21-09-2023 | By Robin Mitchell

Recently, French authorities have published their findings on iPhone 12 radio emissions, claiming that they exceed the legal limits of the country. As such, Apple must push out a software update to rectify the issue or face a large recall in the country. What challenges do radio emissions introduce, what did the French authorities exactly say, and why could this case be considered unfair against Apple with regards to EU legislation?

Captured in Ho Chi Minh, Vietnam during August 2022, a detailed shot of the latest iPhone 14 Pro Max.

What challenges do radio emissions introduce in product design?

Ask any electronic engineer involved with product design what is their most dreaded task, and while some may respond with PCB layout or component selection, nine times out of ten, the answer will almost always be related to conforming to legislation on EMI. As products placed onto the market legally need to ensure that they don’t emit too much electromagnetic radiation or are susceptible to stray electromagnetic radiation, engineers have to perform rigorous amounts of testing to prove this.

While it is perfectly possible for a design to pass all tests with flying colours first time, this is hardly the case. Instead, it is often that a design will be mostly correct with one or two tiny flaws, and these flaws will require either changes in the PCB layout, changes in component values, or the use of additional methods to protect against EMI (such as metal cans). 

Unfortunately for engineers, if their device does fail the testing stage, test houses will not refund the cost of the testing, and getting updated devices tested will require additional payment (as test houses usually charge based on time). The result of this is that devices which fail testing can be extremely costly for engineering projects, potentially push back launch dates, and, in rare instances, even end a project in its tracks if funding runs out.

To make matters worse, it can be immensely difficult for engineers to fault-find issues raised in test houses. For example, a particular resonant frequency that is producing too much EMI may be identified, but the exact location of the source of the EMI may not be. This means that engineers will be told that there is an issue, but it is up to them to find where on the circuit the problem is originating from. 

Finally, as a final thorn in the backside of product design, countries around the world all have their own legal requirements for product testing. Thankfully, the US and the EU are the two major markets, and products that pass EU legislation will likely pass all legislation around the world. But this doesn’t mean that engineers only have to do one test; they may still be obliged to run multiple tests for different markets.

iPhone 12 to be recalled if software update can’t reduce radio emissions

In what can only be described as a rather unusual incident, French authorities recently announced that tests on the iPhone 12 have shown that its radio emissions exceed legal limits in the country. At the time of the announcement, the authorities stated that if Apple is unable to provide a software update to reduce these emissions immediately, then it would force a product recall on all iPhone 12 devices in France. After receiving this news, Apple has managed to solve the issue via a software update and will begin to roll out this update to French devices only. 

Highlighting the proactive approach of manufacturers in addressing these concerns, ANFR stated, "Non-compliant devices received a software update that rectified the non-compliance. These procedures were systematically communicated by ANFR after verifying the effectiveness of the software updates implemented by the manufacturers." This underscores the commitment of both regulatory bodies and manufacturers in ensuring the safety of consumers.

The ANFR's commitment to ensuring public safety is evident in their rigorous testing procedures. Their analysis covered a wide range of mobile phones, and the iPhone 12 was among the few that were identified to exceed the regulatory limits. The agency's transparency in sharing these findings allows consumers to make informed decisions about the devices they use. Furthermore, the collaboration between regulatory bodies and manufacturers, as seen in Apple's swift response, is a testament to the industry's dedication to adhering to safety standards and regulations.

ANFR's Comprehensive Analysis on DAS in 2022

The National Agency for Frequency (ANFR) conducted an extensive analysis on Specific Absorption Rate (DAS) measurements in 2022, covering 102 mobile phones from 33 different brands. Interestingly, 46% of these phones were 5G-enabled. The results from this study revealed that 8 phones, including the iPhone 12, exceeded the regulatory limits set for DAS.

According to French regulators, the iPhone was determined to have a Specific Absorption Rate (SAR) of 5.74 watts per kilogram, while the legal limit is 4 Watts per kilogram. What this essentially means is that the iPhone 12, when left in a pocket, provides surrounding tissue with around 5.74 watts of heating power for every kilogram of body mass. While the concern of EM radiation on the human body has existed for years, there is still little scientific evidence to suggest that any harm comes from having mobile devices near living tissue. For a deeper understanding of DAS and its implications, you can read more here.

The ANFR's findings indicated that for DAS head measurements, all phones were compliant, with values ranging between 0.18 W/kg and 1.51 W/kg. However, for DAS trunk measurements, out of 100 phones tested, three phones exceeded the 2 W/kg limit. Furthermore, for DAS limb measurements, six phones surpassed the regulatory limit of 4 W/kg. All non-compliant devices, including the iPhone 12, were provided with software updates to rectify the non-compliance, ensuring user safety.

Even if Apple provides a fix for the issue, it is believed that the French authorities will present their findings to other EU member states, potentially causing an avalanche of investigations against Apple devices.

ANFR's Role in Monitoring Radio Emissions

The Agence nationale des fréquences (ANFR) stands as a pivotal entity in the realm of radio emissions monitoring. Established to safeguard the interests of consumers and the broader public, ANFR ensures that electronic devices hitting the market are in strict adherence to the established regulatory limits for radio emissions.

With the proliferation of electronic devices, especially mobile phones, the potential risks associated with electromagnetic radiation have become a topic of concern. ANFR's rigorous testing and analysis procedures are designed to mitigate these risks. By conducting comprehensive evaluations, they ensure that consumers are not exposed to harmful levels of electromagnetic radiation, thereby promoting public health and safety.

Beyond their testing endeavours, ANFR is also lauded for its commitment to transparency. Their open data policy is a testament to this commitment. By making their findings and data publicly accessible, they empower consumers and manufacturers with the knowledge they need. This not only helps consumers make informed decisions but also encourages manufacturers to maintain high standards of compliance, fostering a safer electronic ecosystem for all.

Why is this legal limit unfair to engineers?

Legal limits for radio emissions are important as they prevent devices placed on the market from interfering with each other. While countries have every right to set their own limits and regulations, the situation with France could be deemed as being highly unfair. 

The reason for this unfairness comes down to the fact that France is a part of the EU, and the EU has specific legislation to make sure that products designed for one EU member can be used in all EU member states (the CE mark). By creating this unified regulation, it not only simplifies testing procedures for engineers but also allows products to be easily traded across the bloc.

However, if individual EU members start introducing their own product regulations that don’t conform to the single markets framework, then it can introduce numerous challenges to engineering companies that want to sell products across the EU. For example, if Apple decided not to roll out a fix, then iPhone devices sold in other EU member states would not be allowed to be shipped into France, something that the EU has specifically been formed to prevent. 

If the iPhone 12 passed all CE requirementsthen there should be no technical reason why the iPhone 12 cannot be sold in France. However, because France is supposedly allowed to do this, engineers now have to treat France as a separate market with its own range of requirements. 

Does this apply to all electronic devices? How does one test for this? And does this affect all devices ever sold in the country? At this point, who knows, but it is clear that CE is not the only consideration in products from now on when selling into the EU market. 

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By Robin Mitchell

Robin Mitchell is an electronic engineer who has been involved in electronics since the age of 13. After completing a BEng at the University of Warwick, Robin moved into the field of online content creation, developing articles, news pieces, and projects aimed at professionals and makers alike. Currently, Robin runs a small electronics business, MitchElectronics, which produces educational kits and resources.