关键词: 商用密码, 技术审查, 型号证书, 标准密码, 出境评估

Abstract: Complying with National Security Law and Cybersecurity Law of PRC, the #46 document of State Council, as well as the #336 document of State Cryptography Administration honored and encouraged the idea to rely more on the FOEs and be more flexible in regulating commercial cryptography. In response to massive newly enacted rules and regulations, FOEs must adapt their policies in multiple dimensions including research, production, sale, use, exportation, and importation. More importantly, data localization and export evaluation requirement under Cybersecurity Law created a new demand for FOEs to regulate its cryptography technology and international data exchange. This article takes on the perspective of corporations, interprets the two documents mentioned above and their related instructions, and further analyzes the issues posed under Cybersecurity laws and regulations.

Key words: commercial cryptography, technical review, type certificate, standard cryptography, export evaluation