It passed the initial tests. I believe between then and 2023 Apple introduced a signal boosting feature (I need to verify that). Then in 2023, France’s Agence Nationale des Fréquences (ANFR) said Apple must stop or suspend sales of the iPhone 12 because their testing found that, when held against the body (0 mm distance, or "limb-SAR"), the device registered a SAR of 5.74 W/kg, exceeding the EU limit of 4 W/kg. Although the iPhone 12 passed other SAR tests (e.g., at 5 mm distance from the body), the “limb” test failure was enough to prompt regulatory action in France. This testing method is not something most other countries use, by the way.
What Apple does is have an “off-body detection” feature, which allows increased radio power when the device is stationary (e.g., on a table). The problem is that how ANFR tests, the phone senses that it's not being held close to a body and keeps the boosted signal. This means that ANFR’s test conditions did not reflect real world conditions (which isn't uncommon for many test conditions by agencies and companies). In other words, France’s protocol doesn’t permit that power boost (which helps with cell signal). It requires that transmit power stay within limb‑SAR limits even when off-body.
An analogy might be like this. France sets a country-wide limit on all speakers to never play louder than 55 dB (anything <70 should be completely safe for continuous, lifelong exposure). If someone is 30 meters away, the speaker has to be no louder than 55 dB. If someone has their ear on the speaker -- no louder than 55 dB.
That's essentially what ANFR is requiring with cell phone (non-ionizing) radiation -- a set completely safe level regardless of distance. Apple is objecting to that method but following the regulation; there was only so much Apple could do so it disabled that boosting feature in France. Now they are disabling it in the EU to keep things simpler.
A note about cell phones and health risks. The idea behind these tests and regulations is a possible link with brain cancer and potentially other health risks. However, even with the "failed" levels, we know the device’s elevated output remains well below levels associated with potential health harm. One of the claims that has poppoed up over the years is that cell phone use is associated with brain cancers. There have been some peer reviewed publications showing this but the bulk of published research and the best research shows no link. Even more, over the past 25 years there's been a huge increase in cell phone use but no clear increase in brain cancers:
https://www.sciencedirect.com/science/article/pii/S0160412024005695