RRT Response to UK Government Smart Metering Consultation

The EM Radiation Research Trust (RRT) has made its consultation response public, raising serious concerns about the rollout of wireless smart meters. The letter stresses risks to health, children’s rights, and consumer choice, calling for precautionary safeguards, fibre-first solutions, and guaranteed opt-outs to protect vulnerable populations.

Here is our report – Full Consultation Submission from the EM Radiation Research Trust

23rd September 2025

To: [email protected]

Cc: Brian Stein CBE, Chairman, EM Radiation Research Trust

Subject: Response to Smart Metering Policy Framework Post-2025 – Consultation Document

Attention: UK Government Energy Security

Publicly available submission highlighting health, safety, and consumer choice concerns regarding wireless smart meters

The EM Radiation Research Trust (RRT) welcomes the opportunity to contribute to the 2025 consultation on the Smart Metering Policy Framework. While the Government states its aim to improve energy efficiency, serious concerns remain that widespread wireless smart meter installation is proceeding without adequate safeguards for health, safety, or informed consent. This open letter highlights these concerns and provides recommendations to ensure the post-2025 framework genuinely prioritises public health, consumer protection, and meaningful choice.

Public Access to Consultation

Members of the public can access and submit information to the Government consultation here:
https://www.gov.uk/government/consultations/smart-metering-policy-framework-post-2025/smart-metering-policy-framework-post-2025-consultation-document#executive-summary

Deadline for Responses: 11:59 pm on 3 October 2025

Our Principal Concerns

• Health impacts and Electromagnetic Hypersensitivity (EHS): UK legal and welfare precedent recognises EHS as disabling and requiring formal accommodation. See: https://phiremedical.org/news/
• Children’s rights and cumulative exposure: Current exposure limits are outdated and fail to protect children from involuntary, continuous RF exposure. See: https://www.thechildrensdeclaration.org/the-declaration
• Non-thermal and cumulative RF exposure: Independent studies show biological effects at levels far below ICNIRP thermal thresholds. See: https://bioinitiative.org/
• Fire and electrical hazards: Faulty or poorly installed meters have led to serious safety incidents. See: https://radiationresearch.org/5g-phone-mast-fire-london-8th-november-2024/
• Consumer rights and consent: Lack of opt-outs and cost-free wired alternatives risks breaching rights to informed choice and equality of access.
• Data security and privacy: Detailed energy usage data must be safeguarded against misuse, hacking, or unauthorised sharing.

This submission integrates the latest independent scientific evidence, legal precedent, and ethical considerations to recommend precautionary safeguards before further rollout. We support analogue meters, a fibre-first approach, evidence-based public health policy, and robust consumer choice.

1. Primary Objection – Ignoring Up-to-Date Independent Evidence

The consultation does not address the implications of the recent WHO/IARC-commissioned systematic review of RF exposure and cancer in laboratory animals (Mevissen et al., 2025). This high-quality review, undertaken within the WHO/IARC Environmental Health Criteria process, strengthens evidence that RF exposure produces carcinogenic effects in animals.

It reinforces the existing IARC classification of RF electromagnetic fields as Group 2B, “possibly carcinogenic to humans,” highlighting that the risks of non-thermal and cumulative exposures are real and scientifically recognised, with some independent doctors and scientists advocating that the WHO/IARC classification be upgraded to Group 1, “carcinogenic to humans.”

Policy decisions, including a 2030 completion target, must explicitly recognise this WHO/IARC evidence and apply the precautionary principle. See: https://pubmed.ncbi.nlm.nih.gov/40339346/

2. ICNIRP Compliance Alone is Insufficient

The consultation repeatedly implies that ICNIRP compliance and operator assurances are adequate to protect the public. This is scientifically and legally flawed:

• ICNIRP guidance only addresses short-term thermal effects and does not account for non-thermal, pulsed, cumulative, or peak exposures linked to biological effects.
• Independent analysis highlights unscientific bias and significant gaps. Professor Tom Butler (2022) references Hardell and Carlberg, who note:
  “There were missed opportunities for cancer prevention exemplified by asbestos, tobacco, certain pesticides and now RF radiation. No doubt economic considerations are favoured instead of cancer prevention. The cancer victim is the loser in terms of suffering, life quality and shorter life expectancy. Also, the life for the next-of-kin is affected. A strategy to sow doubt on cancer risks was established decades ago and is now adopted and implemented in a more sophisticated way by the telecom industry regarding RF-EMF risks to human beings and the environment. Industry has the economic power, access to politicians and media whereas concerned people are unheard.”

This directly aligns with the WHO/IARC Group 2B classification of RF-EMF as “possibly carcinogenic to humans,” showing that independent experts view RF radiation as a credible cancer risk. Relying solely on ICNIRP thermal limits ignores the non-thermal, biologically active effects and fails to apply the precautionary principle. See: https://ec.europa.eu/health/scientific_committees/scheer/docs/emf2022/Butler_Submission.pdf

Legal Precedent:

• Thomas v Cheltenham (Court of Appeal, 2025) confirms that ICNIRP compliance alone does not dismiss legitimate health objections. Operators and regulators cannot assume immunity from legal scrutiny based on ICNIRP limits. See: https://havewegotplanningnewsforyou.com/wp-content/uploads/2025/03/THOMAS-AND-CHELTENHAM-COURT-OF-APPEAL.pdf
• Education Health Care Plan (EHCP) Awarded for Electromagnetic Hypersensitivity (EHS) (Aug 2022): A UK child was granted an EHCP recognising EHS as a disabling condition requiring formal educational support.
• Early Ill-Health Retirement and Employment Support Allowance Awarded on the basis of EHS (Aug 2022): A 59-year-old social worker was awarded early retirement and state support due to disabling EHS, demonstrating recognition of EHS within the UK’s welfare and occupational health frameworks. See: https://phiremedical.org/news/

These cases, taken together, show that EHS is formally recognised in UK legal, educational, and welfare systems, requiring reasonable accommodation.

3. Protect Vulnerable Populations

The consultation lacks measures for children, hospital patients, AIMD users, electrosensitive individuals, and other vulnerable groups. ICNIRP explicitly excludes AIMD users from its “public” exposure assumptions.

For electrosensitive people, the lack of recognition in the framework is unacceptable. Recent UK welfare and legal determinations establish that:

• ICNIRP compliance does not override public health concerns (Thomas v Cheltenham, 2025).
• EHS is recognised as disabling in both education (EHCP, 2022) and employment/welfare law (Ill-Health Retirement, 2022).
• Authorities risk legal challenge if they fail to accommodate these groups.

Children’s Declaration on NIR Exposure (2023):
International experts and child advocates have warned that current exposure limits are outdated, based on decades-old thermal assumptions, and fail to protect children from cumulative and synergistic harms. The Declaration highlights:

• Acute effects: headaches, dizziness, nausea, insomnia, lack of concentration, brain fog
• Chronic risks: DNA damage, cancer, neurological impacts
• Continuous, cumulative exposure in homes, schools, and public spaces (including from smart meters)
• Lack of monitoring of actual exposure levels or impacts on children
• Misleading “safe exposure” claims from bodies such as ICNIRP

See: https://www.thechildrensdeclaration.org/the-declaration

The Declaration also warns of commercial exploitation of children’s data via digital and AI-driven technologies, raising profound ethical issues alongside health concerns.

Policy Implication:
The smart metering framework must explicitly provide:

• Statutory opt-outs and non-wireless alternatives for vulnerable individuals
• Independent monitoring of cumulative exposures in schools, hospitals, and homes
• Safeguards aligned with children’s rights under UNCRC Articles 3, 17, 23, and 24

4. Fire and Electrical Safety

Recent UK product safety action (EDMI Atlas Mk7CD recall, March 2025) shows that smart meters can present real fire and electrical-shock risks. Any policy that accelerates replacement before 2033 must include independent fire-safety audits, reporting, and a clear recall/mitigation process.

See: https://www.gov.uk/product-safety-alerts-reports-recalls/product-recall-edmi-atlas-mk7cd-electricity-smart-meters-2502-0134

5. Fibre-First & Opt-Out

Technology neutrality must prioritise wired analogue solutions. Wireless options should only be used where independent scientific evidence confirms biological safety. Consumers must be able to opt-out of wireless smart meters without penalty, with cost-free wired alternatives.

6. Monitoring, Transparency, and Enforcement

Annual deployment plans must include publicly available data on:

• Independent certification of electrical/fire safety
• Adverse events and health complaints
• Verified operator data on emitted power and beam direction

Operators must not rely on opaque self-certification from third-party contractors.

7. Specific Recommendations

• Independent Health Review: Secretary of State to publish a plan showing how Mevissen et al. (2025) WHO/IARC Environmental Health Criteria are assessed and integrated
• Fibre-First Requirement: Suppliers must justify wireless deployment, preferring wired/analogue meters
• Opt-Out & Alternatives: Guarantee no-cost, no-penalty alternatives for those declining RF meters
• Fire-Safety Audits & Recall Handling: Mandatory independent inspections, reporting, and consumer remediation, including compensation for damage to property or injury to life
• Monitoring & Transparency: Public logs of meter models, emissions, firmware, adverse events, and operator data for local verification

8. Outstanding Questions

• How will WHO/IARC 2025 evidence be integrated into guidance and licence conditions?
• What statutory safeguards guarantee opt-outs without penalty?
• How will independent fire/electrical audits and recalls be enforced?
• How will health concerns, including AIMD and EHS claims, be assessed?

9. Conclusion

This open letter is made publicly available to ensure transparency and inform citizens of the health, safety, and legal considerations associated with the post-2025 smart metering framework.

The RRT supports a safe, effective, and consumer-respecting smart metering programme. The current framework underweights peer-reviewed science, legal developments, hardware safety failures, and the rights of vulnerable populations. Before enforcing tighter rollout obligations or raising completion targets, the Department must:

• Adopt precautionary policy changes
• Require independent certification that wireless deployments adhere to biologically safe limits defined by independent research, not just ICNIRP thermal thresholds
• Guarantee consumer choice
• Prioritise fibre-first/analogue solutions

Key Supporting Sources:

RRT letters to the Department of Energy Security and Net Zero:

FOI and Government responses:

Legal & Ethical Governance Considerations:
Consultation must comply with the Gunning Principles (R v Brent London Borough Council, 1985): formative stage, sufficient information, adequate time, and conscientious consideration. Failure risks procedural challenge.

Respectfully submitted on behalf of EM Radiation Research Trust

Eileen O’Connor
Director, EM Radiation Research Trust

Website: www.radiationresearch.org

Address: Chairman Mr. Brian Stein CBE, Radiation Research Trust, Chetwode House, Leicester Road, Melton

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