Written evidence submitted by EM Radiation Research Trust (HAR1953)

Dear Chair Dame Bradley and Members of the Home Affairs Select Committee,

I am writing on behalf of the UK EM Radiation Research Trust (RRT) in response to the UK Government’s call for evidence on the proposed digital ID system (“BritCard”). The EMRRT is a UK-based public charity focused on risks associated with electromagnetic fields (EMFs), particularly for vulnerable populations, including users of Active Implantable Medical Devices (AIMDs), individuals with electromagnetic hypersensitivity (EHS), and immune-compromised individuals.

The EM Radiation Research Trust (RRT) strongly opposes the introduction of a mandatory digital ID system. Our opposition is based on serious concerns regarding individual privacy, data security, and public health. The infrastructure required to support digital ID systems would likely increase exposure to radiofrequency (RF) radiation, raising potential health risks that must be carefully considered.

Mandatory digital ID systems present significant risks to individual privacy and civil liberties. Centralising personal data increases the potential for misuse, hacking, and unauthorised surveillance. These risks are compounded when digital ID is linked to mobile or wireless technologies, which may expose individuals to additional RF emissions.

We provide this submission to share evidence and scientific literature relevant to potential health, equality, and legal considerations associated with digital ID infrastructure that involves electronic devices emitting EMFs. This submission is intended for informational purposes and does not constitute policy advocacy by the RRT.

Health and Vulnerability Considerations Digital ID systems typically require interaction with electronic devices, which may emit EMFs. Evidence from peer-reviewed research and international health bodies indicates:

1. Active Implantable Medical Devices (AIMDs):
• EMF exposure can interfere with devices such as pacemakers and cochlear implants.
• ICNIRP 2020 guidelines explicitly exclude AIMD users from protection, meaning standard compliance testing may not address this vulnerability. (Lin, J.C., Frontiers in Public Health, 2025)

2. Electromagnetic Hypersensitivity (EHS):
• EMF exposure is reported to cause ill health in some individuals
• Legal cases in the UK have increasingly recognised EHS as a condition requiring reasonable accommodation.

3. General Population and Children:
• The UK Department of Health (2005) recommends children use mobile phones only for essential purposes, keeping calls short, reflecting a precautionary approach to EMF exposure. (Department of Health, “Mobile Phones and Base Stations: The Facts”, 2005)

4. Carcinogenic Potential:
• The WHO/IARC 2025 systematic review of animal studies reports evidence of carcinogenic effects of radiofrequency (RF) radiation in laboratory animals. RF radiation remains classified by IARC as a Group 2B possible human carcinogen, though some researchers continue to advocate for reassessment and some scientists advocate for Group 1 reclassification. (Environmental Research, 2025)

5. Other EMF Effects:
• Non-thermal effects, such as microwave hearing, remain under-assessed in current compliance testing.
• Council Recommendation 1999/519/EC sets a 2 mJ/kg limit for auditory disruption, though it is rarely applied.

Legal and Equality Considerations Evidence from UK case law and legislation indicates that public authorities must consider health-based vulnerabilities when implementing policies that affect access to services:

• Equality Act 2010, Section 149: Requires due regard to eliminating discrimination and advancing equality for people with protected characteristics, including disabilities arising from AIMDs or EMF sensitivity.
• Steven Thomas v Cheltenham Borough Council ([2025] EWCA Civ 259): The Court of Appeal confirmed that credible health concerns relating to EMF exposure cannot be dismissed solely on the basis of ICNIRP compliance.
• Yasmin Skelt v First Secretary of State (2003): ICNIRP certification cannot automatically override public health objections.
• Recognition of EHS in legal contexts supports the requirement to accommodate individuals with EMF sensitivities.

These sources provide evidence of legal obligations for public authorities to consider the potential impact of EMF exposure when introducing technology-dependent infrastructure.

Observations Relevant to Digital ID Deployment Based on the evidence presented above, potential considerations for digital ID infrastructure include:

• The possibility of interference with AIMDs.
• Disabling effects for individuals with EHS.
• Potential carcinogenic risk associated with RF exposure.
• Requirement to ensure equality of access and reasonable accommodations.

This evidence suggests that careful assessment of infrastructure design, exposure mitigation, and alternative access options is warranted to comply with health, equality, and legal standards.

The EM Radiation Research Trust opposes the introduction of mandatory digital ID, based on both public health and civil liberties grounds. Policymakers should prioritise safety, privacy, and transparency before implementing any system that increases RF exposure or centralises personal data.

References

1. WHO/IARC. (2025). Systematic Review of Radiofrequency Radiation in Laboratory Animals. Environmental Research, 2025.
2. Lin, J.C. (2025). ICNIRP Limits and Public Health: A Critical Review. Frontiers in Public Health.
3. Department of Health. (2005). Mobile Phones and Base Stations: The Facts. GOV.UK.
4. Council of the European Union. (1999). Council Recommendation 1999/519/EC on EMF Exposure.
5. Steven Thomas v Cheltenham Borough Council ([2025] EWCA Civ 259).
6. Yasmin Skelt v First Secretary of State (2003).

Note: This submission presents scientific and legal evidence relevant to the potential impacts of digital ID systems.

Yours sincerely,

Aug 2025