Yes as this app is using AES encryption algorithms in addition to iOS security features. You need following:
1. US Encryption Registration (ERN) – For distributing in US. You can register in the following link which is pretty fast: https://snapr.bis.doc.gov/snapr/
2. French Import Declaration approval – For Distribution in France. You can contact them at firstname.lastname@example.org. They will send you a form for you to fill up and return to them. Upon successful submission, you will get approval in subsequent weeks. If you choose not to sell in France, you may leave France unchecked in pricing page when submitting your app for review and this approval is not required.
Checking whether the app has encryption and whether you need export compliance certificate is government’s concern and not Apple’s. As far as government concerns, you need the export certs.
If you choose NO, you will get your app approved but that doesn’t mean you don’t require those approvals.