K Number
K081796

Validate with FDA (Live)

Date Cleared
2009-01-23

(212 days)

Product Code
Regulation Number
862.1345
Reference & Predicate Devices
Predicate For
N/A
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

The EasyPlus mini R2N Self Monitoring Blood Glucose Test System is intended for the quantitative measurement of glucose in fresh capillary whole blood samples drawn from the fingertips or forearm. Testing is done outside the body (In Vitro diagnostic use). It is indicated for use at home (over the counter [OTC]) by persons with diabetes, or in clinical settings by healthcare professionals, as an aid to monitor the effectiveness of diabetes control.

The EasyPlus mini R2N Meter is intended for the quantitative measurement of glucose in fresh capillary whole blood samples drawn from the fingertips or forearm. EasyPlus mini R2N Blood Glucose Test Strips must be used with the EasyPlus mini R2N Meter. Testing is done outside the body (In Vitro diagnostic use). It is indicated for use at home (over the counter [OTC]) by persons with diabetes, or in clinical settings by healthcare professionals, as an aid to monitor the effectiveness of diabetes control.

The EasyPlus mini R2N Blood Glucose Test Strips, are intended for the quantitative measurement of glucose in fresh capillary whole blood samples drawn from the fingertips or forearm. EasyPlus mini R2N Blood Glucose Test Strips must be used with the EasyPlus mini R2N Blood Glucose Meter. Testing is done outside the body (In Vitro diagnostic use). They are indicated for use at home (over the counter [OTC]) by persons with diabetes, or in clinical settings by healthcare professionals, as an aid to monitor the effectiveness of diabetes control.

The EasyPlus mini R2N Glucose Normal/High Control Solution For use with the EasyPlus mini R2N meter and EasyPlus mini R2N Blood Glucose Test Strips as a quality control check to verify the accuracy of blood glucose test results.

Special conditions for use statement(s):
For Over-the-Counter use. Not for use with newborns.

Alternate site testing (AST) can only be used during steady-state blood glucose conditions. AST (forearm) should only be performed under the following conditions:
Testing before a meal
In a fasting state
Two hours or more after a meal
Two hours or more after insulin dosing
Two hours after physical activity

Special instrument requirements:
EasyPlus mini R2N Blood Glucose Meter

Device Description

The EasyPlus mini R2N Self-Monitoring Blood Glucose System consists of the EasyPlus mini R2N Blood Glucose Meter, EasyPlus mini R2N Glucose Test Strips, Auto-Lancet Device, Check Strip and Control Solution (Please refer to the IFU for the product picture).

AI/ML Overview

Here's a breakdown of the acceptance criteria and study details for the EasyPlus mini R2N Self Monitoring Glucose Test System, based on the provided 510(k) summary:

1. Table of Acceptance Criteria and Reported Device Performance:

The primary acceptance criteria are based on ISO 15197:2003 for In Vitro Diagnostic Test Systems — Requirements for Blood Glucose Monitoring Test Systems for Self-Managing Diabetes Mellitus. This standard specifies acceptable limits for accuracy when comparing the device's readings to a reference method (YSI 2300D analyzer).

Acceptance Criteria (ISO 15197)Reported Device Performance (EasyPlus mini R2N)
95% of individual glucose results falling within ±15 mg/dL of the reference method for glucose concentrations <75 mg/dL8/8 (100.0%) of individual glucose results fell within ±15 mg/dL. (Also 7/8 (87.5%) within ±5mg/dL and 7/8 (87.5%) within ±10mg/dL).
95% of individual glucose results falling within ±20% of the reference method for glucose concentrations ≥75 mg/dL151/157 (96.18%) of individual glucose results fell within ±20%. (Also 56/157 (35.67%) within ±5%, 103/157 (65.61%) within ±10%, and 138/157 (87.90%) within ±15%).
Hematocrit Interference: Bias ≤15 mg/dL when glucose concentration ≤75 mg/dL and bias ≤ 15% when glucose concentration > 75 mg/dLMax bias for 20-60% hematocrit range generally falls within these limits. (E.g., Lot 012072901: -1.18% to -4.61% for 20-50% Hct, -0.47% for 60% Hct. Lot 012072701: -0.45% to -3.97% for 20-50% Hct, -0.59% for 60% Hct. Note: 0% and 70% hematocrit show higher biases but are outside the claimed range.)

2. Sample Size Used for the Test Set and Data Provenance:

  • Sample Size (Clinical/Method Comparison): 165 total samples (156 diabetes patients + 9 spiked/glycolyzed samples) were used for the accuracy/method comparison studies across 3 sites.
  • Data Provenance: The document implies the study was conducted in Taiwan, R.O.C. (submitter's address). The study appears to be prospective, as it involved participants performing finger-stick and forearm blood draws for testing.

3. Number of Experts Used to Establish Ground Truth for the Test Set and Qualifications:

  • The ground truth for the test set was established using a YSI 2300D analyzer. This is a laboratory reference method, implying that the "experts" are the lab technicians operating and validating the YSI instrument, rather than medical experts interpreting images or clinical data. Their qualification would be in operating and calibrating such laboratory equipment. The document states: "Calibrate YSI 2300D analyzer before its use and the calibrators are manufactured gravimetrically and provided from the instrument supplier. Execute the validation of YSI 2300D analyzer by using this international standard reference material (NIST 965a) every year."

4. Adjudication Method for the Test Set:

  • None specified in the traditional sense of expert adjudication for diagnostic opinions. The "ground truth" is a quantitative measurement from a reference laboratory instrument (YSI 2300D). Discrepancies would be handled through statistical comparison rather than an adjudication process between experts.

5. If a Multi-Reader Multi-Case (MRMC) Comparative Effectiveness Study was Done, What Was the Effect Size?

  • No, an MRMC comparative effectiveness study was not done. This device is a blood glucose meter, not an imaging device or a system requiring human interpretation of complex data. The study compares the device's measurements to a reference instrument and examines performance by lay users vs. professionals.
  • However, the study did compare professional vs. lay users for various sample collection sites. For example:
    • Finger vs YSI: Lay users (Y=1.0307X-2.8876, R2=0.9471) vs. Professionals (Y=1.0470X-3.9092, R2=0.9540).
    • Forearm vs Finger: Lay users (Y=0.9410X+15.266, R2=0.9163) vs. Professionals (Y=0.9144X+16.121, R2=0.9448).
    • While not an MRMC study in the imaging sense, these comparisons explore the effectiveness of the device with different types of users. There isn't an "effect size of how much human readers improve with AI vs without AI assistance" as it's not an AI-assisted interpretation task.

6. If a Standalone Study (Algorithm Only Without Human-in-the-Loop Performance) Was Done:

  • Yes, a standalone study was done. The core performance evaluation (accuracy against YSI) directly assesses the device's (meter + strip) ability to measure glucose concentrations accurately. While human users collect the sample and operate the device, the "performance" itself relates to the analytical output of the system compared to the reference.
  • The "Within-run" and "Day-to-Day Precision" studies, "Linearity/assay reportable range," "Traceability," and "Detection limit" are all analytical performance studies of the device itself (standalone).

7. The Type of Ground Truth Used:

  • Expert Reference Method: The ground truth for the clinical accuracy studies (method comparison) was obtained using a YSI 2300D analyzer, which is a laboratory-grade glucose reference method.
  • For the precision and linearity studies, the ground truth was venous blood samples with glucose added to achieve specific target concentrations, implying a gravimetrically prepared or precisely measured reference.

8. The Sample Size for the Training Set:

  • The document describes performance studies, not the development or training of an AI algorithm. Therefore, there is no "training set" in the context of machine learning provided in this 510(k) summary. The device is an electrochemical biosensor, not an AI/ML-based diagnostic.

9. How the Ground Truth for the Training Set Was Established:

  • As there is no AI/ML training set, this question is not applicable.

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K0M7296

JAN 2 3 2009

EasyPlus mini R2N Self Monitoring Glucose Test System 510(k) SUMMARY

A Submitter's information

Company EPS Bio Technology Corp Address 2F, No 49-2, Lane 2, Guang Fu Rd , Sec 2 Hsinchu City, Tawan, R O C Contact Name Mr Y C Leı, General Manager 886-3-5752522 Phone Fax 886-3-5752552

B Measured

Glucose

  • C Type of Test Quantitative, electrochemical brosensor
  • D Proprietary and Established Names EasyPlus mını R2N Self-Monitoring Blood Glucose Test System

E Common or Usual Name Glucose Test System

ட Regulatory Information

  • Regulation section ﮩ 21 CFR 862 1345, Glucose Test System 21 CFR 862 1660, Quality control materials (assayed and unassayed)
  • 2 Classification Class II Class I, reserved

ന Product code

NBW, System Test, Blood Glucose, Over the Counter CGA, Glucose Oxidase, Glucose JJX, Single (Specified) Controls (assayed and Unassayed)

  • 4 Panel Chemistry 75

G Intended Use

  • 1 Intended use(s) See Indications for Use below
  • ଧ Indication(s) for use

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The EasvPlus mını R2N Self Monitorınq Blood Glucose Test System The EasyPlus mını R2N Self Monitoring Blood Glucose Test System is intended for the quantitative measurement of glucose in fresh capillary whole blood samples drawn from the fingertips or forearm Testing is done outside the body (In Vitro diagnostic use) It is indicated for use at home (over the counter [OTC]) by persons with diabetes, or in clinical settings by healthcare professionals, as an aid to monitor the effectiveness of diabetes control

The EasyPlus mini R2N Meter

The EasyPlus mini R2N Meter is intended for the quantitative measurement of glucose in fresh capillary whole blood samples drawn from the fingertips or forearm EasyPlus mini R2N Blood Glucose Test Strips must be used with the EasyPlus mומו R2N Meter Testing is done outside the body (In Vitro diagnostic use) It is indicated for use at home (over the counter [OTC]) by persons with drabetes, or in clinical settings by healthcare professionals, as an and to monitor the effectiveness of diabetes control

The EasyPlus mini R2N Blood Glucose Test Strips

The EasyPlus min: R2N Blood Glucose Test Strips , are intended for the quantitative measurement of glucose in fresh capillary whole blood samples drawn from the fingertips or forearm EasyPlus mini R2N Blood Glucose Test Strips must be used with the EasyPlus mini R2N Blood Glucose Meter Testing is done outside the body (In Vitro diagnostic use) They are indicated for use at home (over the counter [OTC]) by persons with diabetes, or in clinical settings by healthcare professionals, as an aid to monitor the effectiveness of diabetes control

The EasyPlus mını R2N Glucose Normal/High Control Solution

For use with the EasyPlus mını R2N meter and EasyPlus mını R2N Blood Glucose Test Strips as a quality control check to verify the accuracy of blood glucose test results

  • Special conditions for use statement(s) က
    For Over-the-Counter use Not for use with newborns

Alternate site testing (AST) can only be used during steady-state blood glucose conditions AST (forearm) should only be performed under the following conditions

  • Testing before a meal
  • ♦ In a fasting state
  • · Two hours or more after a meal
  • ← Two hours or more after insulın dosing
  • ♦ Two hours after physical activity

Special instrument requirements ব

EasyPlus mını R2N Blood Glucose Meter

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H Device Description

The EasyPlus min: R2N Self-Monitoring Blood Glucose System consists of the EasyPlus mını R2N Blood Glucose Meter, EasyPlus mını R2N Glucose Test Strips, Auto-Lancet Device, Check Strip and Control Solution (Please refer to the IFU for the product picture)

l Substantial Equivalence Information

  • 1 Predicate device name(s) EasyPlus Self-Monitoring Blood Glucose System
  • 2 Device Company EPS Bio Technology Corporation
  • ന Predicate 510(k) number(s) K061992
  • Comparison with predicate র্ব
Similarities
ItemDevicePredicate
Detection methodAmperometryAmperometry
EnzymeGlucose oxidase(Aspergillus niger)Glucose oxidase(Aspergillus niger)
MediatorPotassium ferricyanidePotassium ferricyanide
ElectrodeCarbon electrodeCarbon electrode
Hematocrit range20-60%30-55%
Sample volume$> 0.6 uL$$> 2.0 uL$
Temperature range10-40°C10-40°C
Humidity rangeRH ≤ 90%RH ≤ 90%
CodingOne CodeCode card
Memory capability480 tests with date and time100 tests with date and time
Power3V 2X CR2032 batteries1 5V (AAA) batteries
Battery lifeApprox 2000 testsApprox 1000 tests
Differences
ItemDevicePredicate
Test range20-600 mg/dL30-550 mg/dL
Test time5 seconds5 seconds
Size L x W x H (inch)3 5"x 2 1"x 0 97"3 2"x 2"x 0 7"
Weight2 05 oz (without batteries)1 6 oz (without batteries)
  • J Standard/Guidance Document Referenced (If applicable)

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  • CLSI EP5-A, Precision Performance of Clinical Chemistry Devices 1
  • CLSI EP6-A, Evaluation of the Linearity of Quantitative Analytical Methods, Proposed 2 Guideline
  • 3 CLSI EP7-A. Interference Testing in Clinical Chemistry, Proposed Guideline
  • ISO 15197 2003, In Vitro Diagnostic Test Systems Requirements for Blood ಗ Glucose Monitoring Test Systems for Self Managing Diabetes Mellitus
  • 5 IEC 60601-1-2, Medical Electrical Equipment - Part 1 General Requirement for Safety, Electromagnetic Compatibility - requirements and Tests
  • IEC 61010-1, Safety Requirements for Electrical Equipment for Measurement, 6 Control, and Laboratory Use - Part 1 General Requirements
  • IEC 60601-2-101, Safety Requirements For Electrical Equipment for Measurement, 7 Control, and Laboratory Use - Part 2-101 Particular Requirements for In Vitro Diagnostic (IVD) Medical Equipment
  • IEC 60068-2-64. Environmental Testing- Part 2 Test Methods- Test Fh Vibration, 8 Broad-band Random (Digital Control) and Guidance
  • 9 IEC 61326 (2002-02) - (for reference), Electrical Equipment for Measurement Control, and Laboratory Use - EMC Requirements
  • ISO 14971 2000, Medical Devices Application of Risk Management to Medical 10 Devices
  • ISO 15223 2000. Medical Devices Symbols to be Used With Medical Device Labels, 11 Labeling, and Information to be Supplied
  • 12 EN 376 2002. Information Supplied by the Manufacturer With In Vitro Diagnostic Reagents for Self Testing
  • ISO 10993-1. Biological Evaluation of Medical Devices Part 1 Evaluation and 13 Testing
  • 14 EN 13640 2002 Stablity Testing of in Vitro Diagnostic Reagents

K Test Principle

The EasyPlus mını R2N Self-Monitoring Blood Glucose System employs a dısposable dry reagent strip technology, based on the glucose oxidase method for glucose determination Each test strip features an electrode containing the enzyme glucose oxidase (Aspergillus niger) A blood sample is applied to the blood collection area at the tip of the strip and is automatically drawn into the reaction zone, where the glucose oxidase catalyzes the oxidation of glucose to produce gluconic acıd During the reaction, a mediator transfers electrons to the electrode surface and generates a current The amount of the current is proportional to the amount of glucose present in the blood sample the glucose concentration is measured by the EasyPlus mini R2N Glucose Meter and displayed on the screen after 5 seconds

L Performance Characteristics (if/when applicable)

  • Analytical performance 1
    • a Precision/Reproducibility

Within-run - The testing was used by venous blood, which comes with heparın blood collection tube Glucose was added to the blood to prepare 6 different levels of glucose

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concentration for the testing The glucose concentration ranges were 20-50 mg/dL, 51-110 mg/dL, 111-150 mg/dL, 151-250 mg/dL, 251-400 mg/dL, and 401~600 mg/dL For each testing range, 10 Meters, 10 PCs of test strips for each meter, and 2 lots of test strips were used (N=10 Meter x10 tests x 2 lots =200)

Range (mg/dL)NLot 021074801
Mean(mg/dL)SD(mg/dL)CV (%)
20~50 mg/dL10053 81 572 92%
51~110 mg/dL10076 01 982 61%
111~150 mg/dL100126 83 282 59%
151~250 mg/dL100214 67 053 29%
251~400 mg/dL100363 08 172 25%
401~600 mg/dL100561 612 392 21%
Normalcontrol solution100111 63 923 51%
Range (mg/dL)NLot 021075201
Mean(mg/dL)SD(mg/dL)CV (%)
20~50 mg/dL10055 92 484 44%
51~110 mg/dL10077 52 803 62%
111~150 mg/dL100132 33 272 47%
151~250 mg/dL100221 25 922 67%
251~400 mg/dL100368 97 742 10%
401~600 mg/dL100563 413 962 48%
Normalcontrol solution100119 74 383 66%

Day-to-Day Precision

10 Meters, 2 lots of test strip, and 3 control solutions of Low, Normal and High were prepared Each control was tested twice a day, once in the morning and once in the afternoon for 10 days (N=10 Meter x 2 Lots x 2 tests x10 days =400),

ControlsolutionNmean(mg/dL)SD(mg/dL)CV (%)
Low40047 11 673 54%
Normal400122 24 623 78%
High400398 510 572 65%

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Linearity/assav reportable range o

A blood sample of 25 mL was taken, treated with heparın vacuum tube, to be set for a day Testing was performed using whole blood supplemented with ß -Dglucose to provide samples at seven different blood glucose levels (20-50 mg/dL, 51-80 mg/dL, 81-120 mg/dL, 121-200 mg/dL, 201-300 mg/dL, 301-400 mg/dL, and 400-600 mg/dL) A total of 210 tests were performed using 10 meters among the seven glucose ranges per each strip lot

The linear regression was as follows

N=630 (210X3Lot)
Slope1 0450
Y-intercept-1 2505
R20 9950
  • Traceability, Stability, Expected values (controls, calibrators, or methods) C The device is traceable to a laboratory YSI 2300D analyzer Calibrate YSI 2300D analyzer before its use and the calibrators are manufactured gravimetrically and provided from the instrument supplier
    Execute the validation of YSI 2300D analyzer by using this international standard reference material (NIST 965a) every year

Stability characteristics of the Normal and High control solutions were determined by using real-time stability studies to determine the storage stability at room temperature to be 19 months

  • d Detection limit
    Data was provided to support a reportable range of 20-600 mg/dL

  • e Analytical specificity
    Hematocrit interference was evaluated by adjusting the glucose concentrations and hematocrit levels of venous blood samples from several donors The venous blood samples spiked to 4 glucose concentration levels described in the following table The hematocrit levels were adjusted to 0%, 20%, 40%, 50%, 60% and 70% Each sample was run n=10 for each strip lot and the maxımum percent bias was calculated compared to the 40% hematocrit samples The acceptance criteria of Hematocrit interference test is bias ≤15 mg/dL when glucose concentration ≤75 mg/dL and bras ≤ 15% when glucose concentration > 75 mg/dL Results are summarized in table as below After analysıs of this studie, the claim for the device was for use with samples having hematocrit concentrations ranging from 20% to 60%

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Strip lot #Hematocrit%YSI Labeled Value, mg/dLSlopeY-interceptR2% Bias
0120729010%54 85 122 5 267 0 494 00 987451 7450 969729 51
20%45 25 119 5 269 0 497 00 94617 28420 9982-1 18
40%47 55 127 5 270 0 505 50 9896-3 40030 9982-2 21
50%47 50 125 5 264 0 504 00 9529-4 14260 9974-4 61
60%50 05 120 5 264 5 509 50 92967 50740 9992-0 47
70%50 55 118 0 258 5 505 00 714917 8940 9944-13 46
0120727010%54 85 122 5 267 0 494 01 081243 4380 981134 01
20%45 25 119 5 269 0 497 00 94008 88230 9968-0 45
40%47 55 127 5 270 0 505 51 0130-7 86320 9981-2 75
50%47 50 125 5 264 0 504 00 9423-1 85920 9992-3 97
60%50 05 120 5 264 5 509 50 93774 46870 9985-0 59
70%50 55 118 0 258 5 505 00 679826 6410 9973-10 74

Assay cut-off f

N/A

  • Comparison studies 2
    a Method comparison with predicate device

Site 1,2,3.

Accuracy / Method comparison at sites 1,2,3

A total 156 diabetes patients performed a finger stick and forearm using the EasyPlus mini R2N system at 3 sites A healthcare professional then performed the test on the EasyPlus mini R2N and the YSI 2300 analyzer The range of tested values for these samples was 74 2-486 mg/dL In order to fully cover the measuring range, 9 of the samples were spiked with glucose or allowed to glycolyze The total 165 (156+9) samples ranged in concentration from 32 to 591 mg/dL on the EasyPlus min: R2N SMBG system The distribution of total 165 samples is described as below

GlucoseconcentrationNumber of sample% of sample
<50mg/dL63 6
50-80 mg/dL84 8
81-120 mg/dL4929 7
121-200 mg/dL5734 5
201-300 mg/dL3320 0
301-400 mg/dL53 0
>400 mg/dL74 2

Meter versus YSI at each site met the ISO 15197 requirement of ninety-five percent (95 %) of the individual glucose results fallıng withın ±15 mg/dL of the

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results of the manufacturer's measurement procedure at glucose concentrations for samples <75 mg/dL and within ± 20 % at glucose concentrations ≥75 mg/dL These results are summarized in the table below

System accuracy results for glucose concentrations < 75 mg/dL

Within ±5mg/dLWithin ±10mg/dLWithin ±15mg/dL
7/8(87.5%)7/8(87.5%)8/8(100.0%)

System accuracy results for glucose concentrations > 75 mg/dL

Within ±5%Within ±10%Within ±15%Within ±20%
56/157(35 67%)103/157 (65 61%)138/157(87 90%)151/157 (96 18%)

Method comparison studies were performed by using alternate site testing (AST) samples compared to professional finger stick samples The studies were performed by using professional and participant AST samples take from the forearm

The linear regressions were as follows

ComparisonNRange(mg/dL)Slope and Y-interceptR2
Finger vs YSI (professionals)15674 2-486$Y=1.0470X-3.9092$0.9540
Finger vs YSI (lay users)15674 2-486$Y=1.0307X-2.8876$0.9471
Thenar vs Finger(professionals)15671 0-566$Y=1.0113X+3.2591$0.9610
Thenar vs Finger(lay users)15671 0-566$Y=1.0072X+6.7177$0.9539
Hypothenar vs Finger(professionals)15671 0-566$Y=1.0642X-2.7188$0.9617
Hypothenar vs Finger(lay users)15671 0-566$Y=1.0421X+1.0330$0.9684
Forearm vs Finger(professionals)15671 0-566$Y=0.9144X+16.121$0.9448
Forearm vs Finger (lay users)15671 0-566$Y=0.9410X+15.266$0.9163

And compare with predicate device, the linear regressions was as follows EasyPlus mini R2N vs predicate device Y = 1 0431X -1 1192, R = 0 9785

  • Matrix companson b N/A
  • Clinical studies ತಿ
    • Clinical Sensitivity a N/A
    • Clinical specificity ﻫ N/A
    • c Other clinical supportive data (when a and b are not applicable) see section 2 a

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4 Clinical cut-off N/A

ട് Expected values/Reference range

Expected blood glucose levels for people without diabetes (refereced from American Diabetes Associations Standards of Medical Care for Patients with Diabetes Mellitus, Diabetes Care, 25(2002), p S37)

TimeRange (mg/dL)
Before meals or Fasting70-110
2 hour after mealsLess than 120

N Proposed Labeling

The labeling is sufficient and it satisfies the requirements of 21 CFR Part 809 10

O Conclusion

ן

The EasyPlus mini R2N Self Monitoring Blood Glucose System has the same intended use and sımılar technological characteristics as the EasyPius Self Monitoring Blood Glucose System (K061992) marketed by EPS Blo Technology Corp , Moreover, bench testing contained in the submission demonstrate that any differences in their technological characteristics do not raise any new questions of safety or effectiveness Thus, the EasyPlus mini R2N Self-Monitoring Blood Glucose System is substantially equivalent to the predicate devise

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Image /page/9/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo features a stylized eagle with its wings spread, and the text "DEPARTMENT OF HEALTH & HUMAN SERVICES USA" is arranged in a circular pattern around the eagle. The logo is black and white.

Food and Drug Administration 2098 Gaither Road Rockville MD 20850

EPS BIO Technology Corp c/o Y C Leı General Manager 2F No 49-2, Lane 2, Guang Fu Road, Sec 2 Hsınchu Cıty, 30071 Tarwan, ROC

JAN 2 3 2009

K081796 Re

Trade Name EasyPlus mını R2N Self-Monitoring Blood Glucose Test System Regulation Number 21 CFR 862 1345 Regulation Name Glucose Test System Regulatory Class Class II Product Codes NBW. CGA. JJX Dated January 9, 2009 Received January 12, 2009

Dear Mr Lei

We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food. Drug. and Cosmetic Act (Act) that do not require approval of a premarket approval application (PMA) You may, therefore, market the device, subject to the general controls provisions of the Act The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration

If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to such additional controls Existing major regulations affecting your device can be found in Title 21, Code of Federal Regulations (CFR), Parts 800 to 895 In addition, FDA may publish further announcements concerning your device in the Federal Register

Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies You must comply with all the Act's requirements, including, but not limited to registration and listing (21 CFR Part 807), labeling (21 CFR Parts 801 and 809), and good manufacturing practice requirements as set forth in the quality systems (OS) regulation (21 CFR Part 820)

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Page - 2

This letter will allow you to begin marketing your device as described in your Section 510(k) premarket notification The FDA finding of substantial equivalence of your device to a legally marketed predicate device results in a classification for your device and thus, permits your device to proceed to the market

If you desire specific information about the application of labeling requirements to your device, or questions on the promotion and advertising of your device, please contact the Office of In Vitro Diagnostic Device Evaluation and Safety at (301) 594-3084 Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21CFR Part 807 97) You may obtain other general information on your responsibilities under the Act from the Division of Small Manufacturers, International and Consumer Assistance at its toll-free number (800) 638-2041 or (301) 443-6597 or at its Internet address http //www fda gov/cdrh/dsma/dsmamain html

Sincerely yours.

Coy C. Hh

Courtney C Harper, Ph D Acting Director Division of Chemistry and Toxicology Office of In Vitro Diagnostic Device Evaluation and Safety Center for Devices and Radiological Health

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Indication for Use

510(k) Number (if known) K081796 Device Name EasyPlus mini R2N Indication For Use

The EasyPlus min1 R2N Self Monitoring Blood Glucose Test System

The EasyPlus mini R2N Self Monitoring Blood Glucose Test System is intended for the quantitative measurement of glucose in fresh capillary whole blood samples drawn from the fingertips or forearm Testing is done outside the body (In Vitro diagnostic use) It is indicated for use at home (over the counter [OTC]) by persons with diabetes, or in clinical settings by healthcare professionals, as an and to monitor the effectivemess of diabetes control

The EasyPlus mini R2N Meter

The EasyPlus mini R2N Meter is intended for the quantitative measurement of glucose un fresh capillary whole blood samples drawn from the fingertips or forearm EasyPlus mini R2N Blood Glucose Test Strips must be used with the EasyPlus min R2N Meter Testing is done outside the body (In Vitro diagnostic use)

It is indicated for use at home (over the counter [OTC]) by persons with drabetes, or in clinical settings by healthcare professionals, as an and to monitor the effectiveness of diabetes control

The EasyPlus mini R2N Blood Glucose Test Strips

The EasyPlus mini R2N Blood Glucose Test Strips , are intended for the quantitative measurement of glucose in fresh capillary whole blood samples drawn from the fingertups or forearm EasyPlus mini R2N Blood Glucose Test Strips must be used with the EasyPlus mini R2N Blood Glucose Meter Testing is done outside the body (In Vitro diagnostic use) They are indicated for use at home (over the counter [OTC]) by persons with diabetes, or in clinical settings by healthcare professionals, as an aid to monitor the effectiveness of diabetes control

The EasyPlus mini R2N Glucose Normal/High Control Solution

For use with the EasyPlus min R2N meter and EasyPlus mini R2N Blood Glucose Test Strips as a quality control check to venfy the accuracy of blood glucose test results

Prescription Use V (21 CFR Part 801 Subpart D) Over the Counter Use V (21 CFR Part 801 Subpart C)

(PLEASE DO NOT WRITE BELOW THIS LINE, CONTINUE ON ANOTHER PAGE IF NEEDED)

And/Or

Concurrence of CDRH, Office of In Vitro Diagnostic Device Evaluation and Safety (OIVD)

Carol C. Benson

Division Sign-Off Office of In Vitro Diagnostic Device Evaluation and Safety

510(k) K081796

§ 862.1345 Glucose test system.

(a)
Identification. A glucose test system is a device intended to measure glucose quantitatively in blood and other body fluids. Glucose measurements are used in the diagnosis and treatment of carbohydrate metabolism disorders including diabetes mellitus, neonatal hypoglycemia, and idiopathic hypoglycemia, and of pancreatic islet cell carcinoma.(b)
Classification. Class II (special controls). The device, when it is solely intended for use as a drink to test glucose tolerance, is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 862.9.