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The NBTC clarified that product with WLAN only still need SAR/EMF report on July 17, 2018 by verbal(no written announcement from NBTC and this Announcement was effective from July 18, 2018.
NTC TS 1012-2551 (Broadband Wireless Access (Radio Local Area Network – RLAN)) - Notification of the NTC Regarding Safety Criteria and Measures for the Use of Radio communication Equipment on Human Health do not indicate to refer to human health announcement. Due to implementation of ISO17065 (quality system of certification body), NBTC reconsidered that if product is only WLAN (without WWAN), they will not mandate SAR/EMF requirements any more. So NBTC announced the news on 7 July that it is not required for SAR/EMF for WLAN only products (without WWAN). Due to industrial / manufacturer request, NBTC had reconsidered the SAR/EMF requirements for WLAN only product on 17 July 2018 and finally gave a verbal reply to them, but the new requirements has not been added to the standard yet. The conclusions from NBTC are as follow.
NBTC will still require SAR or EMF test report for WLAN only products.
Product using at <20 cm distance from human body such as notebook, mobile phone, tablet, will require SAR test report (all kind of notebook will require SAR no matter where is antenna location e.g. even located on top of screen will be considered as SAR required)
Product using at >20 cm distance from human body such as access point, will require EMF test report.
Note: If product is using frequency with output power not over 100mW EIRP such as 2.4 GHz products, it can be exempted for SAR/EMF test report.
In a word, after double announcement of NBTC, products with WWAN+WLAN will require SAR or EMF test as usual.