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Must I have my encryption commodities and software approved as a “retail” product prior to submitting them for review as a “mass market” product?

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Must I have my encryption commodities and software approved as a “retail” product prior to submitting them for review as a “mass market” product?

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A previous review as a “retail” encryption product under License Exception ENC is not required in order to qualify for “mass market” treatment. However, if a product was previously approved as “retail” under License Exception ENC, exporters should reference the previous application control number when submitting a review request for mass market treatment under Section 742.15(b)(2) of the EAR.

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