The SMS standard specifies UCS-2 encoding:
http://www.3gpp.org/ftp/Specs/html-info/23038.htm

I see many “emoji” have been defined in Unicode 6. But many emoji are outside 
the BMP, so can’t be encoded in UCS-2. Does anyone know, is the intention that 
these emoji should be encoded in SMS using UTF-16 rather than UCS-2? Are there 
any plans in-progress to update the SMS standards to specify UTF-16 rather than 
UCS-2?

Perhaps this question could be added to the Emoji FAQ. 
http://unicode.org/faq/emoji_dingbats.html

Regards,
Craig McQueen

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