Export Control of Qt Framework and Tools
Many jurisdictions have regulations governing the export of software products and physical products containing software. These regulations vary based on the products classification, origin, and destination.
The Qt framework and tools are exported from the EU and thus subject to the EU’s export control legislation.
This page shows how the Qt Group classifies the Qt framework and related tools and extensions in this context, and what restrictions it puts upon exporting to sanctioned parties and destinations.
As a customer, you might also ship Qt libraries and selected tools as part of your application or product. The page therefore also lists some advice on how Qt is typically handled especially under export control of the US.
Warning: If you are exporting (parts of) Qt yourself: The Qt Group makes the export control information available for informational purposes only, as a courtesy to our customers. The information provided here is provided as is and Qt does not represent, warrant, or guarantee that the information is complete, accurate, or up to date. It is your obligation as an exporter to verify such information and comply with the current applicable regulations. The information is not intended to constitute legal advice or to be used as a substitute for specific legal advice from a qualified lawyer. You should not act (or refrain from acting) based on information provided without obtaining professional advice regarding your particular facts and circumstances. Please note that any software, including software within physical products, must be separately classified by the exporting party. Any use of the information by you is without recourse to Qt and is at your own risk. In no event shall Qt be liable for any direct, indirect, incidental, special, or consequential damages incurred by you or any third party, whether in an action in contract or tort, arising from your use of the information. If you could not find the needed information here, please contact Qt Group via the Support portal.
Country of origin and country of export
The Qt framework and tools are mainly developed in the European Union (EU). While the EU sets certain restrictions for exporting software, the Qt framework and the related tools provided by the Qt Group generally do not contain functionality that would cause them to be under tight regulations.
The following table provides information often required when assessing export control of Qt framework and tools from the EU.
| Question | Answer | Comment |
|---|---|---|
| What is the country of manufacture (assembly)? | Finland (EU) | Release packages are produced within Finland. Most of the code is developed in Norway, Germany, or Finland. |
| What is the country of export? | Ireland (EU) | Location of commercial distribution master server is Ireland. |
Classification per product
The following table provides classification of different products provided by the Qt Group. Note that the comments on US EAR and Export Control Classification Number (ECCN) are only indicative for customers that plan to export parts of Qt themselves from the US.
| Product Name | EU Export Classification | Subject to US EAR * | Indicative ECCN * | Classification Method | Classification basis | Dual use system | Military item |
|---|---|---|---|---|---|---|---|
| Qt framework libraries | Not controlled | No | Not controlled | Self-classification | EU & US classification basis: public domain (EAR § CFR 742.15(b)) | No | No |
| Qt Installer and Installer Framework | Not controlled | No | ECCN 5D992.c | Self-classification | EU & US classification basis: mass market | No | No |
| Qt Creator | Not controlled | No | ECCN 5D992.c | Self-classification | EU & US classification basis: mass market | No | No |
| Qt Design Studio | Not controlled | No | ECCN 5D992.c | Self-classification | EU & US classification basis: mass market | No | No |
| Qt Safe Renderer | Not controlled | No | EAR99 | Self-classification | EU & US classification basis: encryption used for data integrity only | No | No |
US export control
The Qt Group does not export products from the United States (US), and its products are not subject to the https://www.bis.gov/regulations US {Export Administration Regulations (EAR)}. They are, to the largest extend, not US-origin. The lines of code that were developed in the US are pursuant to the de minimis rule. However, if you are a customer who is located in or exports from the US, EAR might apply to you.
| Question | Answer | Comment |
|---|---|---|
| Is Qt subject to US EAR? | Only if exported by customer | The Qt Group does not export products from the US. |
| Does Qt have a US Harmonized Tariff System Code (HTSC)? | Not applicable | If the customer exports the Qt framework libraries from the US, the HTSC depends upon how these are packaged. |
| Do the products contain items developed in US? | No | There are some lines of code developed in the US, but in total, this is clearly under the "de minimis" rule. |
Exporting to sanctioned parties and destinations
The Qt Group products or related technical data may not be exported, re-exported or transferred, either directly or indirectly,
- to any person or entity located, established, or resident in a country or territory subject to a comprehensive trade embargo maintained by the United Nations, the United States, or the European Union (including, but not necessarily limited to, Cuba, Belarus, Iran, North Korea, Russian Federation, Syria and any territories of Ukraine occupied by the Russian Federation, such as Crimea, or
- to or for the benefit of any person or entity subject to sanctions adopted by United Nations, the United States, or the European Union, or of any country with jurisdiction over the business activity, unless specifically authorized to do so under applicable law or a valid license issued by a competent authority.
For a list of sanctioned destinations, see for instance the US Sanctioned Destinations list, and the EU Sanctions Map.
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