G/TBT/W/722  
 
10 March  2020 
(20-1842) Page: 1/2 
Committee on Technical Barriers to Trade  Original: English  
 
FRANCE - MANDATORY L ABELLING OF SAR RADI O EQUIPMENT  
STATEMENT BY THE EUROPEAN UNION TO THE COMMITTEE ON TECHNICAL BARRIERS T O TRADE  
26 – 27 FEBRUARY  2020 
The following communication, dated 9 March  2020, is being circulated at the request of the 
delegation of the European Union . 
 
_______________  
 
 
1.  The European Union  thank s the Delegation of China for its comments on the mandatory labelling 
for SAR radio equipment notified by France to this Committee on 3  April 2018 under the reference 
G/TBT/N/FRA/184  and G/TBT/N/FRA/185 .  
2.  Although D irective 2014/53/EU on the harmonisation of the laws of the Member States relating 
to the making available on the market of radio equipment does not impose compliance with specific 
technical specifications, Article 17 thereof provides that "the manufacture r shall perform a 
conformity assessment of the radio equipment with a view to meeting the essential requirements 
set out in Article 3 ", in order to be able to place it on the market. These essential requirements 
include the specific absorption rate (so cal led, "SAR") limit values given in the harmonised standards, 
resulting from the Council recommendation of 12 July 1999 on the limitation of exposure of the 
general public to electromagnetic fields, which recommends that the Member States should aim to 
achie ve compliance with the basic restrictions featured in Annex II. For the 100 kilohertz to 
10 gigahertz frequency band, these basic restrictions are expressed as SAR values.  
3.  In France, the values set out in the recommendation were included in Decree No 2002 -775 of 
3 May 2002 on the limit values for exposure of the general public to electromagnetic fields emitted 
by equipment used in telecommunication networks or by radio installations and in the Order of 
8 October 2003 establishing the technical specification s applicable to radio terminal equipment. 
The notified draft decree and order are therefore not liable to create any legal ambiguity or 
insecurity. The objective of the decree is to inform the consumer of the value of the SAR, the 
measurement of which is p rovided for by the aforementioned texts.  
4.  In addition, Decree No 2010 -1207 of 12 October 2010 on displaying the specific absorption rate 
of radio terminal equipment and the Order of 12 October 2010 on displaying the specific absorption 
rate of radio termina l equipment have been in force since 2011. The application of these regulations 
has not prompted any response from telephone manufacturers and importers, who have not reported 
any obstacles to placing the equipment in question on the market.  
5.  In France, con sumer associations and individuals regularly ask the national authorities about 
public exposure to radio frequencies particularly because radio equipment is becoming increasingly 
numerous and because authorities need to respond to public concerns related t o future 5G networks . 
6.  In its opinions, the French Agency for Food, Environmental and Occupational Health  & Safety 
(Anses) has recommended improving public information and making it compulsory to display 
the SAR: 
− expert appraisal "Radio frequencies and Health", 2013  
(https://www.anses.fr/fr/system/files/AP2011sa0150Ra.pdf ), G/TBT/W/722  
 
- 2 - 
 
  − expert appraisal "Exposure to radio frequencies and child health", 2016  
(https://www.anses.fr/fr/system/files/AP2012SA0091Ra.pdf ). 
7.  Finally, on the point of the requested transitional period, France would like to recall that the entry 
into force of both the or der and draft decree are set for 1 July 2020.  
 
__________