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Last Updated on October 4, 2023
EMF radiation standards can be very confusing! Even for the experts!
On top of that, EMF standards vary country by country. And to add the confusion 5G is coming (a hot topic nowadays), and that’s been creating waves (figurative and electromagnetic) around the tech and health world.
5G is the fifth generation of cellular network technology.
Every decade or so, the wireless network is updated to compensate for the new technology. Today, everything from our cars to our clothes are connected to a wireless signal, which creates the need for a faster and more efficient network.
And 5G will allow just that. 5G has the potential to be 40 to 100 times faster than 4G. It is also estimated to be able to support up to a million devices per square kilometer, compared to a tenth of that (100,000) for 4G.
To keep up with the 5G race around the world, take a look at our 5G Guide.
But, with a faster network speed comes more EMF exposure. Since 5G can’t travel as far, there will be more 5G cell towers, with a closer distance between them.
Recent research has established that Electromagnetic Field radiation (EMF), a non-ionizing form of energy emitted from electronic devices, can negatively affect our health. These effects range from infertility, chronic illnesses and behavioral disorders, all the way to cancer.
The United States Federal Communications Commission (FCC) states that 5G (and prior generations for that matter) is not harmful, and that the new technology will not go over its EMF exposure limits.
While there isn’t much research showing what a 5G-specific frequency can do to the body when used as wireless communication, many agree that these 1996 standards are severely outdated, and don’t take into account recent research or updated technology use. Other countries have similar limits that could stand to be updated, but there are a few that are proactive in updating their regulations as more and more research comes out.
Regional Differences in Radiation Standards
Different regions of the world have adopted more specific EMF standards. According to Kenneth R. Foster, Ph.D, a professor in the Department of Bioengineering at the University of Pennsylvania, these regional standards are roughly based on 3 different models of reasoning.
1) Evidence of Thermal Damage Model
The United States and many countries in Western Europe reason that biological damage from radiation stems only from the thermal heating of cells. Thermal damage is a widely accepted effect of low-frequency radiation emitting at a high power level (this is why your laptop gets hot!).
However, this is the riskiest model of the three, since it ignores new research showing that other biological effects are evident, despite any thermal heating. Just like with cigarettes, it took the declining health of hundreds of thousands of people for the U.S. to update regulations.
Our new patterns of technology use have not been around long enough to see widespread biological effects, but until this becomes evident, it is unlikely that standards will be updated.
2) Evidence of Multiple Biological Effects Model
Russia, China, and many Eastern European countries have limits well below those of the U.S., and are focused more on the dose of EMF over extended exposure periods, instead of the immediate thermal impacts that the Western nations base their limits on.
This harsher stance has become more accepted as research continues to demonstrate that biological effects are shown in the body even with zero thermal changes.
3) Precautionary Model
Some countries have taken it a bit further, using a precautionary approach as a model for their reasoning.
The Precautionary Principle states: when human activities may lead to morally unacceptable harm that is scientifically plausible but uncertain, actions shall be taken to avoid or diminish that harm.
Italy, Switzerland, and Belgium have created exposure standards “specifically intended to minimise (sic) the yet unknown risks” of Radio Frequency (RF) and lower-frequency electromagnetic fields. While this goes beyond established research, these countries are trying to do their due diligence to make sure their citizens aren’t guinea pigs as the real-life wireless technology experiment is carried out.
Instead of reacting, these countries are predicting based on current evidence that chronic, long-term exposure to wireless radiation might have more adverse health effects than current short-term research is showing.
So what exactly are these limits, and how do they compare across countries? Well, to understand EMF radiation exposure limits, you need to be able to know how to measure EMF radiation exposure.
Measuring Electromagnetic Fields
Measuring Radio Frequency (RF) EMF radiation can get complicated, and confusing. There are many different units of measurements to describe exposures, since harm varies with power, distance, source, modulation, and length of exposure. RF is also absorbed differently depending on the conductivity of different body parts. That being said, no set standard applies accurately across the board.
Because an RF electromagnetic field has both an electric and a magnetic component, the intensity of each field can be measured in different units, such as Electric Field Strength (volts per meter), Magnetic Field Strength (amps per meter) and Power Density (milliwatts per square centimeter), which takes into account both fields when measuring exposure farther away from the RF source.
These units are all used to describe RF exposure coming from antennas and cell towers, and they can vary a lot between countries–and even within countries–depending on frequency range and the area it’s in.
To measure the RF exposure coming from wireless handheld devices, the most universal standard is the Specific Absorption Rate, or SAR limit. SAR describes the speed at which the radio waves are absorbed in the body, in watts per kilogram. Any device that falls within the 900 MHz to 5,600 MHz (5.6GHz) wireless device frequency range is subject to the SAR standard. For more information about SAR, and its shortcomings when measuring EMF exposure, read this blog post about SAR standards.
International SAR Standards
The International Commission on Non-Ionizing Radiation Protection (ICNIRP) is an NGO recognized by the World Health Organization (WHO). In 2011, radiation standards were created based on evaluations of the established health effects. These standards detail all types of radiation limits for different electromagnetic frequencies.
The current SAR exposure limits for RF mobile device exposure in the U.S. and Europe are:
|Region/Country||Guideline||Limit in W/kg||Limit in W/kg|
|United States||FCC (1996)||1.6 W/kg in 1 g of tissue||0.1-6,000|
|Europe||ICNIRP (1998)||2.0 W/kg in 10 g of tissue||10-10,000|
For the FCC standard, no more than 1.6 watts per kilogram (energy) can be absorbed by any 1 gram of tissue. For the ICNIRP standard, no more than 2 watts per kilogram can be absorbed by 10 grams of contiguous tissue.
So which is better? Well, SAR values depend on average volume. Since the ICNIRP SAR standard covers a larger area of 10 grams of tissue, there is actually less allowable RF exposure per gram of tissue.
In the end, SAR was developed only to minimize thermal effects of RF emissions on the body, and doesn’t take into account biological effects that might happen regardless of tissue heating.
SAR limits don’t vary much country by country. The European Union, Australia, Japan, and many other countries in the world follow ICNIRP SAR standards. The United States, Canada, and Korea follow FCC SAR standards, created by the United States FCC.
In terms of other EMF exposure regulations, much of the world has adopted some version of the complete ICNIRP guidelines, but some countries are stricter than others in implementation and establishing specific standards.
The WHO chart below details limits for Power Density, Electric Field, and SAR in many different countries.
The United States
The FCC hasn’t updated radiation standards since 1996, a time where only 15% of Americans owned a cell phone compared to 96% (~315 million) of Americans today. Like mentioned earlier, cell phones are required to have a SAR value of 1.6 watts or less per kilogram of body weight.
In 2013, the American Academy of Pediatrics advised the FCC that its guidelines “do not account for the unique vulnerability and use patterns specific to pregnant women and children.” Still, the FCC has declined to update its standards, and many new phones have tested above the standard with independent lab tests.
The U.S. also has some of the highest Power Density limits for EMF exposures, showing it is not concerned with the precautionary principle.
The FCC has established a three-part plan to have one of the first and fastest 5G networks. Most devices are not yet 5G-compatible, so many have not been able to take advantage of the 5G infrastructure already set up in many cities.
Many cities and counties in the U.S. are protesting, especially about the placement of 5G cell towers.
Bluntly put, Health Canada says EMF exposures “present no known health risk.”
Instead of standards, they only have recommendations for safe exposure, delineated in Safety Code 6. This code considers research up to August 2014. Their SAR standard of 1.6 w/kg follows the FCC standard, and suggestions on reducing exposure are consistent with those of its southern neighbor.
Health Canada states that it doesn’t consider precautionary measures because there is no conclusive evidence of harm caused by exposure levels found in Canadian homes and schools.
With regards to 5G, while there is community backlash, Canada has plans to implement millimeter-wave 5G networks in 2020, with a new frequency by 2022.
To harmonize standards, committees from Australia and New Zealand were amalgamated in 1991 to work on a joint RF field exposure Standard based on the 1998 ICNIRP guidelines. However, the committee split up before finalizing a standard, leaving the two countries to work on their own guidelines. Both are guided by ICNIRP guidelines.
ARPANSA created the standards for RF radiation exposure in Australia in 2002. These standards are known as the Radiation Protection Series 3 (RPS3). The guidelines go in-depth on specific levels for specific exposure. The entire document is 136 pages long.
The RPS3 was last updated in May 2016, when Schedule 5 was created. This update extended the scope of the regulations to include equipment that will be needed when it’s time for 6G. (Yes, they are already looking beyond 5G—a rather daunting thought considering the repercussions of 5G are yet to come).
It’s important to note that while developing these standards, ARPANSA consulted other stakeholders, including members of the telecommunications industry. Much like the FCC in the United States, the people who were consulted about RF radiation standards are also people with vested interests in wireless networks and the development of 5G technology.
That being said, 5G is well on its way in Australia. There are still protests and concerns being raised, but not enough to delay 5G implementation.
New Zealand’s electromagnetic radiation standards are based on ICNIRP guidelines, known as Standard NZS 2772.1:1999. Included in the Standard are RF limitations, covering the range of 3 kHz to 300 GHz (the upper limit for 5G).
However, the Standard is not cited in legislation, and thus has no formal legal status, much like Canada’s code. However, the Ministry of Health does recommend strict application. Exposure should be minimized if it can be achieved “at modest expense,” according to clause (10(d)).
The Foreword states: “There is currently a level of concern about RF exposure, which is not fully alleviated by existing scientific data… the committee will continue to monitor the results of this research and, where necessary, issue amendments to this document. Generally, it is therefore sensible in achieving service or process requirements to minimise unnecessary or incidental RF exposure.”
Separate SAR limits on mobile device radiation, public RF exposure limits, which deal with cell towers instead of handheld devices, are stricter than they are for occupational RF exposures. These limits are 50 times lower than the acknowledged threshold for established effects.
Though the Standard was adopted in 1999, the guidelines were reaffirmed in 2017. Even with relatively strict guidelines, in early 2019 Health Minister David Clark dismissed 5G radiation exposure warnings.
“I am advised by Ministry of Health officials that the balance of research evidence suggests that exposure to the radiofrequency produced by any transmitter, including those that will be used by 5G services, do not cause health problems, provided they comply with international guidelines,” he said.
Although Europe was the leader when it came to 4G technology, it seems they have fallen behind in the 5G race due to regulatory hurdles dealing with manufacturing and the Huawei battle. However, some countries are pulling ahead and have live 5G sites already in place.
In terms of public RF exposure, many countries in Europe follow the ICNIRP guidelines. However, some have tightened the standards.
Belgium has some of the strictest radiation regulations. Belgium banned marketing of cell phones to children below age 14, and banned the sale of phones designed for children below age 7.
Its capital, Brussels, mandates only 6 volts per meter (Electric Field Limit) for public RF exposure, which is 50 times stricter than international standards.
However, with those standards in place, Belgium can’t implement 5G technology. In early 2019, the Belgian Institute of Postal and Telecommunications Services recommended the city adopt a higher threshold.
There currently exists a large and growing anti-5G movement, with many Belgians concerned that mobile phones cause adverse health effects. The grONDES are the anti-cellular activists, lead by spokesperson Olivier Galand. The group, which states they are not anti-technology, just asks that technology respect health.
Sentiment continues to grow among the public, and it is impacting the lawmaking. Céline Fremault, the regional environment minister put a delay on 5G implementation, saying she won’t turn the people of Brussels to laboratory mice.
Many people whose interests lie in the expansion of the 5G network are concerned since Brussels, Belgium, is home to the European Union policy making.
Italy is another country with stricter regulations than ICNIRP mandates. There are two different limits set by Italian law.
General limits are about 30% lower and restrictive limits, which apply to “buildings for human long-stay purposes” are 10 times lower than ICNIRP standards.
Beyond federally enforced restrictions, there are local regulations establishing distances between base sites and sensitive locations–think schools, hospitals, etc. For example, in Rome, there must be at least 100 meters between a base site and a sensitive place.
There is resistance against the 5G rollout in Italy. Florence invoked the Precautionary Principle in regard to 5G technology.
For now, it looks like Italy’s 5G rollout may be slowed by public and political resistance.
The U.K. complies fully with the 1998 ICNIRP guidelines for public exposure, but lack specific standards, and it has not updated its legislation to reflect the new Extremely Low Frequency (ELF) EMF guidelines adopted by ICNIRP in 2010.
5G requires many new base stations, but the U.K. government guidelines ensure that at places accessible to the public, frequency levels are below guideline levels.
Despite this, some people are still weary. Residents of Glastonbury, the site of the world-famous annual Glastonbury Festival, did not want 5G to be tested at the event. Over 3,000 people from the town signed a petition for the 5G test to be banned.
The government went ahead with plans and made the June 2019 Glastonbury Festival the largest 5G test environment recorded, with over 200,000 people in attendance. Prior to the event, an independent group that monitors EMF radiation issued a public warning. They found while driving around the site that unsafe levels were consistently present. Additionally, on-site workers reported bad headaches, nose bleeds, and digestive issues.
Named the most innovative country in the world for nine straight years, tech-centered Switzerland’s exposure limits are surprisingly lower than those set in the ICNIRP. Their approach for setting the limits is precautionary, and focuses mainly on safety around mobile telephone base stations.
In general, the limit is already lower than ICNIRP guidelines. But, around schools and hospitals—which have higher risk populations—the limit decreases even more. For public spaces, they have the same standard as Belgium at 6 volts per meter.
Despite having lower standards than the international standards, Switzerland was one of the first to unveil 5G. 5G antennas have been installed in some neighborhoods in Geneva, and residents aren’t too happy with them. Many inhabitants of the area near the three new antennas have all developed symptoms of insomnia, tinnitus, and headaches.
29-year-old Johan Perruchoud, who is often on his computer, said it best: “nous nous sentons comme des cobyes.” We feel like guinea pigs.
In Bern, Switzerland, a protest in May led some administrative areas to block the construction of 5G antennas. “Stop 5G” is the movement to do simply that: stop the 5G rollout. This group wants more research on the potential health effects.
Resistance is even higher in rural areas. Parliamentary motions against 5G have been proposed in 7 of the 26 cantons (cantons are like states).
EMF exposure limits in South Korea have been enforced since April 2002, and are based on the 1998 ICNIRP standards. However, the new ICNIRP 2010 guidelines have not yet been implemented in South Korea, similar to the U.K.
The radiation guidelines haven’t been updated in almost a decade, which may be part of the reason South Korea was able to introduce a 5G network so quickly.
In April 2019, South Korea made history by becoming the first country to launch a nationwide 5G network. Within 140 days, SK Telecom surpassed its one million subscriber mark. Though the provider only offers three phones with 5G capabilities, already 3.5% of 28 million customers are equipped with 5G. The increase has been twice as fast as that of 4G subscribers in 2011.
Public concern surrounding the new 5G is still very high. Hundreds of public appeals regarding radiation emitted from base stations have been submitted to the government. Other complaints have been filed to the Korea Electric Power Corporation.
With over a billion people inside the country’s borders, India has created one of the largest–and fastest–telecom markets in the world!
In 2008, India adopted the ICNIRP guidelines. In 2011, based on recommendations from the Inter-Ministerial Committee, the exposure limit for base stations was reduced to 1/10th of the international limits.
In 2013, the government added an amendment saying that every two years, there will be an audit on the base stations to make sure they are complying w ith the general exposure limit. In fact, in India if you are afraid of the radiation levels around your house, you can go online to see exact information on a specific cell tower. You can also pay for the Department of Telecommunications to give radiation readings in different locations around your house.
With these strict standards, the question remains whether or not the limits will be upheld as 5G is introduced. India lags behind other countries, and might not adopt 5G until the end of 2020.
While getting into specific EMF standards and limits across countries is quite complicated and confusing, there are some big-picture comparisons that can be made.
The U.S., Canada, Australia, Korea, and many Western European countries have lenient standards that allow for the most technological innovation possible, and makes it easy to put up cell towers almost everywhere to give people instant connectivity. If this practice becomes harmful to a big portion of the population, only then will they reconsider their actions.
In contrast, Switzerland, Belgium, Italy, Russia, and countries in Eastern Europe are questioning if RF radiation emissions are safe, and some are using precautionary measures to protect their populations and environments as EMF radiation and 5G is researched more. However, many in these countries still battle to be at the front of technological innovation for the sake of political and economic power, and this might get in the way of safe RF standards.
Hopefully, as research in the area continues to grow along with awareness of EMF radiation, moves will be taken to reduce exposure around the world. Regardless, the controversy surrounding 5G implementation doesn’t seem to be headed anywhere soon.