Apple has changed the rules on this. I read through all the Apple docs and as many of the US export regs as I could find.
My view on this was until recently even using HTTPS for most apps meant Apple would require the export certificate. Some apps such as banking would be OK but for many apps they did not fall into the excempt category which is very, very broad.
However Apple has now introduced a getout under the exempt category for apps that JUST use https. I do not know when they did this but I think it was either Dec 2016 or Jan 2017. We are now submitting our apps without the certificate from the US Govt.