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EUTesting guide

# SAR Testing for CE Marking: RF Exposure Limits

SAR (Specific Absorption Rate) testing is a mandatory part of RED compliance for devices worn on or near the body. The EU limit is 2 W/kg averaged over 10g of contiguous tissue for head and trunk — different from the US 1.6 W/kg over 1g limit. Test results from one regime cannot be directly used to demonstrate compliance with the other.

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At a glance

EU SAR limits

2

Products requiring SAR

6

SAR test process steps

7

## EU SAR limits (ICNIRP 1998 / RED harmonised standards)

### Head and trunk

2.0 W/kg

Averaged over: **10 g contiguous tissue**

ICNIRP 1998 guidelines — referenced in RED harmonised standards EN 50360, IEC 62209-1/-2

### Limbs (hands, wrists, ankles, feet)

4.0 W/kg

Averaged over: **10 g contiguous tissue**

Higher limit applies because peripheral tissue is less sensitive to thermal effects than trunk/head

## Products typically requiring SAR assessment

Smartphones and feature phones

Tested at head (voice call position) and body (data use with belt clip or pocket). Most handsets test both positions.

Tablets and laptop computers

Body SAR when used on a lap or against the body. Exemption evaluation available per IEC 62209-2 if minimum separation distance > 20 cm is guaranteed.

Smartwatches and wearables

Wrist/limb SAR assessment. Worn directly on skin — limb limit (4 W/kg) applies, but close-body positioning makes SAR management critical.

True wireless earbuds (TWS)

Placed in/on the ear — head SAR assessment (2 W/kg over 10g). Despite low Bluetooth transmit power, proximity to tissue requires formal SAR evaluation.

Wi-Fi routers and access points

Body SAR if placed within 20 cm of the human body in normal use. Many routers are exempt from SAR testing by demonstrating a ≥ 20 cm separation distance.

Mobile broadband modems (USB/PCIe)

Tested for body SAR in normal use position. Host device integration may change the effective separation from the user.

## SAR test process overview

01

Determine use positions: identify all normal use scenarios (head, body, limb) based on intended use and reasonably foreseeable use.

02

Select SAR measurement system: tissue-simulating liquid calibrated for the operating frequencies is placed in a Specific Anthropomorphic Mannequin (SAM) phantom.

03

Configure device for maximum SAR: set device to maximum transmit power on each frequency band. Test at worst-case antenna orientation.

04

Perform spatial peak SAR scan: electric field probe scans in 3D space inside the phantom. Spatial peak SAR is identified from the field distribution.

05

Apply 1g or 10g tissue averaging: SAR is averaged over 10g of contiguous tissue (EU — ICNIRP 1998 method). US FCC uses 1g averaging — results are not directly comparable.

06

Compare against limit: measured peak spatially averaged SAR must be ≤ 2 W/kg (head/trunk) or ≤ 4 W/kg (limbs).

07

Document in technical file: SAR report, device configuration during test, tissue-simulating liquid parameters, and uncertainty analysis must be included.

## Frequently asked questions

### What is the difference between EU and US SAR limits?

EU SAR limits follow ICNIRP 1998 guidelines: 2 W/kg averaged over 10g of contiguous tissue for head and trunk. US FCC limits are 1.6 W/kg averaged over 1g of tissue. The averaging mass differs significantly — 10g (EU) vs 1g (US). A device can pass one regime and fail the other, or vice versa, due to the different averaging methods. Test laboratories offer both EU and US SAR testing from the same measurement campaign.

### Can SAR compliance be demonstrated by calculation rather than measurement?

For very low-power devices, IEC 62209-2 allows an exclusion evaluation — a calculation-based method to demonstrate the device is unlikely to exceed the SAR limit without physical measurement. If the product's maximum transmitted power is below defined thresholds (which depend on frequency band and product type), SAR measurement may not be required. This exclusion is product-type specific and must be formally documented in the technical file.

### What happens if a device fails SAR testing?

SAR failure means the measured peak spatial average SAR exceeds the regulatory limit. Common mitigations: reduce maximum transmit power (impacts radio range and performance), add antenna design modifications to redirect radiation away from tissue, add SAR-reducing antenna spacer structures, or implement adaptive power reduction when body proximity is detected. Any design change after a SAR failure requires retesting to verify the fix.

### Is SAR testing required for Wi-Fi 6E or 5G mmWave products?

SAR testing as defined by IEC 62209-1/-2 applies to frequencies below 6 GHz. For 5G mmWave products operating at frequencies above 6 GHz (FR2 bands: 24.25–52.6 GHz), SAR is replaced by Power Density (PD) as the RF exposure metric — measured in W/m² rather than W/kg. The harmonised standard for mmWave compliance in EU is EN 62232. Wi-Fi 6E operates at 6 GHz (5.925–7.125 GHz) where SAR limits still apply.

**Disclaimer:** Educational resource only. SAR measurements must be performed by accredited laboratories using calibrated equipment. EU and US SAR test methods and limits differ — test reports from one market may not support compliance in the other.

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