Currently, standards for the compliance testing of wireless devices are being extended to cover a wider frequency band and different usage patterns of mobile phones as well as of novel body-worn and handheld devices. As a consequence, not only the head but also strongly varying tissue distributions of the body are exposed to electromagnetic radiation. Several authors have reported changes in the SAR absorption of body tissue due to the presence of a low permittivity fat layer. This paper identifies two different effects which can lead to increased SAR in layered tissue in comparison to the SAR assessed using homogeneous tissue simulating liquid: (1) for larger distances between the tissue and the antenna, standing wave effects occur depending on the frequency and fat layer thickness. (2) In the very close near-field (distances approximately lambda/40), reactive E-field components lead to high local absorption in the skin. The latter effect occurs at lower frequencies and depends on the antenna type. Modification of the parameters of the homogeneous liquids cannot compensate for these effects. However, a conservative exposure estimate can be obtained by applying a multiplication factor between 1 and 3 to the values assessed using current experimental dosimetric techniques.