I. Background of the Regulatory Update

On September 7, 2026, the OJEU issued Commission Implementing Decision (EU) 2026/2003, formally including EN 50566:2017/A2:2025 in the list of harmonised standards under the Radio Equipment Directive (RED). Since then, this standard has been granted presumption of conformity for EU market access. The standard text was officially published by the European Committee for Electrotechnical Standardization (CENELEC) in October 2025.

The core technical tightening of this revision is that the test distance for Body Specific Absorption Rate (Body SAR) is adjusted from ≤5mm in the original standard to 0mm, and the safety assessment fully adopts the test condition of "zero-distance contact with the human body". The SAR limit requirement remains unchanged, still at no more than 2.0 W/kg averaged over 10g of tissue.

This standard applies to all types of wireless communication equipment operating in the 30 MHz to 6 GHz frequency band and used within 200mm of the human body under normal conditions, covering handheld terminals, body-worn devices, devices used in combination with accessories, and wireless modules integrated into clothing.

II. Compliance Timeline for the Transition Period

This standard update sets an 18-month transition period (September 7, 2026 – March 7, 2028), with compliance requirements for each phase as follows:

During the transition period: For new product certification, manufacturers may voluntarily choose to follow the old version EN 50566:2017/A1:2023 or adopt the new A2 standard for assessment. Provisions from the two versions shall not be mixed in a single certification application. Products that have been certified under the old standard and legally placed on the market shall retain their original compliance status.

After the transition period: All newly submitted CE RED certification applications must mandatorily comply with EN 50566:2017/A2:2025. For existing products that continue to be supplied on the EU market, their compliance shall be reconfirmed in accordance with current regulations after the old standard is officially withdrawn.

EU member states shall complete the national transposition of this standard by October 31, 2026. All national standards of member states that conflict with the new standard shall be fully repealed by October 31, 2028.

III. Risk Warning on Market Surveillance Sampling After the Transition Period

A key point for enterprises to note: CE certification obtained under the old A1 standard during the transition period does not mean that products can permanently avoid the 0mm test requirement.

After the transition period, market surveillance authorities of EU member states will fully implement the A2 standard for products newly placed on the market. For products that were legally placed on the market before the end of the transition period, hold only certification under the old 5mm standard, and are only intended for local inventory digestion in Europe, regulatory sampling will still be assessed according to the old standard applicable at the time of marketing.

For products that continue to be imported and placed on the market after the transition period but have not updated their certification and DoC in accordance with the new standard, regulatory sampling will directly adopt the 0mm zero-distance condition for testing and assessment. If test results exceed the limit, products will face compliance risks such as market withdrawal, recall, official notification, and subsequent market access restrictions, resulting in direct economic losses and brand damage to enterprises.

In particular, for products with narrow RF power margins and antennas positioned close to the edge of the device, SAR values differ significantly between 5mm and 0mm test distances. Such products are at high risk of failing sampling tests if supply continues after the transition period. It is recommended that enterprises conduct 0mm condition verification and screening in advance.

IV. BTL Laboratory Compliance Support and Sampling Response Solutions

BTL SAR Laboratory has completed method validation and capability building for the new standard, and can fully support enterprises in responding to this regulatory upgrade.

Implementation Logic of Market Surveillance Sampling

1. Before sampling is initiated, the Declaration of Conformity (DoC) in the product’s Technical Construction File (TCF) will be checked first to confirm the date of issue and the referenced standard version, after which the test distance will be determined.

2. Existing old-model products: If the product was placed on the market before March 7, 2028 (before the end of the transition period), the DoC was signed before the transition period and references the old standard with 5mm distance, and the product is only circulated as local European inventory, sampling will still be conducted at 5mm distance, and 0mm testing is not mandatory.

3. Products imported after the transition period: If the product is newly imported into the EU after the end of the transition period, regardless of whether it is an old model, as long as the DoC references the new A2 standard, sampling must be assessed under the 0mm zero-distance condition.

Manufacturer Compliance Obligations and Risk Warnings

1. Old models with continuous import: For old models that continue to be imported into the EU after the transition period, manufacturers must ensure that the products meet the 0mm test requirements, and the Supplier’s Declaration of Conformity (SDoC)/DoC must correctly reference the new standard, and shall not continue to use the old standard.

2. Boundary for inventory products: The "old standard for old products" principle only applies to products that were legally placed on the market before the end of the transition period and are only for inventory digestion in Europe; it does not apply to products of the same model that are newly produced or newly imported after the transition period.

3. High-risk warning: Products with narrow RF power margins and antennas positioned close to the edge of the device show significant differences in SAR values between 5mm and 0mm test distances. They are high-risk categories for sampling failure after the transition period. Pre-validation and rectification under 0mm conditions are recommended in advance.

Recommended Pre-validation Items for Sampling Tests by BTL Laboratory

BTL Laboratory is equipped with Dasy5, Dasy8 SAR test systems and the cSAR test system. All three systems have completed method validation and metrological calibration for 0mm test conditions, can be applied to the test requirements of the new regulation, and can benchmark EU regulatory sampling conditions to carry out compliance pre-validation for products sold on the EU market. The specific verification items are as follows:

1. Full-scenario Power and MAX SAR Verification

Covering all normal usage scenarios of the product such as handheld, body-worn, and accessory-equipped use, complete verification of transmit power and duty cycle under each frequency band and operating mode, and conduct maximum SAR (MAX SAR) testing under 0mm zero-distance conditions, to accurately determine the compliance level of the product under the new standard.

2. Effectiveness Verification of SAR Suppression Mechanisms

▷ Proximity sensor (P-Sensor): Verify trigger distance, response sensitivity and trigger logic to confirm stable triggering in 0mm human contact scenarios, and simultaneously verify the SAR suppression effect after triggering.

▷ Earpiece proximity switch function: Verify the switching logic of earpiece proximity detection and corresponding power adjustment effect in call scenarios, to meet compliance requirements in real usage scenarios.

▷ Power back-off mechanism: Verify the trigger conditions, back-off amplitude and operational stability of power back-off across all frequency bands and operating conditions, to confirm that SAR can be controlled within limits through power adjustment while ensuring the basic communication performance of the product.

For details on the new regulation test plan, sampling pre-validation cycle and technical support, please contact BTL for consultation.