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France bans iPhone 12 after finding radiation levels are too high
(www.techspot.com)
This is a most excellent place for technology news and articles.
Source: https://download.tomtom.com/open/manuals/new_GO/html/en-gb/SpecificAbsorptionRate(SAR)compliance-EU.htm
Last modified: 3/3/2016 3:06:39 PM
So, looks like its just two different requirements that have been around since at least 2016 when tomtom posted that. Its low enough to not exceed the body limit when being held away from the body, but not the limit for extremities when being held or body when in pocket.