EMF Sensitive? You May Not Be the Outlier You Think You Are
Part 1. An intro to New Zealand regulatory frameworks; why your concerns are outside the framework; and how EMF radiation regulation came to differ so much from toxic chemicals regulation.
This Substack briefly describes New Zealand’s regulatory framework, who has responsibility for what in relation to radiofrequency electromagnetic fields (RF-EMF) radiation, and why current regulation of RF-EMF radiation is like it is.
If you suffer from a series of symptoms that you temporally associate with exposures from RF-EMF radiation, either from a single device, or from many devices, bad luck. Your condition is formally unrecognised in New Zealand and you have nowhere to go.
Yet the condition may be more common than formally recognised. Estimates of prevalence range from 5% (Japan[i] and Switzerland[ii]), 10% (Germany)[iii] to 13% (Taiwan)[iv]. Surveys of medical doctors reveal that they are commonly consulted by patients who consider that the symptoms they experience are associated with RF-EMF radiation (Slottje et al 2017[v]; Undas et al 2025[vi]).
A recent study reviewed nationally representative population-based data, collected via online surveys of adults [n=3,475 (United States 1,271; Australia 1,104; Canada 1,100). The study found that, across the general population, on average 12.6% reported wireless sensitivity and 10.0% reported medically diagnosed electromagnetic hypersensitivity (EHS) with 14.0% reporting either or both (14.3%, 18.9%, 8.7%). The study found that across all gender and age categories, males ages 25 to 34 reported the highest prevalence proportionally.[vii]
New Zealand has no dedicated public-sector RF-EMF health research programme, despite the rapid expansion of wireless infrastructure and cumulative exposure. If we exclude fibre infrastructure, New Zealand’s wireless and radio frequency-dependent telecommunications sector is likely worth roughly NZ$7–8 billion annually, centred on mobile networks, wireless broadband, tower infrastructure, and spectrum-based services.
The state instead relies heavily on offshore standards bodies and delegated scientific authority, while the economic and infrastructural importance of the telecommunications sector creates little institutional incentive to broaden the scope of risk assessment.
The science and research impasse reflects long-standing institutional approaches to RF-EMF governance. Globally, regulatory systems for RF-EMF emerged largely from telecommunications regulation, radiation protection, engineering standards, and spectrum management, rather than from the toxicological and environmental-health frameworks traditionally used to assess industrial pollutants and chemical exposures.
Yet the evidence that levels currently claimed by New Zealand ministries to be based on the ‘best available evidence’ and to be ‘safe’ is increasingly contradicted by a growing body of case reports, mechanistic studies, and debate within the scientific literature. These studies continue to raise questions about whether existing regulatory frameworks adequately address chronic, cumulative, developmental, or non-thermal biological effects, and why governments essentially delegate ‘the science’ to non-governmental organisations while continuing to lower regulations and standards, in the name of economic growth.
CASE STUDIES DOCUMENT ADVERSE EFFECTS AT ‘SAFE’ LEVELS
Case studies in the scientific literature are increasing in number, and electromagnetic hypersensitivity, also known as microwave syndrome, is a substantial and increasing field of research (however, not in New Zealand). Here are four examples:
Person (A) previously healthy, works on their laptop computer at home on wifi. He develops chronic headaches, dizziness and vertigo. Intermittent symptoms increase and become debilitating (e.g. Ashton 2025).[viii]
Person (B), previously healthy, experiences a continuous heavy headache during the week, pain in the chest, shortness of breath, cough, fatigue, dizziness, uncontrolled movements of the body, low blood pressure (e.g. 86/57 mmHg), palpitations with rapid heart rate (e.g. 140–145). She works on an upper floor, two base stations are located on the roof and a major antenna is located outside in close proximity to her workspace (Hardell & Koppel 2022).[ix]
Person (C) experiences strange pressure on the brain, burning head pain, fatigue, impaired concentration and memory, reduced motor function, insomnia, nausea, altered hearing sensitivity, and visual disturbance (Dieudonne 2019).
A family (D) goes on holiday. The parents experience sleeping problems, headache, tiredness, and a high pulse rate. The children got sleeping problems, diarrhea, pain in the stomach, skin rashes, headache, and emotional symptoms. The symptoms predominantly stop on returning home. (e.g. Nilsson & Hardell 2023)
All of these scenarios concern people who feel unwell when they are temporally located in the vicinity of site (or multiple sites) that emit radiofrequency electromagnetic fields (RF-EMF) radiation at levels that the Ministry of Health state are safe.
None of the examples involve recognised acute thermal injury or perceptible heating. New Zealand’s standards: NZS 2772.1 are regulatory limits are built around preventing established thermal effects. There are no direct thermal effects.
NEW ZEALAND: NO RESEARCH FIELD, NO REPORTING FRAMEWORK
More and more case studies document the adverse experiences by people, however, there is nowhere in the New Zealand public system that will recognise, document and report local adverse health effects.
If you experience headaches, dizziness, cognitive fatigue, insomnia, or other symptoms that you temporally associate with exposure to radiofrequency electromagnetic fields (RF-EMF), New Zealand’s public health system offers little formal recognition or investigative pathway. There is no dedicated surveillance programme, no national reporting framework for clinicians, and no funded public-sector research group focused on understanding possible long-term biological effects from chronic low-level RF-EMF exposure.
When an individual believes their symptoms are mediated by RF-EMF, they can report their problem to their doctor. The doctor will note it down on the patient’s private notes. It is placed in a section that does not feedback to any larger system. The doctor does not file a report. New Zealand does not appear to maintain a dedicated clinical reporting or surveillance framework for suspected RF-EMF-related health effects, leaving clinicians without a standardised pathway for case reporting, aggregation, or longitudinal monitoring.
The concerned individuals will likely search New Zealand universities and the scientific community to find scientists whose work involves understanding the risks from RF-EMF radiation. They will find that there are no research groups doing this work and no funding set aside for such work.
WHO CONTROLS NZ SAFETY LIMITS AND REGULATIONS?
MBIE administers telecommunications and radio-spectrum regulation through Radio Spectrum Management, while ministerial responsibility sits primarily with the Minister for Media and Communications; health aspects are handled separately through Health NZ and related advisory structures.
The Ministry for Business, Innovation and Employment (MBIE) administers the Resource Management (National Environmental Standards for Telecommunication Facilities) Regulations 2016. The NES-TF 2016 replaced the NES-TF 2008. This is when power was transferred from the Ministry for the Environment to MBIE.
The current telecommunications regulations continue on the basis that the regulation NZS 2772.1:1999 for radiofrequency fields is based on maximum exposure levels – 3 kHz to 300 GHz, and require facilities to be installed and operated in accordance with it (NES-TF 2016, section (6)).
While telecommunications industry actors may clearly understand MBIE’s regulatory role, most people may not appreciate this as MBIE’s role is not always transparent. For example, a May 2025 Ministry for the Environment (MftE) consultation included Part 2.5: National Environmental Standards for Telecommunication Facilities, proposals to lessen the 2016 regulations for outdoors telecommunications devices as ‘The current rules in the NES-TF are too restrictive and do not cover a range of low impact telecommunication facilities’.[x]
The proposal directly concerned regulations administered by MBIE. Therefore, although Chris Bishop was Minister responsible for RMA reform, for telecommunications regulation, the primary ministerial responsibility sits with the Minister for Media and Communications, Paul Goldsmith.
The proposal did not define ‘low-impact’. MBIE then took full responsibility for analysing the submission responses from the public and private sector to their part of the consultation (page 187).[xi] An earlier April 2025 Interim Regulatory Statement relating to the NES-TF regulations update had signalled that any concerns that current exposure standards were not sufficiently safe would be out of scope.[xii]
Under NES-TF, telecommunications providers need to comply with the New Zealand radio frequency exposure standard NZS 2772.1:1999 by reference, which is administered and reviewed by the Ministry of Health and Health New Zealand (Te Whatu Ora). The protections for radio frequency exposures will be maintained with no changes. The Ministry of Health and Health New Zealand advised that the references to NZS 2772.1:1999 align with international best practice and remain fit for purpose. (Pages 21-22)
WHO ASSESSES THE SAFETY OF RF-EMF?
Formal scientific reviews which follow a robust evidence gathering and risk assessment framework are not undertaken in New Zealand to assess the safety of RF-EMF. Such a framework does not exist.
The ‘core’ programme which purports to research RF-EMF, the Interagency Committee on the Health Effects of Non‑Ionising Fields, looks at papers on key research topics, and prepares summaries. The Committee meets every 6 months and releases a ‘Report to Ministers’ every couple of years (2015, 2018, 2022). The reviews which are published as Reports to Ministers are likely undertaken in a voluntary capacity or with short term funding. It is likely the funding is allocated under the Vote Health category of ‘regulatory and enforcement services’.
No robust scientific process is followed, and the key authors are not declared.
The Interagency Committee is not a group of expert New Zealand-based researchers and scientists whose work involves dedicated research into the human health risk of non-ionising radiation. The Committee is under-represented by experts in biological health and risk, and predominantly stacked with officials and industry representatives who are focussed on policy development, monitoring and regulatory standards.
Although the Ministry of Health is tasked with protecting public health, it does not fund any group or committee to undertake research and risk assessment of RF-EMF radiation. The authority of determining risk from non-ionising RF-EMF radiation is effectively proxied out to reflect the findings of offshore agencies.
MBIE controls telecommunications regulation - but holds national control of science policy and funding. Even as some $50 million is allocated to the regulation of telecommunications services under the Telecommunications Act 2001, although MBIE has discretion to allocate research funding for long-term research into the risk to human and environmental health from RF-EMF to investigate human and environmental health effects, no funding is allocated.
It’s remarkable that the regulator of a technology where claimed safe levels are disputed, would also control the scientific funding that could undertake research to shed light on human and environmental health risk, and then would fail to do so.
DELEGATED POWERS: ICNIRP LIMITS ARE THE BASELINE
New Zealand’s core public basic restrictions reflect the ICNIRP position, with whole-body average SAR of 0.08 W/kg and local head/torso SAR of 2 W/kg averaged over 10 g for 100 kHz to 6 GHz. These remain the limits that Health NZ still lists for NZS 2772.1:1999.
In 2022 the Interagency Committee recommended moving to limits based on ICNIRP 2020.[xiii] As of the current public guidance and legislation, NZ still points to NZS 2772.1:1999.
ICNIRP recommendations and restrictions remain built around dosimetry and established heating-related mechanisms rather than a new non-thermal regulatory mode.
Neither NZS 2772.1 nor ICNIRP 2020 are specifically designed around:
Children as a distinct exposure group. There are no separate limits for smaller body size developing tissues and childhood vulnerability. The assumption is that safety factors cover variability.
Cumulative, repeated exposures. Standards assess instantaneous or short-term dose, and not hours/day over years from multi-device environments.
Real-world usage patterns. Instead, phones are tested at defined positions and are not necessarily pressed against skin, or placed on the lap or in hip pockets for long periods or used in weak-signal conditions where there is higher power output.
The ICNIRP 2020 updates predominantly concern future high-frequency systems and edge-case exposure scenarios. Therefore concerns such as in the paragraph above are not addressed by the ICNIRP 2020 update.
RADIOFREQUENCY RADIATION, NON-IONISING & NON-THERMAL EFFECTS
The relationship between ionising vs non-ionising and thermal vs non-thermal is important, because they describe different dimensions of interaction.
Ionising vs non-ionising is about whether a single photon has enough energy to remove an electron (a quantum property).
Thermal vs non-thermal is about how energy is transferred to tissue at the macroscopic level (a bulk effect).
In the RF (radiofrequency) range, all exposures are non-ionising, the photon energy is far too low to break chemical bonds. However, RF can still produce thermal effects if enough energy is absorbed collectively, leading to tissue heating (this is the basis of current exposure limits such as SAR). In this sense, RF can be non-ionising but thermal.
Non-ionising does not imply non-thermal, and non-thermal does not imply non-interaction.
The term non-thermal effects refers to biological responses that occur without measurable heating, such as changes in signalling, oxidative stress markers, or membrane behaviour. These are not explained by bulk temperature rise. Importantly, non-thermal does not mean ‘no energy’, it means the energy is below the threshold that produces a detectable temperature increase, but may still interact with biological systems through other mechanisms.
In the electromagnetic spectrum, the distinction between non-ionising and ionising radiation is fundamentally a matter of photon energy, not the source or technology. Ionising radiation (upper ultraviolet, X-rays, gamma rays) carries sufficient energy per photon, typically on the order of ~10 electron volts (eV) or higher, to remove electrons from atoms and molecules, creating ions and directly disrupting chemical bonds. In contrast, non-ionising radiation, which includes radiofrequency (RF) electromagnetic fields used in telecommunications (radio, mobile phones, Wi-Fi, 5G), operates at much lower photon energies, many orders of magnitude below ionisation thresholds.
Its primary established interaction with biological tissue is through induced currents and dielectric heating, which is the basis for current exposure standards. Importantly, the boundary between non-ionising and ionising radiation is not a sharp line but a transition region within the ultraviolet range, and classification reflects dominant interaction mechanisms rather than an absolute biological divide.
In the context of RF-EMF, this means that exposures are categorised as non-ionising by physics, but this classification alone does not resolve questions about long-term, cumulative, or non-thermal biological effects, which remain areas of ongoing scientific investigation.
INCREASING DENSITY & CUMULATIVE EXPOSURE
The expansion of RF-emitting systems has been characterised by two parallel trends: increasing numbers of base stations (especially for 5G densification) and rapid growth in personal and machine-connected devices. Exposure patterns are becoming more complex, with device proximity often dominating individual exposure rather than distant towers.
Analyses confirm similar infrastructure expansion (especially 5G rollout), but the evidence base is largely limited to measurement and compliance studies, which consistently show exposures well below regulatory limits. There is little domestic work modelling cumulative or system-level exposure trends.
Cumulative exposure in RF-EMF (radiofrequency electromagnetic fields) is a neglected research field. People are no longer exposed to a single source in isolation (e.g. one cell tower), but to a constantly changing mixture of sources: phones held close to the body, Wi-Fi routers, nearby base stations, Bluetooth devices, and increasingly embedded sensors and infrastructure. Each source typically operates well below the prevailing regulatory limits, but in real life they overlap in time and space, with exposures varying by proximity, behaviour, and environment.
Most standards and measurements are designed around single-source, short-term exposures, whereas actual exposure is multi-source, intermittent, and cumulative over long periods. As new technologies are released, premarket safety testing does not occur.
HOW RF-EMF STEWARDSHIP DIFFERS FROM TRADITIONAL ENVIRONMENTAL REGULATION
RF-EMF governance grew out of radiation protection, physics, dosimetry, and standards compliance. RF-EMF is regulated more like a radiation-physics exposure compliance problem than a toxicological public-health risk problem. That is why the responsible bodies often both review the science and define the limits. It also explains why non-thermal, chronic, developmental, and cumulative-risk questions sit awkwardly inside the current framework.
The central question became: what external field strength or absorbed energy prevents established acute effects? For radiofrequency, the dominant regulatory endpoint remains tissue heating; ARPANSA states that excessive heating is the only established RF health effect and the Australian standard is built around that premise.
That history has informed the governance culture in 2026. The system is comfortable with measurement, modelling, exposure limits, compliance margins, and engineering controls. It is not structured around toxicology-style questions: low-dose chronic exposure, developmental vulnerability. This approach might explain why some of the prominent actors RF-EMF science in Australia and New Zealand tend to have physics backgrounds, rather than undergraduate degrees in biology, toxicology and health.
In contrast, institutions responsible for chemical regulation tend to have a stronger expectation of toxicological dossiers, dose-response reasoning, uncertainty factors, vulnerable populations, cumulative exposure, and periodic reassessment.
For chemicals and pollution, the standard risk-assessment paradigm revolves around hazard identification, dose–response assessment, exposure assessment and risk characterisation. That model focuses on biology, questioning - what does the agent do to organisms, at what dose, through what pathway, in whom, and with what uncertainty?
The US EPA describes human health risk assessment in exactly those four steps, and its pesticide programme explicitly begins with hazard identification/toxicology, then dose-response, exposure, and risk characterisation.
Under Europe’s REACH regulation, for example, companies must identify and manage risks for substances they place on the market, while ECHA operates a broader chemical evaluation and restriction architecture.
REFERENCES
[i] Hojo S, Tokiya M, Mizuki M et al. Development and evaluation of an electromagnetic hypersensitivity questionnaire for Japanese people. 2016. BioelectromagneticsVolume 37, Issue 6 pp. 353-372. https://doi.org/10.1002/bem.21987
[ii] Schreier, N., Huss, A. & Röösli, M. The prevalence of symptoms attributed to electromagnetic field exposure: a cross-sectional representative survey in Switzerland. Soz.-Präventivmed. 51, 202–209 (2006). https://doi.org/10.1007/s00038-006-5061-2
[iii] Blettner M, Schlehofer B, Breckenkamp J, Kowall B, Schmiedel S, Reis U, Potthoff P, Schüz J, Berg-Beckhoff G. Mobile phone base stations and adverse health effects: phase 1 of a population-based, cross-sectional study in Germany. Occup Environ Med. 2009 Feb;66(2):118-23. doi: 10.1136/oem.2007.037721.
[iv] Tseng, MCM, Yi-Ping Lin, YP, Cheng, TJ. Prevalence and psychiatric comorbidity of self-reported electromagnetic field sensitivity in Taiwan: a population-based study. J Formos Med Assoc 2011;110:634–41. https://doi.org/10.1016/j.jfma.2011.08.005.
[v] Slottje P, van Moorselaar I, van Strien R et al. Electromagnetic hypersensitivity (EHS) in occupational and primary health care: A nation-wide survey among general practitioners, occupational physicians and hygienists in the Netherlands. International Journal of Hygiene and Environmental Health. 220(2) Part B, April 2017, Pages 395-400, https://doi.org/10.1016/j.ijheh.2016.11.013
[vi] K. Undas, G. Kanclerz, J. Popielak and G. Tatoń, “Experience of Polish Physicians on Electromagnetic Hypersensitivity,” 2025 Progress in Applied Electrical Engineering (PAEE), Koscielisko, Poland, 2025, pp. 1-4, doi: 10.1109/PAEE68231.2025.11155985.
[vii] McCredden JE, McLean L, Steinemann A. Wireless sensitivity and co-morbidities: A prevalence study in Australia, Canada, and the United States. Next Research 8:101577, https://doi.org/10.1016/j.nexres.2026.101577
[viii] Ashton D (2025) Self-diagnosing electromagnetic hypersensitivity. A case study. Front. Public Health 13:1535513. doi: 10.3389/fpubh.2025.1535513
[ix] Hardell L & Koppel T. Electromagnetic hypersensitivity close to mobile phone base stations – a case study in Stockholm, Sweden. Reviews on Environmental Health, vol. 38, no. 2, 2023, pp. 219-228. https://doi.org/10.1515/reveh-2021-0169
[x] Ministry for the Environment. May 2025. Package 1: Infrastructure and development – Discussion document. Part 2.5: National Environmental Standards for Telecommunication Facilities. Wellington: Ministry for the Environment.
[xi] Ministry for the Environment. 2026. National Environmental Standards for Electricity Transmission Activities and National Environmental Standards for Telecommunication Facilities: Report on Recommendations and Decisions. Wellington: Ministry for the Environment. https://environment.govt.nz/assets/publications/NES-ETA-and-NES-TF-Report-on-recommendations-and-decisions.pdf
[xii] Interim Regulatory Impact Statement: Amendments to the Resource Management (National Environmental Standards for Telecommunication Facilities) Regulations 2016. Section 47, pages 21-22. https://www.regulation.govt.nz/assets/RIS-Documents/Interim-Regulatory-Impact-Statement-Amendments-to-the-National-Environmental-Standards-for-Telecommunication-Facilities-2016.pdf
[xiii] ICNIRP 2020. ICNIRP GUIDELINES FOR LIMITING EXPOSURE TO ELECTROMAGNETIC FIELDS (100 KHZ TO 300 GHZ) PUBLISHED IN: HEALTH PHYS 118(5): 483–524; 2020. https://www.icnirp.org/cms/upload/publications/ICNIRPrfgdl2020.pdf
