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MOLECULAR AND CLINICAL ONCOLOGY
Abstract. Radiofrequency (RF) radiation in the frequency
range of 30 kHz‑300 GHz is classied as a ‘possible’ human
carcinogen, Group 2B, by the International Agency for
Research on Cancer (IARC) since 2011. The evidence has since
then been strengthened by further research; thus, RF radiation
may now be classied as a human carcinogen, Group 1. In spite
of this, microwave radiations are expanding with increasing
personal and ambient exposure. One contributing factor is
that the majority of countries rely on guidelines formulated
by the International Commission on Non‑Ionizing Radiation
Protection (ICNIRP), a private German non‑governmental
organization. ICNIRP relies on the evaluation only of thermal
(heating) effects from RF radiation, thereby excluding a large
body of published science demonstrating the detrimental effects
caused by non‑thermal radiation. The fth generation, 5G, for
microwave radiation is about to be implemented worldwide in
spite of no comprehensive investigations of the potential risks
to human health and the environment. In an appeal sent to the
EU in September, 2017 currently >260 scientists and medical
doctors requested for a moratorium on the deployment of 5G
until the health risks associated with this new technology have
been fully investigated by industry‑independent scientists. The
appeal and four rebuttals to the EU over a period of >2 years,
have not achieved any positive response from the EU to date.
Unfortunately, decision makers seem to be uninformed or even
misinformed about the risks. EU ofcials rely on the opinions
of individuals within the ICNIRP and the Scientic Committee
on Emerging and Newly Identied Health Risks (SCENIHR),
most of whom have ties to the industry. They seem to dominate
evaluating bodies and refute risks. It is important that these
circumstances are described. In this article, the warnings
on the health risks associated with RF presented in the 5G
appeal and the letters to the EU Health Commissioner since
September, 2017 and the authors' rebuttals are summarized.
The responses from the EU seem to have thus far prioritized
industry prots to the detriment of human health and the envi-
ronment.
Introduction
Over the years, numerous international appeals on radiofre-
quency (RF) radiation and health and the environment have
been published (e.g., www.emfscientist.org). These seem to
have had little or no impact on those proposing limits on RF
radiation and on the deployment of this technology. On the
contrary, ambient RF radiation exposure has increased and is
a potential health risk based on the current knowledge of the
biological effects of RF radiation (1‑8). There seems to be an
‘unholy’ alliance between the telecom industry and certain
scientists, organizations (even WHO), and some politicians,
thus reducing the potential for precautionary actions (9,10).
The International Agency for Research on Cancer (IARC)
of WHO in 2011 classified RF radiation in the frequency
range of 30 kHz‑300 GHz as a ‘possible’ human carcinogen,
Group 2B (11,12). Since then, the evidence of the adverse
effects of RF radiation has strengthened based on human
epidemiological (7,8,13) and animal studies (14‑16). These
results add scientic evidence to a previous evaluation (17).
Thus, RF radiation may now be classied as a human carcin-
ogen, Group 1. That is the strongest classication, which is the
same as that for e.g., asbestos and smoking.
The IARC cancer classication seems to have had little
or no impact on protecting the public against risks associ-
ated with RF exposure. A major hampering factor has been
the exposure guidelines by the International Commission
on Non‑Ionizing Radiation Protection (ICNIRP) based only
on the acute and very short‑term thermal (heating) effects
of RF radiation. These guidelines are used by the majority
of countries worldwide. These guidelines were initially
published approximately 20 years ago (18) and were updated
in 2009 (19); however, no changes were made to adapt to the
rapidly increasing evidence of the harmful effects of RF and
Correspondence to: Professor Lennart Hardell, 3Present address:
The Environment and Cancer Research Foundation, Studievägen 35,
SE‑702 17, Örebro, Sweden
E‑mail: lennart.hardell@environmentandcancer.com
Key word s: appeals, microwave radiation, radiofrequency radiation,
radiofrequency electromagnetic field, EMF, 5G, EU, WHO,
moratorium, health risks, non‑ionizing radiation guidelines
COMMENT
Appeals that matter or not on a moratorium on the deployment
of the fth generation, 5G, for microwave radiation
LENNART HARDELL1,3 and RAINER NYBERG2
1Department of Oncology, Faculty of Medicine and Health, Örebro University, SE‑701 82 Örebro, Sweden;
2Faculty of Education and Welfare Studies, Åbo Akademi University, 65100 Vasa, Finland
Received September 21, 2019; Accepted January 3, 2020
DOI: 10.3892/mco.2020.1984
HARDELL and NYBERG: APPEALS ON THE DEPLOYMENT OF 5G
2
new RF signal characteristics and exposure from new technolo-
gies. ICNIRP, with the support of the WHO (10) and the major
telecom companies, has made considerable efforts to convince
countries worldwide to follow their guidelines. However, with
the deployment of the 5th generation of microwave radiation,
5G, even the obsolete ICNIRP guidelines may be exceeded
and may become an obstacle for the deployment of 5G (20).
Thus, ICNIRP is preparing new guidelines that are briey
commented on below. However, as already published (9,10),
the ICNIRP guidelines may be contradictory to a vast number
of existing scientic reports demonstrating the harmful effects
of RF radiation (21). Furthermore, there may perhaps also be
conicts of interests in terms of ties to the industry.
ICNIRP
On July 11, 2018, the ICNIRP released a draft of the guidelines
for limiting exposure to time‑varying electric, magnetic and
electromagnetic elds (100 kHz‑300 GHz). It was open for
public consultations until October 9, 2018. Appendix B was
based on the assessment of the health risks based on a literature
survey (https://www.icnirp.org/en/activities/public‑consulta-
tion/index.html).
Of note, in the background material to the new ICNIRP guidelines,
the IARC classication from 2011 of RF exposure as class 2B,
‘possibly’ carcinogenic to humans (11,12) was not included.
Notably, one of the ICNIRP commission members, Martin
Röösli (https://www.icnirp.org/en/about‑icnirp/commis-
sion/index.html), was also one of the IARC experts evaluating
the scientic RF carcinogenicity in May, 2011 (https://mono-
graphs.iarc.fr/wp‑content/uploads/2018/06/mono102‑F05.
pdf), which classied RF exposure as a class 2B ‘possible’
carcinogen. Thus, he should be aware of the IARC classica-
tion. Of note, one of the authors of this article (L.H.) was a
member of the IARC expert group.
Below, eight excerpts/quotes from the 2018 ICNIRP
draft guidelines are presented (https://www.icnirp.
org/cms/upload/consultation_upload/ICNIRP_RF_
Guidelines_PCD_2018_07_11.pdf). These assertions in the
ICNIRP evaluation do not seem to represent the valid evalu-
ation of the published literature on the health risks associated
with RF:
i) Brain physiology and function. ‘In summary, there is no
evidence of effects of radiof requency EMF [electromagnetic
eld] on physiological processes or eye pathology that impair
health in humans. Some evidence of supercial eye damage
has been shown in rabbits at exposures of at least 1.4 kW m‑2,
although the relevance of this to humans has not been demon‑
st ra t e d ’.
ii) Auditory, vestibular, and ocular function. ‘In s ummary,
no effects on auditory, vestibular, or ocular function relevant
to human health have been substantiated’.
iii) Neuroendocrine system. ‘In summary, the lowest level at
which an effect of radiofrequency EMF on the neuroendocrine
system has been observed is 4 W kg‑1 (in rodents and
primates), but there is no evidence that this translates to
humans or is relevant to human health. No other effects have
been substantiated’.
iv) Neurodegenerative diseases. ‘In summary, no adverse
effects on neurodegenerative diseases have been substanti‑
ate d ’.
v) Cardiovascular system, autonomic nervous system and
thermoregulation. ‘In summary, no effects on the cardiovas‑
cular system, autonomic nervous system, or thermoregulation
that compromise health have been substantiated for exposures
with whole body average SARs below approximately 1 W kg‑1,
and there is some evidence that 4 W kg‑1 is not sufcient to
alter body core temperature in hamsters. However, there
is strong evidence that whole body exposures in rats that
are sufcient to increase body core temperature by several
degrees centigrade can cause serious adverse health effects
in rat s’.
vi) Immune system and hematology. ‘The few human studies
have not indicated any evidence that radiofrequency EMF
affects health in humans via the immune system or haema‑
tolog y’.
vii) Fertility, reproduction and childhood development. ‘In
summary, no adverse effects of radiofrequency EMF exposure
on fertility, reproduction or development relevant to human
health have been substantiated’.
viii) Cancer. ‘In summary, no effects of radiofrequency EMF
on cancer have been substantiated’.
Since the ICNIRP 2018 draft guidelines excluded a large
number of science‑based evidence of health hazards from RF
radiation, numerous rebuttals have been sent to the ICNIRP.
However, it remains unknown as to whether these rebuttals
have been taken into account or not.
Thus, the ICNIRP does not acknowledge the health effects
caused by RF radiation. This has been rebutted by several
scientists (21‑24).
Details and proofs of scientific misinterpretation were
outlined in a comprehensive response by Dr Martin Pall (21).
He demonstrated that the denials of scientific facts
concerning health risks seem to be the rule in the Health
Risk Assessments of the ICNIRP 2018 Draft Guidelines.
ICNIRP confirmed that Pall's response was received on
October 8, 2018 (tinyurl.se/pall). As outlined above in all
eight summarizing statements, the ICNIRP denies that
any scientific reports exist which demonstrate harmful
effects below the ICNIRP guidelines. However, as Dr Pall
demonstrated, a large number of peer‑reviewed studies have
been published over a period of >20 years contradicting the
ICNIRP evaluations. Independent peer‑reviewed scientic
articles (1,7,8) have demonstrated the harmful effects even
far below the current public safety limits based on ICNIRP
1998 reference levels 10 W/m2for 2‑300 GHz and 2‑10 W/m2
for 400 to 2,000 MHz (18).
MOLECULAR AND CLINICAL ONCOLOGY 3
The ICNIRP also seems to have disregarded previously
published animal studies (14‑16) on carcinogenesis. The NTP
results have been discussed in a commentary (25) and clari-
ed to that degree that they should have been considered in
full. These ndings supported human epidemiology results on
cancer risks from RF radiation (6,26). The nal new ICNIRP
guidelines have yet to be published.
In fact, a hint of the ICNIRP nal document may be found
in a presentation by the ICNIRP chairman Eric van Rongen
at a meeting held on April 17, 2019 https://www.anfr.
fr/leadmin/mediatheque/documents/expace/workshop‑5G/2
0190417‑Workshop‑ANFR‑ICNIRP‑presentation.pdf.
van Rongen stated that there is no evidence that RF EMF
causes diseases, such as cancer and that the US NTP (14‑15)
and Ramazzini Institute (16) studies are not convincing for
carcinogenesis. ICNIRP seems still to hold the view, which
is clearly benecial to the industry, that only thermal effects
exist for RF radiation and not any non‑thermal effects, which
have been proven in research by the majority of scientists in
this eld.
ICNIRP recently published a note on the NTP and Ramazzini
Institute animal studies (27). Some of their incorrect state-
ments are commented on below. The ICNIRP claims that
there is no veried mechanism for RF radiation carcinogen-
esis, in spite of well‑designed studies showing the contrary,
e.g., oxidative stress (25,28) and DNA damage (25,29). The
ICNIRP claims that the histopathological evaluation was not
blinded in these studies; however, this is not true, as supported
by the methods described in these studies. Furthermore, the
ICNIRP claims that the body core temperature was increased
in the NTP study (15) and suggested it to be a factor increasing
cancer risk, although heat is not a known carcinogen. The
ICNIRP also claims that only the Hardell group found an
increased risk for acoustic neuroma although the Interphone
study had similar ndings (7). ICNIRP does not seem to take
into account the concordance between the tumor types found
in human epidemiological and animal studies. These are just
a few examples.
It is noteworthy that ICNIRP repeats certain debatable state-
ments in spite of being rebutted by Melnick (25) and should
have been known to the 13 ICNIRP Commission members
(https://www.icnirp.org/en/about‑icnirp/commission/index.
html) with their names listed at the end of the article (27).
Perhaps this ICNIRP article lacks scientic authorization. As
previously suggested, they seem to create doubt (30,31). Thus,
one must be cautious when also interpreting other publications
by the 13 Commission members.
The ICNIRP points out an important scientic problem: How
incorrect data can achieve lives of their own and gain respect-
ability and credence with inappropriate repetition. Corrections
and clarications (25), seem to have difcult time to coun-
teract any possible errors, which is to the disadvantage of both
good science and public health. Of note, President Franklin
D. Roosevelt stated that ‘Repetition does not transform a lie
into a truth’ (https://www.azquotes.com/quote/377323).
Finland, in a new regulation, 1045/2018, dated December 15,
2018, allowed higher average radiation, 200 W, in narrow
areas of 1x1 cm (1 cm2) (please see Table 1.5, Note 3 (in
Swedish): (https://www.nlex./data/sdliite/liite/6943.pdf).
This was probably decided in order to accommodate the
steerable, beam‑formed, narrow 5G elds, which will be used
by most 5G equipment. The Director of the Radiation Safety
Agency in Finland claims that this is no problem, as if you
disperse the effect of 200 W (on 1 cm2) upon a whole square
meter it will still be within the ICNIRP guideline of 10 W/m2
(private communication from Petteri Tiippana, 2018, please
see https://www.dropbox.com/s/89cm7bmb410em8w/200W%
3Am2‑STUK.pdf?dl=0).
On top of the other flaws which ICNIRP members are
presenting, they also suggest that only the ‘mean values’ of RF
radiation should be measured. However, the interferences and
the supra‑additive effects between pulses from different RF
radiation sources can lead to ‘hundreds of thousands higher
density’ short‑time pulses than the power density mean values
with the guideline of 10 W/m2. This has been well‑documented
in a report from the Finnish Radiation Safety Agency (32).
Panagopoulos (29) has clearly demonstrated that using mean
values for RF radiation may underestimate the risk. Intensity,
frequency, exposure duration, polarization, pulsing and modu-
lation are crucial parameters for the bioactivity. Puranen (32)
states that the instant effect density can be much stronger than
the mean values. However, the guidelines only consider the
mean values.
Appeals to the EU and responses from the EU
The impact of the many international appeals on RF radiation
safety, if any, is unclear. However, they will be historical docu-
ments on warnings that have been thus far ignored by the EU
and the WHO. This is exemplied below.
The deployment of 5G for microwave radiation has given
increasing awareness and concern among individuals
regarding the risks to human health and the environment
resulting in massive protests and even a moratorium in certain
EU countries and US cities (https://tinyurl.se/5gstoppers). 5G
uses a different technology compared with previous genera-
tions, such as 2G, 3G and 4G. In the following, our 5G appeal
to EU is discussed (www.5Gappeal.eu). This has currently
been signed by >260 scientists and medical doctors from a
number of countries. It is still open for endorsement.
a) The 5G Appeal, September 13, 2017 and response. Be l ow,
the full text, with included links to references, is presented
although it can also be found online (www.5gappeal.eu), and
also at (https://www.environmentandcancer.com/5g‑appeal/).
Scientists and doctors warn of potential severe health effects
of 5G. ‘We the undersigned scientists and doctors recommend
a moratorium on the roll‑out of the fth generation, 5G, for
telecommunication until potential hazards for human health
and the environment have been fully investigated by scientists
independent from industry. 5G will substantially increase
exposure to radiofrequency electromagnetic elds (RF‑EMF)
HARDELL and NYBERG: APPEALS ON THE DEPLOYMENT OF 5G
4
on top of the 2G, 3G, 4G, Wi‑Fi, etc. for telecommunications
already in place. RF‑EMF has been proven to be harmful for
humans and the environment’.
5G leads to the marked increase of mandatory exposure
to wireless radiation. ‘5G technology is effective only over
short distance. [The range of 5G radiation is decreased due
to its increased carrier frequency (up to ~100 GHz) compared
to previous mobile telephony generations and other existing
microwave telecommunications radiations such as Wi‑Fi
(up to 2.6 GHz), and according to Rayleigh's law which
explains that the intensity of scattered electromagnetic radia‑
tion (Jscat) is proportional to f 4 (where f is the frequency
of the radiation) when the dimensions of the scattering
particles ‑ such as the molecules of the air, of the building
materials, etc. ‑ are smaller than the wavelength (which is the
case for all mobile telephony radiations): Jscat ∝ f 4 (33)]. It is
poorly transmitted through solid material. Many new [base]
antennas will be required and full‑scale implementation will
result in antennas every 10 to 12 houses in urban areas, thus
massively increasing mandatory exposure’.
‘[Moreover, apart from the increase in background exposure,
5G is likely to induce signicant thermal effects in addition
to the already non‑thermal ones, again due to its signicantly
higher frequency (34)]’.
‘With “the ever more extensive use of wireless technolo‑
gies,” (35) nobody can avoid to be exposed. Because on top
of the increased number of 5G‑transmitters (even within
housing, shops and in hospitals) according to estimates,
“10 to 20 billion connections” (36) (to refrigerators, washing
machines, surveillance cameras, self‑driving cars and buses,
etc.) will be parts of the Internet of Things. All these together
can cause a substantial increase in the total, long term
RF‑EMF exposure to all EU citizens’.
Harmful effects of RF‑EMF exposure have already been
proven. ‘Over 230 scientists from >40 countries [now
252 scientists from 43 nations] (37) have expressed their
“serious concerns” regarding the ubiquitous and increasing
exposure to EMF generated by electric and wireless devices
already before the additional 5G roll‑out. They refer to the
fact that “numerous recent scientific publications have
shown that EMFs affect living organisms at levels well below
most international and national guidelines”. Effects include
increased cancer risk, cellular stress, increase in harmful free
radicals, genetic damages, structural and functional changes
of the reproductive system, learning and memory decits,
neurological disorders, and negative impacts on general
well‑being in humans. Damage goes well beyond the human
race, as there is growing evidence of harmful effects (38) to
both plants (39) and animals (40)’.
‘After the scientists’ appeal was written in 2015 additional
research has convincingly conrmed serious health risks from
RF‑EMF elds f rom wireless technology. The world's largest
study (25 million US dollar) National Toxicology Program
(NTP) (41), shows statistically signicant increase in the inci‑
dence of brain and heart cancer in animals exposed to EMF
[intensities] below the ICNIRP (International Commission on
Non‑Ionizing Radiation Protection) guidelines followed by
most countries. These results support results in human epide‑
miological studies (17) on RF radiation and brain tumour
risk. A large number of peer‑reviewed scientic reports (2)
demonstrate harm to human health from EMFs’.
‘The International Agency for Research on Cancer (IARC), the
cancer agency of the World Health Organization (WHO), in
2011 concluded that EMFs of frequencies 30 KHz ‑ 300 GHz
are possibly carcinogenic to humans (Group 2B) (12,42).
However, new studies like the NTP study mentioned above and
several epidemiological investigations including the latest
studies on mobile phone use and brain cancer risks conrm
that RF‑EMF radiation is carcinogenic to humans (17)’.
‘The EUROPA EM‑EMF Guideline 2016 (1) states that ”there
is strong evidence that long‑term exposure to certain EMFs is
a risk factor for diseases such as certain cancers, Alzheimer's
disease, and male infertility…Common EHS (electromagnetic
hypersensitivity) symptoms include headaches, concentra‑
tion difculties, sleep problems, depression, lack of energy,
fatigue, and u‑like symptoms”’.
‘An increasing part of the European population is affected
by ill health symptoms that have for many years been linked
to exposure to EMF and wireless radiation in the scientic
literature. The International Scientic Declaration on EHS &
multiple chemical sensitivity (MCS), Brussels (43), declares
that: “In view of our present scientic knowledge, we thereby
stress all national and international bodies and institutions…
to recognize EHS and MCS as true medical conditions which
acting as sentinel diseases may create a major public health
concern in years to come worldwide i.e. in all the countries
implementing unrestricted use of electromagnetic eld‑based
wireless technologies and marketed chemical substances…
Inaction is a cost to society and is not an option anymore…
we unanimously acknowledge this serious hazard to public
health…that major primary prevention measures are adopted
and prioritized, to face this worldwide pan‑epidemic in
perspective”’.
Precautions. ‘The Precautionary Principle (44) was adopted
by EU 2005 (45): “When human activities may lead to morally
unacceptable harm that is scientically plausible but uncer‑
tain, actions shall be taken to avoid or diminish that harm”’.
‘The Council of Europe Resolution 1815 (46): “Take all
reasonable measures to reduce exposure to electromagnetic
elds, especially to radio frequencies from mobile phones,
and particularly the exposure to children and young people
who seem to be most at risk f rom head tumours…Assembly
strongly recommends that the ALARA (as low as reasonably
achievable) principle is applied, covering both the so‑called
thermal effects and the athermic [non‑thermal] or biological
effects of electromagnetic emissions or radiation” and to
“improve risk‑assessment standards and quality”’.
‘The Nuremberg code (47) applies to all experiments on
humans, thus including the roll‑out of 5G with new, higher
MOLECULAR AND CLINICAL ONCOLOGY 5
RF‑EMF exposure. All such experiments: “should be based
on previous knowledge (e.g., an expectation derived from
animal experiments) that justies the experiment. No experi‑
ment should be conducted, where there is an a priori reason
to believe that death or disabling injury will occur; except,
perhaps, in those experiments where the experimental physi‑
cians also serve as subjects,” Nuremberg code pts 3‑5 (47).
Already published scientific studies show that there is “a
priori reason to believe” in real health hazards’.
‘The European Environment Agency (48) is warning for
“Radiation risk f rom everyday devices” in spite of the radia‑
tion being below the WHO/ICNIRP standards (49). EEA also
concludes: “There are many examples of the failure to use the
precautionary principle in the past, which have resulted in
serious and often irreversible damage to health and environ‑
ments…harmful exposures can be widespread before there is
both ‘convincing’ evidence of harm from long‑term exposures,
and biological understanding [mechanism] (50) of how that
harm is caused”’.
‘Safety guidelines’ protect the industry, not health. ‘The
current ICNIRP “safety guidelines” are obsolete. All proofs
of harm mentioned above arise although the radiation is
below the ICNIRP “safety guidelines” (49). Therefore new
safety standards are necessary. The reason for the misleading
guidelines is that “conict of interest of ICNIRP members (10)
due to their relationships with telecommunications or electric
companies undermine the impartiality that should govern the
regulation of Public Exposure Standards for non‑ionizing
radiation…To evaluate cancer risks it is necessary to include
scientists with competence in medicine, especially oncology’.
‘The current ICNIRP/WHO guidelines for EMF are based on
the obsolete hypothesis that “The critical effect of RF‑EMF
exposure relevant to human health and safety is heating of
exposed tissue” (51). However, scientists have proven that
many different kinds of illnesses and harms are caused
without heating (“non‑thermal effect”) (52) at radiation levels
well below ICNIRP guidelines’.
The authors thus urge the EU to carry out the following.
i) ‘To take all reasonable measures to halt the 5G RF‑EMF
expansion until independent scientists can assure that
5G and the total radiation levels caused by RF‑EMF (5G
together with 2G, 3G, 4G, and WiFi) will not be harmful for
EU‑citizens, especially infants, children and pregnant women,
as well as the environment’. ii) ‘To recommend that all EU
countries, especially their radiation safety agencies, follow
Resolution 1815 and inform citizens, including, teachers
and physicians, about health risks from RF‑EMF radiation,
how and why to avoid microwave radiation, particularly
in/near e.g., daycare centers, schools, homes, workplaces,
hospitals and elderly care’. iii) ‘To appoint immediately,
without industry inuence, an EU task force of independent,
truly impartial EMF‑and‑health scientists with no conicts
of interest (to re‑evaluate the health risks and: a) To decide
about new, safe “maximum total exposure standards” for
all microwave radiation within EU. b) To study the total
and cumulative exposure affecting EU‑citizens. c) To create
rules that will be prescribed/enforced within the EU about
how to avoid exposure exceeding new EU “maximum total
exposure standards” concerning all kinds of EMFs in order
to protect citizens, especially infants, children and pregnant
women’. iv) ‘To prevent the wireless/telecom industry through
its lobbying organizations from persuading EU‑ofcials to
make decisions about further propagation of RF radiation
including 5G in Europe’. v) ‘To favor and implement wired
digital telecommunication instead of wireless’.
First reply from the EU. A reply from the EU was sent on
October 13, 2017 by the Directorate‑General Health and
Food Safety (Public health, country knowledge, crisis
management) in Luxembourg. It was not replied to by the
Commissioner Andriukaitis, but instead by Mr. John F. Ryan,
Director (for the full text please see: http://www.5gappeal.
eu/wp‑content/uploads/2018/06/reply_ryan.pdf). Some para-
graphs are presented below:
‘It is worth underlining that for the Commission health
protection is always taken into account in all of its proposals.
There is consistent evidence presented by national and inter‑
national bodies (International Commission on Non Ionising
Radiation Protection ‑ ICNIRP, Scientific Committee on
Emerging and Newly Identied Health Risks ‑ SCENIHR)
that exposure to electromagnetic fields does not repre‑
sent a health risk, if it remains below the limits set by
Council Recommendation 1999/519/EC (https://ec.europa.
eu/health//sites/health/les/electromagnetic_elds/docs/emf_
re c 519 _ e n. p d f )’.
‘The Scientic Committee on Emerging and Newly Identied
Health Risks, which is independent of the Commission, has a
standing mandate to provide this update’.
‘It has already produced ve opinions. The last opinion was
adopted in January 2015 on “Potential health effects of exposure
to electromagnetic elds”. (https://ec.europa.eu/health/scien‑
tic_committees/emerging/docs/scenihr_o_041.pdf)’.
‘These scientic opinions have not provided any scientic
justication for revising the exposure limits (basic restric‑
tions and reference levels) under Council Recommendation
1999/519/E C’.
‘Digital technologies and mobile communication technolo‑
gies, including high speed internet, will be the backbone of
Europe's future economy, allowing all citizens to be connected.
At the same time, all citizens deserve appropriate protec‑
tion against electromagnetic elds from all types of sources
including from wireless devices’.
‘Most 5G networks are expected to use smaller cells than
previous generations with lower electromagnetic elds expo‑
sure levels. This is conrmed by the experience so far gained.
The introduction of 3G and 4G has not increased exposure
from environmental elds and this has been published also
in peer‑reviewed journals. In particular, the introduction of
3G has lowered exposure of mobile phone users for calls,
compared to 2G’.
HARDELL and NYBERG: APPEALS ON THE DEPLOYMENT OF 5G
6
‘Related to the issue of the alleged conicts of interests, the
Commission is not aware of any conicts of interests of members
of international bodies such as ICNIRP or the members of
SCENIHR. Please be informed that the Ombudsman conclu‑
sion in case 208/2015/P concerning conicts of interests in
a Commission expert group on electromagnetic elds is that
there was no maladministration by the European Commission
(https://www.ombudsman.europa.eu/en/cases/decision.
faces/en/78175/html.bookmark)’.
‘Please be assured that the Commission will pursue scrutiny
of the independent scientic evidence available to ensure the
highest health protection of our citizens’.
Comment: There are obvious misconceptions in this reply
such as: ‘The introduction of 3G and 4G has not increased
exposure from environmental fields and this has been
published also in peer‑reviewed journals’. On the contrary,
numerous peer‑reviewed articles have demonstrated that expo-
sure to ambient RF radiation has increased substantially, as
discussed (3‑6).
In addition, the statement that: ‘the Commission is not aware
of any conicts of interests of members of international bodies
such as ICNIRP or the members of SCENIHR’ does not repre-
sent the scientic evidence of inherent conicts of interest
both in ICNIRP and SCENIHR (9,10). The very Commission
seems to be ill‑informed or even misinformed, as the EU
seems to take information mainly from these two fraudulent
organizations, but not from independent researchers. The EU
does not seem to rely on sound science and thereby downplays
the RF‑related risks (7‑12,53,54).
b) First rebuttal to the EU and the response. On
November 13, 2017, a rebuttal was sent to the EU
Commissioner of Health, Dr Andriukaitis. The whole
letter can be found at: https://www.environmentandcancer.
com/letter‑to‑vytenis‑andriukaitis‑13‑11‑2017/.
‘We suppose that you know that Director John F. Ryan,
October 13, 2017 replied (Ares 2017 5015409 ‑ Reply to the EU
5G‑appeal, and that he said: “There is consistent evidence
that exposure to electromagnetic elds does not represent a
health risk… if below the limits …” His conclusion is based
on the opinions of ICNIRP and SCENIHR’.
‘As early as February 1, 2016, in a Comment on SCENIHR
to Mr. Ryan it was shown in article and letter by Drs. [S a ge],
Carpenter and Hardell, representing BioInitiative and ECERI,
that: ”The evidence in the SCENIHR Final Opinion on EMF
clearly and convincingly establishes the potential for health
effects of exposure to electromagnetic elds [EMF]. Based
on the evidence provided in this Opinion, the Committee is
obligated to draw to the attention of the [EU] Commission
that EMF is a new and emerging problem that may pose an
actual or potential threat”’ (55).
‘In spite of all this, Mr Ryan in his reply to us still continues
to claim that EMF ‘does not represent a health risk’ and ‑
without any other references than ICNIRP and SCENIHR
‑ defends industry's standpoint that EMFs are harmless if
below the ICNIRP “safety guidelines”. In addition he ignores
the IARC evaluations on both ELF‑EMF and RF‑EMF to be
‘possible’ human carcinogens, Group 2B’.
‘In the 5G‑Appeal we urge EU to appoint a truly independent
expert group of EMF‑and‑health researchers (contrary to
ICNIRP and SCENIHR) to decide about new safe guidelines
for EMF exposure. It is imperative to immediately apply
EU:s Precautionary Principle (and ALARA) enabling rapid
response to stop distribution of 5G products in order to
diminish the harm that has already been proven by scientists.
A European pan‑epidemic may follow if you don't do so’.
Second reply from EU on 29 November, 2017. This was sent
from the European Commission, Cabinet of Commissioner
Vytenis Andriukaitis, Head of Cabinet Brussels, written
by Arūnas Vinciunas. The full reply can be found at:
http://www.5gappeal.eu/wp‑content/uploads/2018/06/reply_
vinciunas.pdf).
‘When Mr Ryan answered your email, in which you stated
your disagreement with the Commission's stance on the 5G
appeal, he presented the conclusions of roughly two decades
of research on the potential health effects of EMF, and the
views expressed in the Scientic Opinions produced by the
independent Scientic Committees. [ICNIRP ‑ International
Commission on Non‑Ionizing Radiation Protection and
SCENIHR ‑ Scientic Committee on Emerging and Newly
Identied Health Risks]. The Committee's last Opinion on
EMF, published in 2015, is based on hundreds of peer‑reviewed
studies published worldwide and is the fourth Opinion on
EMF published since EMF legislation was adopted in 1999.
The Committee's conclusion in this latest Opinion was based
on exposure studies, epidemiological studies and in vivo and
in vitro studies, and studies on any suggestions of causality
were considered for the weighting’.
‘The Commission services are confident that the advice
provided by the Scientic Committees is unbiased, accurate
and scientically sound and therefore do not feel it necessary
to appoint an independent expert group of EMF‑and‑health
researchers to discuss new safe guidelines for EMF exposure’.
‘The recourse to the EU's Precautionary Principle to stop the
distribution of 5G products appears too drastic a measure. We
rst need to see how this new technology will be applied and
how the scientic evidence will evolve. Please rest assured
that the Commission will keep abreast of future developments
in view of safeguarding the health of the European citizens at
the highest level possible and in line with its mandate’.
Comment: This reply from EU is far from adequate. It does
not represent a sound evaluation of the RF‑related radiation
risks based on published peer‑reviewed studies. This is again
outlined in our response to the EU.
c) Second rebuttal to the EU and the response. On January 17,
2018, a letter was sent to Dr. Vytenis Andriukaitis, EU
Commissioner of Health. Sections of this letter are presented
MOLECULAR AND CLINICAL ONCOLOGY 7
below and the full text can be found at: https://www.environ-
mentandcancer.com/letter‑to‑vytenis‑andriukaitis‑and‑donald
‑tusk‑17‑01‑18/.
‘Following the letter and the Scientist Appeal calling for a
moratorium on 5G (“The 5G Appeal”), which we sent to your
ofce, we received a response from Director John F. Ryan
on October 13, 2017 and then, upon our reply, a letter f rom
Mr. Arūnas Vinciūnas dated 29.11.2017’.
‘Despite the conclusive evidence presented in our letters, both
Director Ryan and Mr. Vinciūnas gave generic responses and
continued to claim that EMF “does not represent a health
risk”. In doing so they only refer to ICNIRP and SCENIHR
opinions without explaining why they disregarded the compel‑
ling evidence and references under the 5G‑Appeal headline:
“Harmful effects of RF‑EMF exposure are already proven”’.
‘The ICNIRP exposure limits are dependent on an unproven
hypothesis that “only heat from EMF can cause health
hazards”. This hypothesis has clearly been rejected in a large
number of scientic studies’.
‘Both EU ofcials defend the industry‑supportive standpoint
that EMFs are harmless if below the ICNIRP “guidelines”.
However, many of the scientists on both ICNIRP's and
SCENIHR's committees are connected to the telecom industry
with obvious conicts of interest’.
‘Mr Vinciūnas stated in his letter: “The recourse to the EU's
Precautionary Principle to stop the distribution of 5G prod‑
ucts appears too drastic a measure.” Mr Vinciūnas nishes
his letter: “we need to see … how the scientic evidence will
evolve”’.
‘According to Communication from the Commission on
the precautionary principle: “Whether or not to invoke the
Precautionary Principle is a decision exercised where scien‑
tic information is insufcient, inconclusive, or uncertain
and where there are indications that the possible effects on
the environment, or human, animal or plant health may be
potentially dangerous and inconsistent with the chosen level
of protection.” That describes the situation with 5G perfectly.
Existing data shows that 5G frequencies [radiations] are
hazardous. However, additional studies will be necessary to
fully determine the extent of the risk’.
Third reply from the EU. This letter was replied to on
April 27, 2018 by Mr. Arūnas Vinčiūnas from the Cabinet of
Commissioner Vytenis Andriukaitis. For the full third reply
to our appeals please see: https://www.environmentandcancer.
com/answer‑from‑arunas‑vinciunas‑27‑ 04‑2018/.
‘Thank you very much for your letter of 15 March 2018 which
was also transmitted by email on 19 March. Commissioner
Andriukaitis has asked me to reply to you on his behalf’.
‘Finally, let me refer to the previous correspondence you have
had with John F. Ryan, Director of Public Health and me
(29 November 2017, 13 October 2017 and 19 February 2018)
where we have comprehensively explained our position with
regard to the arguments you have raised. It is my view that we
have now extensively deliberated on the matter and that we
should refrain from further repetition’.
‘Please rest assured that the Commission will remain
committed to safeguarding the health of the European citizens,
at the highest level possible and in line with his mandate’.
d) Third rebuttal to the EU and the response. This
rebuttal had the title “Request for a moratorium on the
5G rollout. Request for guidelines based on independent
research. Request for documents showing that 5G is safe”.
On May 20, 2019 a letter with these requests was sent to
Dr Karmenu Vella, EU Commissioner of Environment and
Dr Vytenis Andriukaitis, EU Commissioner of Health. For
the full text please see: https://www.environmentandcancer.
com/letter‑to‑vytenis‑andriukaitis‑20‑05‑2019/.
‘We make reference to the Precautionary Principle (PP) (56) It
”enables a rapid response to be given in the face of a possible
danger to human health…institutions may take protective
measures without having to wait until the reality… of risks
become apparent … preventive action should be taken” (57).
Research conrms 5G to be a risk to all life on earth’.
‘With this communication we touch upon three points:’
i) ‘Firstly, we request in the 5G Appeal to EU (www.5gappeal.
eu), of which you are a public servant and representative, to
declare an immediate moratorium on 5G deployment. The
5G appeal to EU is now conrmed by 230+ truly independent
scientists and physicians from 36 countries. The Space 5G
appeal (58) ha s more th a n 83, 0 0 0 af rm a t i o n s from 168 co u n ‑
tries. According to PP (56) and EU IP/00/96 (59) “protection
of health takes precedence over economic considerations.”’
ii) ‘Secondly, we ask for groups of truly industry‑independent
researchers to establish new guidelines for exposure. An
“In‑depth analysis” of the deployment of 5G (60), published
by EU in April 2019, needs to be seriously considered. It
stated that” One aspect, for example, that is not well under‑
stood today is the unpredictable propagation patterns that
could result in unacceptable levels of human exposure to
electromagnetic radiation.”(p. 6)’. iii) ‘Thirdly, with this letter
we are formally requesting, in accordance with Art. 42 (61)
on EU Fundamental Rights, access to all documents in your
possession, either created by you or at your disposal, related
to the effects of EMF to human health and the environment.
Once in possession of such a list, we will decide which of those
documents, if any, are of interest and show that 5G is safe. The
list of the documents, and the ways to access them, should be
sent to the email addresses below’.
‘We note that, while the EU is eagerly promoting the rollout
of 5G, a new EU report admits (60) “the problem is that
currently it is not possible to accurately simulate or measure
5G emissions in the real world” (p. 12). “Signicant concern
is emerging over the possible impact on health and safety
arising from potentially much higher exposure to radiofre‑
quency electromagnetic radiation arising from 5G” (p. 4).
The EU report also stresses dangers: ”Increased exposure
HARDELL and NYBERG: APPEALS ON THE DEPLOYMENT OF 5G
8
may result not only from the use of much higher frequencies in
5G but also from the potential for the aggregation of different
signals, their dynamic nature, and the complex interference
effects that may result, especially in dense urban areas.”
(p. 11)’.
Fourth reply from the EU. Finally, a response was delivered
by the EU on September 5, 2019, although with reference to the
wrong date of our letter. It was sent by Arunas Vinciunas from
the Cabinet of Commissioner Vytenis Andriukaitis. The full
response can be read at: https://www.environmentandcancer.
com/answer‑from‑arunas‑vinciunas‑05‑09‑2019/.
‘Thank you for your email of 7 July 2019 to Commissioner
Andriukaitis in which you request to halt the 5G expansion
in the EU immediately in order to allow a moratorium for
industry independent research. Commissioner Andriukaitis
has asked me to reply to you on his behalf’.
‘In my latter note to you I already expressed my view that we
had extensively deliberated on the matter and that we should
refrain from further repetition’.
‘As regards your request to halt the launch of the new 5G
technology, I would like to conrm the view already expressed
in my note of 29 November 2017 to you that stopping the
distribution of 5G products appears too drastic a measure. I
repeat that rst there is a need to see how this new technology
will be applied and how the scientic evidence will evolve’.
‘Concerning your call for a scientic evaluation and new
guidelines for exposure, the second point you have raised,
let me stress that the Commission will review the situation
once the review of the guidelines issued by the International
Commission on Non‑Ionizing Protection (ICNIRP) will be
nalised which is expected in due course’.
‘As regards your third point, documents related to the
effects of electromagnetic fields to human health and
the environment, please be referred to the opinion of the
Commission's Scientific Committee on Emerging and
Newly Identified Health Risks of 20 January 2015 on
potential health effects of exposure to electromagnetic
elds (EMF) (https://ec.europa.eu/health/scientic_commit‑
tees/emerging/docs/scenihr_o_041.pdf) that provides an
extensive list of references to scientic literature on this issue’.
Comment on the fourth reply from the EU appeal: There is no
new evidence of the safety in this letter from EU compared with
the earlier replies. Of note, the EU relies on documentation of
risk only on old and biased selection of references in one single
report from SCENIHR (https://ec.europa.eu/health/scien-
tic_committees/emerging/docs/scenihr_o_041.pdf). Thus,
EU ofcials still seem to base the evaluation of the health
risks on reports from the ICNIRP and SCENIHR that have
been seriously criticized. Of note, the EU relies on a report
from 2015 as to scientic publications on the safety of 5G,
a technology that was not developed during that time. This
suggests that perhaps the EU is reluctant to deal with the safety
issues associated with 5G technology.
e) Fourth rebuttal to the EU. On October 24, 2019 a fourth
rebuttal was sent to the EU (https://www.environmentand-
cancer.com/letter‑to‑arunas‑vinciunas‑24‑10‑2019). We wrote
that ‘Specically now, as we wish to assist the Commissioner
in giving due response, it can be further specied f rom this
side that we need the list of documents related to EMFs
created by RF/Radiofrequencies (so: not by ELF) and even
more specically, to the list of those documents based on which
the Commission is basing its current position that 5G should
not be stopped nor subject to a moratorium (see the statement
of your letter that “rst there is a need to see how this new
technology will be applied and how the scien6c evidence
will evolve”). We leave aside our total disagreement on the
merits of such position at this time: formally, we are entitled
to receive from you such a list of documents based on which
the Commissioner determined that 5G is safe. Based on that
list we will decide which of those documents, are of interest.
Please provide such list by email no later than October 31,
2019. This is urgent’.
Fifth reply from the EU. In this response, dated December 19,
2019, it was stated that new ICNIRP guidelines are expected.
Thus, the same approach to this issue as previously and no new
commitment (https://www.environmentandcancer.com/answe
r‑from‑martin‑seychell‑19‑12‑2019).
Appeals to the Nordic Prime Ministers
The 5G Appeal was also sent to the Nordic Prime
Ministers (https://www.environmentandcancer.
com/letter‑to‑nordic‑ministers‑27‑6‑2018/); (https://www.envi-
ronmentandcancer.com/letter‑to‑nordic‑ministers‑5‑3‑2019/).
The only reply, dated March 29, 2019, was sent from the
Swedish government (Ministry of Enterprise and Innovation,
Mari Mild). It was stated that the government relies on Swedish
Radiation Safety Authority (SSM) and their yearly update of
health risks and that no new health risks have been reported.
According to the letter there is no reason for a moratorium on
the deployment of 5G, see (in Swedish) (https://www.miljo och-
cancer.com/svar‑fran‑naringsdepartementet‑29‑3‑2019/). SSM
relies on ICNIRP.
Discussion
Our experience with the EU and the Governments of the
Nordic countries suggests that the majority of decision makers
are scientically uninformed on health risks from RF radia-
tion (62). In addition, they seem to be uninterested to being
informed by scientists representing the majority of the scien-
tic community, i.e., those scientists who are concerned about
the increasing evidence or even proof of harmful health effects
below the ICNIRP guidelines (www.emfscientist.org). Instead,
they rely on evaluations with inborn errors of conicts, such
as ICNIRP. In fact, the ICNIRP, with the support of WHO
and major telecommunications companies, has been rather
successful in implementing their views in the EU and world-
wide. Their guidelines seem to be based on the omission of
scientic facts. Thus, their possible ignorance of the health
risks is of concern, as well as their reluctance to adhere to
warnings from large numbers of scientists around the world.
MOLECULAR AND CLINICAL ONCOLOGY 9
It is striking that 5G is deployed without previous scientic
evaluation of health risks. Not only cancer risks, but also other
health effects such as fertility, cognitive and neurobehavioral
effects, oxidative stress and electromagnetic hypersensitivity
(EHS) have been associated with RF exposure [for a more
detailed discussion on this tope, please see previous publica-
tions (1,7,8,28,35)]. It is thus noteworthy that the ICNIRP
thermal paradigm is still used for the evaluation of the health
risks associated with RF radiation. One issue of major concern
is that there seems to be conicts of interest among persons
in the evaluating groups. Furthermore the same persons
may often be found in different bodies, thereby in fact citing
themselves representing a cartel (https://www.saferemr.
com/2018/07/icnirps‑exposure‑guidelines‑for‑radio.html).
This has been outlined in peer‑reviewed publications (9,10).
This is also an ethical question. Thus, it would not be
possible to test a new drug on individuals without informa-
tion and signed permission by each individual. Certainly, this
principle should apply to 5G that is furthermore, mandatory.
Exposure to RF radiation from 5G must be regarded as a
medical experiment with potential health risks, some known
and expected based on current knowledge, some unknown
since this is a new untested technology. A letter of information
to those exposed must be sent for informed consent. However,
it must be concluded that such a letter, affirming no risk,
cannot be formulated based on the limited number of studies
on 5G, in fact most of them with no assurance of no risks.
This is also a moral question for all the individuals
involved in the propagation of 5G. It is to be noted that indi-
viduals within e.g., ICNIRP, national governmental bodies and
the EU, partly a cartel, seem to neglect scientic warnings.
They instead seem to follow the no‑risk paradigm. It is thus
questionable as to how it is possible to thereby disregard the
diseases caused by this technology and to not consider the
affected persons.
Taking the history of e.g., tobacco and smoking and the long
period of time it took for cancer classication into account, it
is fully understandable that RF radiation is still in the begin-
ning of that history. However, if no action is currently taken,
the costs to society will most likely be very high in terms of
premature deaths, deteriorated public health and damage to
the ecological system. It is however, important to publish the
history of neglected RF radiation warnings. The EU seems
to perhaps lacking in that respect. It must be concluded that
the polluter has to pay the full cost of harm from this tech-
nology (63). Those in responsible positions in governments
and organizations intended to protect the public and the envi-
ronment from harm (WHO and ICNIRP), but who fail to do so
by ignoring the increasing warnings from scientists worldwide
about the dangers of 5G, should also be held responsible
for the harm to the public that they thereby induce (64). No
doubt damage to the environment by the business sector
may be substantial (https://www.theguardian.com/environ-
ment/2010/feb/18/worlds‑top‑rms‑environmental‑damage).
The EU principle that the Polluter Pays (Article 191, pt 2)
states: ‘Union policy on the environment shall aim at a high
level of protection taking into account the diversity of situa‑
tions in the var ious regions of the Union. It sha ll be based on the
precautionary principle and on the principles that preventive
action should be taken, that environmental damage should as
a priority be rectied at source and that the polluter should
pay’. (https://eur‑lex.europa.eu/LexUriServ/LexUriServ.do?uri
=CELEX:12008E191:EN:HT M L).
‘The fundamental principle of this Directive should
therefore be that an operator whose activity has caused the
environmental damage or the imminent threat of such damage
is to be held nancially liable, in order to induce operators
to adopt measures and develop practices to minimise the
risks of environmental damage so that their exposure to
nancial liabilities is reduced’ (65) (https://eur‑lex.europa.
eu/legal‑content/EN/TXT/HTML/?uri=CELEX:32004L0035
&from=EN).
The industry tries to convince us that the super
high frequencies of 5G are so weak and its milli-
meter waves will penetrate only the outer surface of
the skin. The opposite was proven in USSR research
already in 1977 (https://www.cia.gov/library/reading-
room/docs/CIA‑RDP88B01125R000300120005‑6.pdf).
High frequencies (37‑60 GHz), which will be used in 5G,
caused several kinds of detrimental effects in experimental
rats. The high frequencies seem to be worse than the lower
frequencies. The USSR experiments were made more than
40 years ago ‑ when we had no digital pulsed radiation ‑ with
a generator producing sinus curves. Peaks of pulsed radiation
used in 5G with unpredictable intensity changes seem to be an
important parameter for the bioactivity of RF radiation (29).
In conclusion, this article demonstrates that the EU
has given mandate to a 13‑member, non‑governmental
private group, the ICNIRP, to decide upon the RF radiation
guidelines. The ICNIRP, as well as SCENIHR, are well
shown not to use the sound evaluation of science on the
detrimental effects of RF radiation, which is documented
in the research which is discussed above (9,10,21‑24,54,55).
These two small organizations are producing reports which
seem to deny the existence of scientic published reports on
the related risks. It should perhaps be questioned whether it
is in the realm of protecting human health and the environ-
ment by EU and whether the safety of EU citizens and the
environment can be protected by not fully understanding
the health‑related risks.
Acknowledgements
Not applicable.
Funding
No funding was received.
Availability of data and materials
The information generated and analyzed during the current
study is available from the corresponding author on reasonable
request.
Authors' contributions
Both authors (LH and RN) participated in the conception,
design and writing of the manuscript, and have read and
approved the nal version.
HARDELL and NYBERG: APPEALS ON THE DEPLOYMENT OF 5G
10
Ethics approval and consent to participate
Not applicable.
Patient consent for publication
Not applicable.
Competing interests
The authors declare that they have no competing interests.
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HARDELL and NYBERG: APPEALS ON THE DEPLOYMENT OF 5G
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