EXTENDMAX - Following the Regulation QCVN 12:2020/BQP (former number is QCVN 01:2022/BQ) The Ministry of Defense promulgates the draft National Technical Regulation on cryptographic specifications used in civil cryptographic products (CCP) belongs to the data storage security products group. So how will this technical regulation apply in practice to import and export and trade in civil cryptography products? What are civil cryptographic products for data storage security? What are the market access requirements and steps to export data storage security products to Vietnam? Why is it necessary to obtain type approval for civil cryptographic products under data storage security products group? What are the testing and certification authority for data storage security products? How much does it cost? In the group of manufacturers, importers, distributors, and end-users, who must be the applicant for CCP type approval? Let's learn about these contents through the exclusive ExtendMax guidance article below.
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First of all, let's learn the essential contents of "National technical regulation on cryptographic techinical specifications used in civil cryptography products under data storage security products group".
Application scope of the Regulation
"This regulation prescribes the limits of cryptographic technical characteristics of data storage security products for the protection of information that are not under the scope of state secrets"
(information that are not under the scope of state secrets is information that is not classified as "extreme secret", "top secret", and "secrete" as defined in the Law on Protection of State Secrets dated November 15, 2018)
Regulations on management of the Standard
"The limits of cryptographic technical characteristics mentioned in this Regulation are quality criteria for management in accordance with regulations on quality management of civil cryptographic products specified in the Law on Network Information Security dated November 19, 2015"
Responsibilities of organizations and individuals
Organizations and individuals that have business in civil cryptographic products within the scope of this regulation are responsible for implementing regulations on conformity certification and announcement of conformity and subject to inspection by regulatory State management agencies according to current regulations
HS code of data storage security products
Appendix A of the Regulation stipulates the following HS codes within the scope of regulation
Chapter 84, HS code group 8471 - Automatic data processing machines and their function blocks; magnetic or optical readers, machines that transmit data onto data transmission media in coded form and machines that process these data, not elsewhere specified or included, including HS codes: 84713090, 84714190, 84714990, 84715090, 84717020, 84717099
Chapter 85, HS Code Heading 8517 - Telephone sets, including telephones for cellular or other wireless networks; other equipment for transmitting or receiving voice, images or other data, including telecommunications equipment connected to a wired or wireless network (such as those used in local or wide area networks), other than or collected of heading 84.43, 85.25, 85.27 or 85.28, including HS codes: 85176990, 85177029, 85177039, 85177099
Chapter 85, HS Code Group 8523 - Discs, tapes, solid-state, persistent storage devices, "smart cards" and other information storage media for recording sound or other contents or forms of expression other, whether or not recorded, including templates and masters for the manufacture of discs, but excluding products of Chapter 37, including HS codes: 85235111, 85235119, 85215121, 85235129, 85235130, 85235191, 85235192, 85235199, 85235200
Chapter 85, HS code group 8542 - Integrated electronic circuits, including HS code 85423100 (Processing units and control units, whether or not incorporating memories, converters, logic circuits, amplifiers, copper clock and timer circuits, or other circuits)
ExtendMax's exclusive insights
What are the data storage security products?
The civil cryptographic product under data storage security products group, as the name suggests, has the main function of storing data and uses cryptographic encryption techniques to secure the stored data. Typical civil cryptographic products in this group include:
- Storage servers, storage systems, appliances that stores data
- Tokens used to authenticate payments, used in the banking sector
- Some other information technology products have storage memory and use cryptographic techniques to protect stored data
Who must be the applicant for CCP type approval?
From ExtendMax's point of view, organizations and individuals engaged in the business of civil cryptographic products are classified into four groups, including manufacturers, importers, distributors (but not importers), and users, having the respective responsibility and obligation to ensure that the product is imported and certified as conforming to the regulations.
Process and procedures for conformity certification?
Please see the detailed instructions on the process, procedures, necessary records and documents, obligations and responsibilities of each group of organizations and individuals engaged in the business of civil cryptographic products through the exclusive guidance on type approval for civil cryptographic products of ExtendMax
What can ExtendMax help you in getting type approval for CCP?
With many years of experience in applying for business licenses and import and export licenses of civil cryptography products for many organizations, we can assist you:
→ Classify products into groups and finalized market access requirements needed for each group of products.
- Group of products that use encryption techniques but are not considered as CCP to be subject to management. For this group, enterprises should ask for a written confirmation that the product is not required to apply for a civil cryptographic license to facilitate the customs clearance process.
- The product group must apply for a license to trade in civil cryptography, but it is not required to certify the conformity according to the technical regulations on civil cryptography.
- The product group is required to apply for both a license to trade in civil cryptography and to certify the conformity and apply for a license to export and import civil cryptographic products.
→ In case the products are not considered as CCP, we support clients to obtain CCP Exemption Letter to make sure there will be no trouble in customs clearance
→ Support clients to prepare documents in the fastest time according to the requirements of the authorities in order to obtain CCP trading license and import license
→ Representing customers in carrying out testing and certification procedures for civil cryptography products to obtain Type Approval certificate.
→ Support other legal procedures related to imported products such as applying for licenses and ICT Type Approval certificate from the MIC (where applicable)
→ In case the customer is not yet eligible to apply for a license to trade in civil cryptography products, ExtendMax can provide Importer of Record (IOR) or Exporter of Record services to support import and export CCP.
Contact information for CCP Type Approval services and consulting
EXTENDMAX VIETNAM COMPANY LIMITED
Hotline: 0915 836 555 | Hanoi: 024 6666 3066
Email: consultant@extendmax.vn | phuong.tran@extendmax.vn
HO: ExtendMax Villa, C01-L18 An Vuong, Duong Noi urban area, Duong Noi ward, Ha Dong district, Hanoi City, Vietnam
Test laboratory: BT02-21, An Hung urban area, To Huu street, La Khe ward, Ha Dong district, Hanoi City, Vietnam
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