The European Commission adopted Implementing Decision (EU) 2026/2003 on 4 September 2026. It was published in the Official Journal of the European Union on 7 September 2026. The decision updates the EU’s list of harmonised standards for radio equipment. Commission Implementing Decision (EU) 2026/2003

One relevant change concerns the harmonised reference for EN 50566, a standard for assessing compliance of wireless communication devices with basic restrictions and exposure limit values related to human exposure to electromagnetic fields. The decision provides for EN 50566:2017, together with amendments A1:2023 and A2:2025, to be included in the updated harmonised standards list from 7 March 2028.

What Does the Amended EN 50566 Standard Cover?

The decision updates harmonised standards for several categories of radio equipment. These include location-tracking equipment, cellular communication base stations, ultra-wideband devices, fixed radio systems and other radio technologies.

EN 50566 has a more specific scope. It covers handheld and body-mounted wireless communication devices used close to the human body and operating between 30 MHz and 6 GHz. It provides a product standard for demonstrating compliance with applicable basic restrictions and exposure limit values.

The 2025 amendment, EN 50566:2017/A2:2025, forms part of the updated harmonised reference for assessing human exposure to electromagnetic fields from wireless communication devices used close to the body.

Source access: NEN lists the English-language amendment as published on 1 November 2025 and available for purchase. The full text is not freely available on the catalogue page. Readers should consult the amendment itself for its specific technical provisions.

What Are Harmonised Standards?

Harmonised standards provide technical procedures that manufacturers can use to demonstrate that their products meet applicable EU legal requirements. References to these standards are published in the Official Journal of the European Union.

Under the Radio Equipment Directive, compliance with a harmonised standard whose reference has been published in the Official Journal confers a presumption of conformity with the essential requirements covered by that standard.

For RF-exposure assessment, EN 50566 specifies procedures for assessing compliance with applicable exposure requirements.

What Is the Transition Period?

The decision provides a transition period for the earlier EN 50566 references. The updated harmonised reference, which includes amendments A1:2023 and A2:2025, applies from 7 March 2028. On that date, the references to EN 50566:2017 and amendment A1:2023 are scheduled to be withdrawn from the Official Journal of the European Union. This gives manufacturers time to adapt to the updated standard.

What Does This Mean for Consumers?

Compliance assessments apply to specified device configurations and test conditions. An important question is how well those conditions represent the different ways people carry and use wireless devices in everyday life, particularly when body-worn accessories are involved.

The following international documents provide further technical context. They describe approaches to exposure assessment and SAR measurement, but neither automatically replaces or amends EN 50566. Their publication does not, by itself, establish a new universal RF-exposure limit.

Two International Documents Provide Further Context

ITU-T Recommendation K.160 — Exposure Assessment Guidance

Approved: 14 December 2025

ITU-T Recommendation K.160 provides guidance on assessing human exposure to radiofrequency electromagnetic fields from wireless communication devices used close to the body.

It covers several assessment methods, including specific absorption rate (SAR), absorbed power density (APD) and incident power density (IPD). It also addresses device operating conditions, proximity sensors, time-averaged SAR and exposure from multiple transmitters or operating modes.

K.160 refers to existing international standards for measurement and assessment. The applicable exposure limits depend on the relevant regulatory framework or guidelines.

Read the official ITU-T K.160 Recommendation

IEC/IEEE 62209-1528 — SAR Measurement Procedures

Amendment 1 published: 2 September 2026

IEC/IEEE 62209-1528 specifies procedures for measuring SAR from handheld and body-mounted wireless communication devices used near the head and body. It covers frequencies from 4 MHz to 10 GHz.

Amendment 1:2026 addresses hand SAR, motion sensors, time-averaged SAR algorithm validation, proximity sensors, separation distances and procedures for reducing certain SAR tests.

Sources:

• IEEE: Amendment 1 details
• IEC: Amendment 1 publication record
• IEC: Consolidated standard details

What Does Amendment 1 to IEC/IEEE 62209-1528 Change?

Amendment 1 adds or revises procedures for assessing SAR from wireless communication devices. The main areas addressed are outlined below.

Hand SAR

The amendment introduces an applicability check and a measurement procedure for hand SAR in specified circumstances. This is relevant to the assessment of devices used in the hand. It does not mean that every existing phone model will automatically be retested or that hand exposure has suddenly increased.

Motion and proximity sensors

The amendment adds procedures for measuring SAR in devices with motion sensors, including a sensor-validation annex. It also addresses proximity-sensor assessment.

These sensors can affect how a device operates when its position, movement or proximity to the user changes. The amendment specifies procedures for assessing relevant sensor behaviour during compliance testing.

Time-averaged SAR

The amendment revises procedures for validating algorithms used to assess time-averaged SAR. Some devices use power-control mechanisms that manage transmission over time. The updated procedures address how these algorithms are validated during compliance assessment.

They do not establish that every device using power control will produce lower exposure in every circumstance.

Separation distances and test reduction

Separation distance affects the configuration used during testing. Amendment 1 also introduces a conditional procedure that can reduce the need for certain head-SAR tests.

For devices used next to the ear, a test using a SAM (Specific Anthropomorphic Mannequin) head phantom may not be required for a particular antenna and frequency combination if specified conditions are met. These include:

• Testing the device’s front side in direct contact with a flat phantom at a separation distance of 0 mm, using the same operating conditions that apply to use next to the ear.
• Confirming that the device’s front side is planar.
• Demonstrating that the time-averaged output power next to the ear is no higher than the power used in the flat-phantom measurement.
• Documenting the justification in the test report.

The flat-phantom result must also meet at least one of two criteria:

1. The peak spatial-average SAR (psSAR) must be at least 5 dB below the applicable head-SAR limit; or
2. The centre of the psSAR cube must be at least 95.4 mm from the device’s acoustic output along the specified vertical centreline, and the spatial-average SAR at all locations within 95.4 mm of the acoustic output must be at least 5 dB below the applicable head-SAR limit.

This is a conditional test-reduction procedure, not a general exemption from head-SAR testing. The amendment cautions that some regulatory authorities may not accept flat-phantom SAR measurements as a substitute for SAM-phantom measurements. National regulatory requirements must therefore be considered.

Sources:

Official IEC publication record

Official IEEE amendment record

What Do These Changes Mean for RF-Exposure Assessment?

Changes to measurement procedures can affect compliance results because the test arrangement, assumptions or procedures may differ. A change in a reported result does not, by itself, establish that a person’s actual RF exposure in everyday use has increased or decreased.

Similarly, a lower measured SAR value does not automatically establish lower exposure across every operating mode or device configuration. SAR is one measure used in RF-exposure assessment. APD and IPD are also relevant to particular assessment methods and frequency ranges.

Publication of Amendment 1 does not, by itself, establish that earlier phones were inadequately tested, that newer phones will have higher or lower SAR values, or that regulators in every country will immediately adopt the revised procedures.

These questions require separate evidence and consideration of the applicable regulatory framework.

How Confidently Can a Compliance Result Be Applied to Everyday Use?

A compliance result applies to the device and conditions assessed under the relevant procedure. Applying it to a different configuration depends on whether the differences are covered by the test method or otherwise accounted for in the assessment.

Factors such as the device’s position relative to the body, separation distance, operating mode and accessories may affect the assessment. A phone tested in one configuration should not automatically be assumed to have the same exposure characteristics when used with a different case or body-worn accessory. The significance of any difference depends on the device and the conditions assessed.

This does not mean that every change in configuration invalidates a compliance result. The scope of the assessment and the manufacturer’s instructions are important when interpreting the result.

What Does SAR Testing Establish—and What Does It Not?

Specific absorption rate (SAR) measures the rate at which radiofrequency energy is absorbed per unit mass of tissue. It is expressed in watts per kilogram (W/kg). Standardised SAR testing assesses compliance with applicable SAR limits under specified test conditions.

SAR is a physical measurement quantity, not a direct test for biological effects. SAR testing does not directly measure biological endpoints such as changes in cellular signalling, oxidative stress or gene expression. Researchers have investigated these endpoints in studies of possible non-thermal effects.

A compliant SAR result does not, by itself, establish the absence of every possible biological effect.

RF-exposure guidelines aim to protect against established adverse effects. For RF fields, current guidelines are principally based on established effects associated with excessive tissue heating. Questions about other possible effects, and whether the evidence supports additional protective measures, are separate from whether a device meets the applicable exposure limits.

Read the ICNIRP RF-EMF Guidelines (2020)

ITU-T Recommendation K.160 does not introduce a test for non-thermal biological effects. It provides guidance on assessing exposure against applicable limits using existing measurement standards. Depending on the frequency range and assessment method, the relevant physical quantities include SAR, absorbed power density (APD) and incident power density (IPD).

A measurement standard specifies how exposure is assessed. It does not, by itself, resolve every scientific question about possible health effects.

The iPhone 12 A2403 Example: Contact Measurements and Software

The European Commission’s 2025 decision on the iPhone 12 A2403 illustrates how test procedures and software behaviour can affect RF-exposure compliance.

France’s market surveillance authority, ANFR, found that the iPhone 12 A2403 exceeded the applicable limb SAR limit. Apple disputed the original measurements and proposed an alternative test procedure.

Disagreement Over the Test Procedure

Apple’s first proposal, known as Protocol 1, used a separation distance of 1 mm. It also used an external motorised system to trigger the phone’s Body Detect function.

ANFR rejected this procedure for three reasons. First, it considered that the maximum SAR was more likely to occur at a separation distance of 0 mm. Second, it considered the artificial triggering mechanism potentially unrepresentative of normal use. Third, the test configuration used to isolate a particular antenna could have an undetermined effect on the measurements.

Apple then proposed Protocol 2, which used a separation distance of 0 mm. It also required the volume button to be pressed every 20 seconds to trigger Body Detect. ANFR accepted the revised procedure.

However, measurements conducted in August 2023 still found that the phone exceeded the applicable limb SAR limit. The measured value was 5.740 W/kg, against a limit of 4 W/kg.

Software Correction and EU-Wide Requirements

Following the release of iOS 17.1, further measurements in September 2023 showed that the phone met the limb SAR limit under the reported test conditions. The tests used equipment simulating a mobile network in France. The software update permanently activated the on-body state of Body Detect, reducing the device’s transmission power and SAR.

The Commission also examined whether the corrective software operated throughout the EU. Apple confirmed that the relevant software behaviour applied only to iPhone 12 A2403 devices using cellular networks in France.

Article 40(3) of the Radio Equipment Directive requires corrective action for non-compliant radio equipment throughout the EU.

The Commission therefore considered the measure insufficient because the corrective software did not operate throughout the Union.

In its decision of 19 August 2025, the Commission concluded that France’s measure to withdraw the iPhone 12 A2403 from the market was justified. This finding concerned the specific A2403 model. It should not be interpreted as a finding that every iPhone 12 model was non-compliant.

Read Commission Implementing Decision (EU) 2025/1760

The case illustrates why test procedures, separation distances, software behaviour and corrective action matter when interpreting compliance results.

It also provides context for the later EU standards update. Contact-distance testing is not entirely new. In its 2025 decision, the Commission noted that EN 50566:2017 allowed test distances between 0 and 5 mm and that the worst-case scenario should be considered. It also referred to guidance that typically uses a separation distance of 0 mm, or contact, for head SAR, limb SAR and SAR measurements involving known accessories.

The precise technical changes introduced by Amendment A2:2025 should be checked against the amendment itself. The publicly available catalogue description alone is insufficient to establish the full scope of those changes. Until the complete text has been reviewed, the specific requirements for separation distances should not be presented as confirmed. Nor should any change be interpreted as a blanket requirement to test every phone in direct contact with the head.

Sources

1. European Commission. Commission Implementing Decision (EU) 2025/1760 of 19 August 2025 concerning the measure taken by France with respect to Apple iPhone 12 A2403. Official Journal of the European Union, 1 September 2025. https://eur-lex.europa.eu/eli/dec_impl/2025/1760/oj Relevant sections: paragraphs 18–32 cover the original limb SAR finding, Apple’s proposed test protocols, the 5.740 W/kg result, the iOS 17.1 update and the requirement for corrective action throughout the EU.
2. European Commission. Commission Implementing Decision (EU) 2026/2003 of 4 September 2026 amending Implementing Decision (EU) 2022/2191 as regards harmonised standards for radio equipment. https://eur-lex.europa.eu/eli/dec_impl/2026/2003/oj Relevant sections: recitals 6–7 and 11–13, and the Annex, address EN 50566:2017 and amendments A1:2023 and A2:2025, including the transition arrangements.
3. Nederlands Normalisatie-instituut (NEN). NEN-EN 50566:2017/A2:2025 en. English-language amendment, published 1 November 2025. https://www.nen.nl/en/nen-en-50566-2017-a2-2025-en-344126 The catalogue identifies the amendment and its publication details. The full text is available for purchase; the catalogue description alone does not establish the precise technical changes introduced by the amendment.

Compliance, Everyday Exposure and Health Questions

International standards provide an important technical framework for assessing RF-exposure compliance. However, the interpretation of a compliance result depends on the measurement procedure, the device configuration and the conditions assessed.

The updated standards and the iPhone 12 A2403 case illustrate why these details matter. A compliance result establishes whether a device meets the applicable requirements under the specified assessment procedure. It does not, by itself, establish the exposure a user will experience in every everyday-use scenario or resolve all scientific questions about possible long-term health effects.

Consumers should consult the manufacturer’s guidance for their specific device, follow any stated separation distances and use accessories in accordance with the manufacturer’s instructions. For researchers and regulators, the continuing challenge is to ensure that assessment procedures remain technically robust and relevant to how wireless devices are used in practice.

Disclaimer: This article summarises published regulatory documents, technical standards and related research for general information. It is not legal or medical advice, nor a product-specific RF-exposure assessment. Readers should consult the relevant primary sources and the manufacturer’s guidance for their specific device.

Further reading Legal Accountability of a Guideline versus a Standard

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