Hi Arabella,

The example provided can validate to multiple
<https://crt.sh/?graph=15005443728&opt=nometadata> anchors.

For example, an alternate path to an SSL.com root is provided below.

Anchor: SSL.com TLS ECC Root CA 2022
<https://crt.sh/?q=c32ffd9f46f936d16c3673990959434b9ad60aafbb9e7cf33654f144cc1ba143>
 ---> SSL.com TLS Transit ECC CA R2
<https://crt.sh/?q=5d1bc399274e649e1c72697de91a54ad725088c5221cb61e17ee9c290bc42a92>
     ---> Cloudflare TLS Issuing ECC CA 1
<https://crt.sh/?q=2964fd3210ea68faa2b4a849b36243d33f74429d1b43ce019e7b154eac7759ba>
          ---> www.relialabtest.com
<https://crt.sh/?q=133f15fc8303dccb6b319b65c6d9f2ff9ae1c0fea4abf2eaf70939d77240dc0a>

Hope this helps!

- Ryan

On Wed, Apr 9, 2025 at 12:40 PM Arabella Barks <[email protected]>
wrote:

> 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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