Classical homogenization theory based on the Hashin–Shtrikman coated ellipsoids is used to model the changes in the complex valued conductivity (or admittivity) of a lung during tidal breathing. Here, the lung is modeled as a two-phase composite material where the alveolar air-filling corresponds to the inclusion phase. The theory predicts a linear relationship between the real and the imaginary parts of the change in the complex valued conductivity of a lung during tidal breathing, and where the loss cotangent of the change is approximately the same as of the effective background conductivity and hence easy to estimate. The theory is illustrated with numerical examples based on realistic parameter values and frequency ranges used with electrical impedance tomography (EIT). The theory may be potentially useful for imaging and clinical evaluations in connection with lung EIT for respiratory management and control.