Your questions about the “Specific Absorption Rate” (S.A.R.)

The SAR is assessed in the laboratory using standard protocols.

The tests use “dummies”, i.e. plastic containers in the shape of a human head or a plane, filled with a homogeneous liquid reproducing the dielectric characteristics of the human body. The equipment to be tested is placed under the container.

Until now, only “radio terminals” (i.e. mainly mobile phones and some DECT telephones) have been covered by the regulations on exposure to electromagnetic waves. Their manufacturers are subject to obligations to measure and publish the SARs of the products they place on the market.

In 201512 , the legislator decided to extend these obligations to a larger number of products that emit electromagnetic waves and are likely to be close to the human body.

This is why, from 1 July 2020, pursuant to the decree and order of 15 November 2019 (see appendix), products and equipment that are placed on the market will be concerned by the obligation to publish SAR values:

– contain one or more transmitters of electromagnetic waves with a power exceeding 20 mW13

– and will be used in a “reasonably foreseeable” manner (see explanations below) at a distance of less than 20 cm from the human body.

Governments have set SAR limits to ensure the protection of everyone’s health for exposure to radio waves between 100 kHz and 10 GHz3. Thus, as equipment can be placed close to the body, regulations can only be placed on the market if it complies with the following thresholds :

SAR “head” < 2 W/kg in 10 g of tissue
SAR “trunk” < 2 W/kg in 10 g of tissue
SAR “limbs” < 4 W/kg in 10 g of tissue

In 2015, a law on sobriety, transparency, information and consultation regarding exposure to electromagnetic waves was passed (known as the “Bee Law”).

This law extended the obligation to mention the SAR to all radio terminal equipment for which this measurement must be carried out by the manufacturer (tablets, connected watches, etc.).

The concrete implementation of this measure required the publication of an implementing decree which has just been published. This Decree provides that radio equipment marketed as of July 1, 2020, with a transmitting power greater than 20 mW and for which it is reasonably foreseeable that it will be used at a distance not exceeding 20 cm from the human head or body, must mention the SAR.

There are many products and equipment that can, potentially14 , meet these criteria :

– smartphones

– DECT phones

– tablets

– laptops

– wireless computer peripherals

– connected office equipment

– communicating robots

– connected watches and bracelets

– 3G or 4G/5G routers in “pocket” format (pocket router type) ;

– VHF maritime portable VHF

– walkie-talkies or equivalent devices (PMR) ;

– wireless microphones;

– radio controls for UAVs or model aircraft;

– motorcycle helmets connected

– connected glasses

– wireless headphones or headsets

– Portable safety sensors (e.g. distance sensors, person location modules)

– baby sitters

– connected virtual reality headsets

– wifi cameras

– action cameras

– wireless headphones

– home automation systems

– home automation remote controls

– garage remote control

– wireless payment terminals

– radio-controlled toys

– connected sensors

– internet box

– handheld barcode scanners

– connected GPS

– connected appliances

– connected means of transport

– and so on

To determine whether or not the equipment is affected, the maximum power of all radio-frequency transmitters contained in the equipment must be added together and checked whether or not it exceeds 20 mW.

Manufacturers, importers and distributors are responsible for the products they place on the market, put into service or use. They may be held liable for non-conformities. Consequently, if a player claims to know the SAR value of the equipment it places on the market without having measured it, it runs significant risks both if the regulatory thresholds are exceeded and if there is a discrepancy between the published value and the value measured by the ANFR.

Yes, the regulations have a two-fold objective: both to verify that the product meets public exposure limits and to inform the consumer of the SAR value. Therefore, even if it seems obvious that the product does indeed meet the SAR limits, it is necessary to have the SAR assessed in order to be able to communicate its value publicly.

So far, you have had to verify that the products you market meet the exposure limits for the SARs “head” and “body”. From 1 July 2020, you will also have to check that they meet the limit for the SAR “limbs”. In addition, certain information to the public will also change on that date.

The National Frequency Agency (ANFR) considers that products not intended to be worn or placed close to the body and “connected equipment that may come into brief contact with any part of the human body” would be excluded24. However, the regulatory texts do not mean that portable products and any bulky equipment or equipment intended to be fixed that meets the dual criteria of “more than 20 mW” and “less than 20 cm from the body” are, on a strict reading of the texts, indeed concerned. The parliamentary debates in preparation for the Bee Law expressly refer in particular to baby monitoring systems, which are not necessarily intended to be portable.

Yes, even if your different products integrate the same technology platform (electronic board, power supply, etc.), it is necessary to evaluate the SAR for each of them because the form factor, mechanical design or software programming may be different.

Yes, the regulations do not distinguish between the destination of products, whether for consumers or professionals.

Yes, in general, you must ensure that the products you market comply with regulations and do not put your customers at risk. In addition, if you market affected products under your own name or brand name, you must meet all the obligations that apply to manufacturers and importers.

No. There are mainly two possible conformity assessment procedures: by internal control (or “self-certification”) or by EU type examination. In the case of internal control, the manufacturer ensures and declares under his sole responsibility that the product satisfies the requirements of this Directive. To this end, he must compile a technical file which includes a SAR assessment. This assessment may be carried out by any laboratory capable of assessing the SAR, whether or not it is a notified organism.

Yes, on the one hand, equipment placed on the market, whether before or after 1 July 2020, must be subject to SAR measurement. On the other hand, as from 1 July 2020, all relevant appliances placed on the market before or after that date must be subject to public information of the SAR value(s).

The obligation to measure the SAR is mandatory throughout Europe, for the products concerned, in order to be able to affix the CE marking. On the other hand, few European countries have chosen, like France, to put the emphasis on informing the public.