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There is increasing demand for minimally invasive and non-surgical treatment methods for patients with small breast cancer. Radiofrequency (RF) ablation is the most promising among several non-surgical ablation techniques in the treatment of breast cancer. Several pilot studies of RF ablation therapy are currently in progress in Japan as well as USA. However, non-surgical ablation techniques still have a number of problems with regard to (a) inability to precisely determine tumor size, (b) determination of 100% tumor cell killing, (c) ability to follow local recurrence, and (d) cosmetic outcome. To achieve wide acceptance, non-surgical ablation techniques must achieve results equivalent to those of conventional breast conserving treatment (BCT) in local control and survival. This paper reviews and discusses the practical applicability and relevance of RF ablation treatment for small breast cancer.