Sorry, I forgot to post one case https://www.relialabtest.com it is the 
hierarchy I mentioned.
On Thursday, April 10, 2025 at 12:36:03 AM UTC+8 Arabella Barks wrote:

> Ben,
>
> I still suggest adopting the distrust-after.
> Among the root intermediates that Mozilla plans to remove trust, there is 
> the "AAA Certificates Servies" of Sectigo CA, which is being widely issued 
> and used by a subordinate CA of Cloudflare, namely "Cloudflare TLS Issuing 
> ECC CA 1" (https://crt.sh/?caid=282054, and issued by "SSL.com TLS 
> Transit ECC CA R2"). However, SSL.com TLS Transit ECC CA R2 is just a 
> subordinate CA and not a Root.
>
> If Mozilla directly removes the "AAA Certificates Servies" and others, 
> more than 12,435,053 websites issued by "Cloudflare TLS Issuing ECC CA 1" 
> will be affected, It has bad impact on the business of CloudFlare's 
> customers.
> The above is what I have found out through about few minutes of research, 
> based on the sites count and I think it will have a gravity impact.
>
> I request the community to conduct an assessment to reduce this impact.
> On Thursday, April 10, 2025 at 12:10:21 AM UTC+8 Ben Wilson wrote:
>
>> Thanks for your feedback. Currently, our proposed strategy for handling 
>> this particular issue will be to postpone processing the websites trust bit 
>> removal from the Chunghwa Telecom ePKI Root CA by two or three months 
>> (until approximately Firefox Release 141 
>> <https://whattrainisitnow.com/release/?version=141>). In other words, we 
>> do not anticipate using the distrust-after mechanism in the present case.
>> Thanks again, 
>> Ben
>>
>> On Wed, Apr 9, 2025 at 9:55 AM Jeffrey Walton <[email protected]> wrote:
>>
>>> On Tue, Apr 1, 2025 at 11:03 AM 'Ben Wilson' via
>>> [email protected] <[email protected]>
>>> wrote:
>>> >
>>> > Per - https://bugzilla.mozilla.org/show_bug.cgi?id=1891438#c15:
>>> >
>>> > "In the interest of transparency, Mozilla received a formal request 
>>> from Taiwan’s Ministry of Digital Affairs (MODA), dated March 15, 2025, 
>>> requesting that we delay the removal of the “websites” trust bit for 
>>> Chunghwa Telecom’s ePKI Root CA, which is currently scheduled to occur on 
>>> or about April 15, 2025, in accordance with Mozilla’s Root CA Lifecycles 
>>> Transition Schedule.
>>> >
>>> > MODA explained that the requested delay is intended to support the 
>>> ongoing transition of government websites away from certificates issued by 
>>> CHT’s GTLSCA-G1 subordinate CA. As we understand it, MODA is already 
>>> implementing a short-term migration plan involving the dual issuance of 
>>> approximately 12,000 new certificates for government websites—one from 
>>> Chunghwa Telecom and one from Taiwan CA (TWCA)—to ensure continued 
>>> availability of government services and minimize user disruption.
>>> >
>>> > While we have not yet finalized a decision, we are currently 
>>> contemplating:
>>> >
>>> > Postponing the removal of the “websites” trust bit;
>>> > Implementing a distrust-after date; or
>>> > Taking other actions consistent with Mozilla Root Store Policy and 
>>> ecosystem risk management.
>>> >
>>> > We note that:
>>> >
>>> > The ePKI Root CA uses a 4096-bit RSA key, which provides stronger 
>>> security than other similarly aged root certificates.
>>> > Any extension under consideration would be strictly time-bounded 
>>> (e.g., not to exceed August 1, 2025), reflecting a short-term 
>>> accommodation, not a change in long-term policy direction.
>>> > Mozilla would retain the right to remove or revoke trust at any time, 
>>> based on new information or evolving risk factors.
>>> >
>>> > We welcome feedback on any of these approaches."
>>>
>>> Please consider avoiding the DistrustAfter strategy. It causes
>>> problems for tools which use Google, Mozilla (and friends) curated
>>> lists of trusted CAs. The tools include utilities like cURL and Wget.
>>> See, for example, <https://github.com/curl/curl/issues/15547>.
>>>
>>> Jeff
>>>
>>

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