN
from the source).

4.
Is your App content dynamic or static?
App
Content
Mark YES or NO



Static




Dynamic

Own
Website
Google
3rd Party
Website
If dynamic, please advise if the content comes from
your website, Google’s or another 3rd Party website.



If dynamic, how frequently will you provide new
content to your App users, please provide details?




5. Does your website mirror your App functionality or add more user options? If yes, please describe.


6. Does your App utilize a database, connect through your website with a database, or fetch data from any 3rd
party service? If so, please describe.


7. What languages do your App and your Website support, please provide details?

Languages Supported
App

Website



8. Does your App do any of the following? Check all that apply, and please provide details.
Does your app…
Mark
Y/N
If Yes, Details/Comments
Handle Banking or Monetary Transactions?


Handle Medical Data or Medical applications?


Communicate over secure channels?


Compress, code, or recode any data?


Access, contain, implement or incorporate
any encryption?


Require User Authentication or can anybody
install and use it?





9. Does your App require any of the below listed service integrations? Please put checkmark in “Yes” or “No”
column.


Function
YES
NO
If Yes, Detail the app functionality or
consumer experience it enables.
1
Google Auth



2
Google Mobile Ads/AdMob



3
Google Cloud Message
(Firebase Cloud Message)



4
Google Location



5
Google Maps



6
Google Analytics



7
Google Play Games Service



8
Google Wallet



9
Google Play IAP



10
Google Drive



11
Google Places



12
Google Instant App



13
Google +



14
Google Identity



15
Google Awareness



16
Google Fitness



17
Google Cast



18 Mobile Vision



19
Google Nearby



20
Google Panorama Viewer



21
Google Play Protect (SafetyNet &
Security)



22
Google Wear



23
FIDO



24
Google Tag Manager



26
Unity



27
DRM



28
Other




10. Does your App integrate with any Social Media platform(s)? Please list others in the “Platform” column
below.
Platform
Mark YES or NO
If Yes, Details/Comments
Facebook


Instagram


WhatsApp


Twitter


Linked In


WeChat


Other