FCC’s New 47 CFR Part 2.1093 Guidance: Harmonizing SAR Testing for Portable Devices

On April 2, 2025, the FCC has issued new guidance under 47 CFR Part 2.1093 concerning radio-frequency exposure testing (SAR, PD, EMF, etc.) for portable devices. This guidance references KDB 447498, KDB 616217, KDB 648474, and related documents. The key points of the new rules are as follows:

Core Objective

Harmonize test standards
As a temporary substitute for existing KDB publications (e.g. 447498, 616217, 648474), this guidance ensures consistent testing across different devices (especially tablets and laptops), keeps pace with technological advances, and minimizes deviations from current procedures.

Key Changes

1. Default test separation distance
   – For all devices (including tablets and laptops), the 1-g SAR test must assume a maximum separation of 5 mm.
   – Exception: If the device provides a documented “on-body accessory” (e.g. a belt clip or body-worn holster) clearly shown in the certification filing, the test separation may be increased up to 25 mm—provided the user manual specifies which accessory was used and the corresponding distance.
2. Scenario-specific test requirements
   • Body-worn data-hotspot mode: 1-g SAR measured at 10 mm separation (testing at the stricter 5 mm is also permitted).
   • Head exposure: Any surface used for close-to-ear voice communications (for example, a tablet with a handset-style speaker) must be tested with zero-mm separation (contact condition).
   • Extremity exposure (hands/arms/feet): Any surface or edge within 25 mm of the antenna must undergo a 10-g SAR contact test—unless that very region has already been tested under the body-worn configuration with the same device setup.

Applicable Devices

All portable equipment as defined in § 2.1093, including but not limited to smartphones, tablets, laptops, and other similar rectangular devices.

Special notes:

1. Tablets larger than 20 cm generally do not require close-to-ear testing—unless they support voice calls (so-called “phablets”), in which case they must be tested to the same criteria as a phone (per KDB 648474).
2. Foldable devices must consider that the earpiece or speaker may reside on the reverse side of one of the screens; that side must be tested accordingly.