To be honest, I don't know. Up until my client requested this, I had never heard of it. I know this, for most microsoft applications I have had little problem finding ECCN's. Same goes for FireFox, MalwareBytes, and other more mainstream applications. But, most smaller / niche apps I have completely struck out with.
I also got a response from the developer of Memtest for windows (HCIDesign), and he seemed adamant that due to his applications lack of any form of encryption, it was therefore unnecessary to register an ECCN for it specifically.
Thoughts?