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Re-exporting EAR99 software with encryption from Singapore: de minimis sanity check
David Chen sgRegional Trade Manager · Meridian Trade AsiaAsked 24 Jul 2026
Our product bundles a US-origin encryption library (ENC-restricted, 5D992 self-classified) into otherwise non-US software. Before we re-export from Singapore to a customer in an E:1-adjacent market: does anyone have a worked de minimis calculation for software where the US content is a linked library rather than source? My percentages feel hand-wavy.
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