News Our Feedback to EC 25 September 2022

Disappointing "SCHEER Opinion report"

Critique of SCHEER Opinion Report on Health Risks from Radiofrequency Radiation

A review of the EU expert group and opinion of August 2022 on the need of a revision of the maximum exposure limits for radiation from wireless communications

Report - Conclusion: PDF document

The SCHEER report should be dismissed and a new objective evaluation of the risks to health and the environment must be undertaken by competent experts without conflicts of interests and ties to industry. The report is extremely biased about the current scientific evidence of health risks. It cannot be used as a basis for decisions on new exposure limits for the prevention of harmful health and environmental effects. The relevant EU body to manage the new evaluation procedure is The European Environmental Agency.

Summary - Highlights: PDF document

- The vast majority of field experts agree that the ICNIRP 1998 limits recommended by EU allow exposure to harmful levels of radiation and that they must be stricter.

- Harmful effects from wireless technology radiation below the ICNIRP limits are clearly established by science.

- The EU Commission scientific advisory group (SCHEER) advises positively on adoption of new ICNIRP 2020 exposure limits allowing even more harmful RF radiation exposure.

- The SCHEER Opinion is biased and appear to be designed to find no risks and to greenlight the adoption of exposure limits that benefits industry.

- SCHEER working group members belong to a small self-referencing circle of no-risk proICNIRP advocates, with ties to telecoms industry.

- The SCHEER panel do not meet the basic requirement for risk assessors: The demand for excellence and absence of economic or political ties.

- The SCHEER methodology for assessing the scientific evidence is insufficient, severely biased, and unscientific. A central thread throughout SCHEER report is the manufacture of doubt about harmful effects instead of an objective assessment of the science.

- SCHEER report overlaps risk assessment and risk management - a no-go in public health.

- There is an urgent need for complete re-evaluation of the science.

- The proper EU body to undertake such a risk analysis is the European Environmental Agency.


Mona Nilsson, The Swedish Radiation Protection Foundation, Sweden

Vibeke Frøkjær Jensen, The Council for Safe Telecommunications, Denmark

Henrik Eiriksson, The Council for Safe Telecommunications, Denmark

Contact: Mona Nilsson. E-mail:

Our statement

We welcome that the European Commission will amend the Council Recommendation 1999/519/EC and Directive 2013/35/EU. This is exactly what we ask the EU to do in proposal 2 in our European Citizens' Initiative "Stop (((5G))) – Stay connected but protected".

In the preamble section of the Recommendation 1999/519/EC, point (10) states: "...the framework should be regularly reviewed and reassessed in the light of new knowledge and developments in technology..." As it was created in 1999 and has not been updated since, we consider it not up-to-date. For two decades wireless technologies and their uses have increased dramatically but no review of the Recommendation has taken place.

In proposal 4, we ask the European Commission to ensure that exposure guidelines are made by scientists with biomedical expertise and who are free from conflicts of interest: appoint a new panel or expand SCHEER’s activities to assess RF EMF’s bioactive parameters.

A scientific working group have spent weeks reading and analysing the SCHEER Opinion report. Although we welcome a review in this area, the scientific group’s conclusion of the SCHEER Opinion report is unfortunately extremely disappointing and as follows:

This SCHEER report has by design a predetermined outcome in favor of the telecommunications industry’s needs of continued adherence to ICNIRP’s guidelines. The SCHEER working group has conflicts of interest and is unbalanced as to the selection of its members. The SHEER Opinion fails to include any of the many scientific experts who agree that there is sufficient evidence of health risks well below ICNIRP’s guidelines. Thereby obstructing decisions to adopt much lower limits for better protection of the public and the environment. SCHEER’s so-called "assessment" is of low quality and fails to meet basic scientific criteria. Furthermore, SCHEER completely ignores to do risk assessment for the environment.”

Feedback to the SCHEER Opinion report

Feedback to the SCHEER Opinion report

in PDF document

Strong support for our scientific based criticism of The SCHEER Opinion from stakeholders:

Vibeke Frøkjær Jensen, The Council for Health-Safe Telecommunication, Denmark

Mona Nilsson, Director, Swedish Radiation Protection Foundation, Sweden

Pernille Schriver, Coordinator for The ECI “Stop 5G - Stay Connected but Protected” and representative for Europeans for Safe Connections

Petra Bertová Polovková, NGO Electrosmog&health - OZ Elektrosmog a zdravie, Slovakia

Sophie PELLETIER, Chairman PRIARTEM - Electrosensibles de France, France

Dr. Christine Malfay-Regnier, Chairman Association SOS MCS, France

Magali Lesure, President Coeurs d'EHS, France

Kamil Bartošák, Vice-President of Life – Resonance, Czech Republic

Giorgio Cinciripini, Vicepresidente Associazione Italiana Elletro Sensibili, Italy

David Wedege, Chairman for the Danish EHS Association, Denmark

Patrice Goyaud, President Robin des Toits, France

Jean Michel GARNIER, Vice Président L'association Zones Blanches, France

Bernard Neau, Co-president of the association Résistance 5G Nantes, France

André Cicolella, Chairman Réseau Environnement Santé, France

Stephen KERCKHOVE, Executive officer Agir pour l'environnement, France

Catherine Neyrand, President Association Poem26, France

Dominique Belpomme. Executive director of the European Cancer and Environment Research Institute

(ECERI), Brussels: President of the French Society of environmental medicine (ISDE-France)

Philippe Irigaray, President of the Association for Research at International level on EHS and MCS

(A.R.I.E.M.); Scientific director of the European Cancer and Environment Research Institute (ECERI)

François Vetter, Association pour un Espace Protégé des Ondes Hertziennes and Conseil National des Associations Familiales Laïques, France

Preben Kastrup, Founder and editor Videnscentret for elektro-forurening, Denmark

Eigen Lucan, President ANGEL Association, Romania

Vassilis Anastassopoulos, Patras Citizens' Society for the protection of Health from Electromagnetic Radiation, Greece

Cindy Sage, Co-Editor BioInitiative Reports

Dr. Tarmo Koppel, Georgia State University

Professor Tom Butler PhD MSc

Rainer Nyberg, Chairman, Finnish Radiation Protection Society, Finland

Kate Kheel, Coordinator Safe Tech International, USA

Karen Churchill and Neil McDougall, UK Citizen's for Effective EMF Regulation United Kingdom

Dr. Lennart Hardell, MD, PhD Professor (retired) The Environment and Cancer Research Foundation, Sweden

Einar Flydal, cand. polit., Master of Telecom Strategy and Technology management, independent researcherand science writer, Norway

Rob van der Boom, Chairman of Foundation EHS, The Netherlands

Charlotte Ryø, The Civil Health Rights Movement May Day, Denmark

Francesca Romana Orlando, Association on Chronic and Toxic Injury (AMICA), Italy

More support after the document was submitted:

Elisabeth Birgit Madsen,  Vorstand Bündnis Verantwortungsvoller Mobilfunk, Germany

Shelley Wright, Director, Canadian Educators for Safe Technology, Canada 

Prof. Dr. Klaus Buchner, Germany 

Livio Giuliani, Scientist, Biophysicist, PhD. Italy 

Tiziana Vigni, lawyer and president of Association Atto Primo, Italy 

Erika Tedino, vicepresidente the Association Atto Primo, Italy 

Stefano Gallozzi, president of the Italian environmental association "Comitato di Tutela e Salvaguardia dell'Ambiente in Monte Porzio Catone ONLUS",
president of the international association "Safeguarding the Astronomical Sky Foundation -SAS Foundation" 

Elisabetta Saviotti, Stop5G Romagna, Italy 

SCHEER - Public consultation on the Preliminary Opinion on scientific evidence on radiofrequency

About this initiative: Following a request from the European Commission, the Scientific Committee on Health, Environmental and Emerging Risks (SCHEER) provided a preliminary Opinion on the need of a revision of the annexes in the Council Recommendation 1999/519/EC and Directive 2013/35/EU, in view of the latest scientific evidence available with regard to radiofrequency (100kHz - 300GHz).

Technological advancements and emerging wireless applications, especially in the highest end of the radiofrequency spectrum (millimetre waves), call for the introduction of limits on new dosimetric quantities.

Feedback period: public consultation open until 25 September 2022.


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