K Number
K161484
Device Name
ZIIP Device
Manufacturer
Date Cleared
2017-02-24

(269 days)

Product Code
Regulation Number
882.5890
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The ZIIP Device is intended for facial stimulation and is indicated for over-the-counter cosmetic use.
Device Description
The ZIIP Device is a hand-held, battery-powered device used with conductive gel to stimulate the face superficially through application of transcutaneous electrical currents. It is intended to be used by a single user (multiple applications).
More Information

Not Found

No
The document does not mention AI, ML, or any related concepts like deep learning, neural networks, or training/test sets for algorithms. The device description and performance studies focus on electrical stimulation and safety standards.

No
The device is explicitly stated as intended for "over-the-counter cosmetic use" and "facial stimulation" and not for medical purposes.

No

The device is intended for facial stimulation and cosmetic use, not for diagnosing any medical condition.

No

The device description explicitly states it is a "hand-held, battery-powered device" and mentions testing related to electrical safety and electromagnetic disturbances, indicating it is a hardware device that uses electrical currents for stimulation.

Based on the provided information, the ZIIP Device is not an IVD (In Vitro Diagnostic).

Here's why:

  • Intended Use: The intended use is for "facial stimulation" and "over-the-counter cosmetic use." This describes a device used on the body for cosmetic purposes, not a device used to examine specimens from the body to provide information for diagnosis, monitoring, or treatment.
  • Device Description: The description details a hand-held device that applies electrical currents to the face. This aligns with a physical therapy or cosmetic device, not an IVD.
  • Lack of IVD Characteristics: The document does not mention any of the typical characteristics of an IVD, such as:
    • Analyzing biological samples (blood, urine, tissue, etc.)
    • Detecting or measuring substances in samples
    • Providing diagnostic information
    • Mentioning any laboratory or clinical testing of samples

In summary, the ZIIP Device is a cosmetic device for facial stimulation, not an in vitro diagnostic device.

N/A

Intended Use / Indications for Use

The ZIIP Device is intended for facial stimulation and is indicated for over-the-counter cosmetic use.

Product codes

NFO

Device Description

The ZIIP Device is a hand-held, battery-powered device used with conductive gel to stimulate the face superficially through application of transcutaneous electrical currents. It is intended to be used by a single user (multiple applications).

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

facial

Indicated Patient Age Range

Not Found

Intended User / Care Setting

Not Found

Description of the training set, sample size, data source, and annotation protocol

Not Found

Description of the test set, sample size, data source, and annotation protocol

Not Found

Summary of Performance Studies

There was no clinical testing performed in support of this 510(k) submission.

Key Metrics

Not Found

Predicate Device(s)

K103472

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 882.5890 Transcutaneous electrical nerve stimulator for pain relief.

(a)
Identification. A transcutaneous electrical nerve stimulator for pain relief is a device used to apply an electrical current to electrodes on a patient's skin to treat pain.(b)
Classification. Class II (performance standards).

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Image /page/0/Picture/1 description: The image shows the logo for the U.S. Department of Health & Human Services. The logo consists of a circular seal with the text "DEPARTMENT OF HEALTH & HUMAN SERVICES - USA" arranged around the perimeter. Inside the circle is a stylized image of three human profiles facing to the right, with a design that resembles an abstract caduceus or flowing fabric beneath them.

Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002

February 24, 2017

ZIIP, LLC David Mason Co-Founder 1871 Trestle Glen Rd Piedmont, California 94610

Re: K161484

Trade/Device Name: ZIIP Device Regulation Number: 21 CFR 882.5890 Regulation Name: Transcutaneous Electrical Nerve Stimulator for Pain Relief Regulatory Class: Class II Product Code: NFO Dated: January 16, 2017 Received: January 24, 2017

Dear Mr. Mason:

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. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you, however, that device labeling must be truthful and not misleading.

If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 898. 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 Part 801); medical device reporting (reporting of medical device

1

related adverse events) (21 CFR 803); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.

If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please contact the Division of Industry and Consumer Education at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address

http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to

http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm for the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance.

You may obtain other general information on your responsibilities under the Act from the Division of Industry and Consumer Education at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address

http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm.

Sincerely yours,

Michael J. Hoffmann -S

  • for Carlos L. Peña, PhD, MS Director Division of Neurological and Physical Medicine Devices Office of Device Evaluation Center for Devices and Radiological Health
    Enclosure

2

Indications for Use

510(k) Number (if known) K161484

Device Name ZIIP Device

Indications for Use (Describe)

The ZIIP Device is intended for facial stimulation and is indicated for over-the-counter cosmetic use.

Type of Use (Select one or both, as applicable)

Prescription Use (Part 21 CFR 801 Subpart D)

|X | Over-The-Counter Use (21 CFR 801 Subpart C)

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510(k) SUMMARY

510(k) Notification K161484

GENERAL INFORMATION

Applicant (§807.92(a)(1)) : ZIIP LLC 182 Howard St. #151 San Francisco, CA 94105 Telephone: 1-800-944-7031

Contact Person (§807.92(a)(1)): David Mason Co-Founder ZIIP, LLC david@ziipbeauty.com

Date Prepared (§807.92(a)(1)): May 17, 2016

Device Information

Trade Name (§807.92(a)(2)): ZIIP Device

Generic/Common Name (§807.92(a)(2)): Facial Toning Device

Classification (§807.92(a)(2)): Transcutaneous Electrical Nerve Stimulator – CFR 882.5890

Product Code: NFO

PREDICATE DEVICE(s) (§807.92(a)(3))

  • . K103472 - NuFace Plus Facial Toning Device

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DEVICE DESCRIPTION (§807.92(a)(4))

The ZIIP Device is a hand-held, battery-powered device used with conductive gel to stimulate the face superficially through application of transcutaneous electrical currents. It is intended to be used by a single user (multiple applications).

INDICATIONS FOR USE/INTENDED USE (§807.92(a)(5))

The ZIIP Device is intended for facial stimulation and is indicated for over-the-counter cosmetic use.

TECHNOLOGICAL CHARACTERISTICS/PRINCIPLES OF OPERATION (§807.92(a)(6))

The ZIIP Device is a Facial Toning Device intended for facial stimulation. It produces a small electrical current discharged through the two electrodes. The current delivered is an aesthetic modality providing a small electric current in millionths of an ampere and has the ability to increase facial contour and firm the skin and muscles by supplying a maximum of +/- 200 micro amperes of current. The device measures 2.00" W x 3.9" L x 1.40" D (fits in the palm of a hand) and weighs 3.2 ounces. The outer case of the ZIP Device is manufactured using injectionmolded of thermoplastic resin and the output contacts (probes) consist of chrome-plated spheres. The device is powered by Lithium-lon rechargeable batteries (3.7V, 700mAh (503048-2C) / 2.59Wh, 1.4A rate). The ZIIP Device is shipped with a portable batter-charger (Charging Rate: 0.7A Max. 1.0C rate).

The ZIIP Device was designed with an easy-to-use, ergonomic user interface that has one button to power the device on and off, curved design, and protruding chrome-plated electrodes for ease of facial application. The device is turned on by momentarily pressing the ON/OFF button once. The device annunciates its being turned on by beeping once, flashing a light indicator, and by a single haptic vibration. The device may be turned off at any time by pressing the ON/OFF button once. The device annunciates its being turned off by beeping twice. The unit turns-off if the battery voltage drops below 3.4 Volts.

The ZIIP Device spherical probes are designed for optimal contact with the face. The white LEDs turn-on if the unit can sense 100 nA or greater of electrode current. There is no specific skin impedance at which this happens. The device requires the use of a conductive gel. The conductive gel is used to reduce the impedance between the electrodes and the skin of the user.

Waveform Description

The ZIIP Device provides one continuous waveform output type, a square wave. For duty cycle, the ZIP device has a 100% duty cycle because the user is receiving energy on both the positive and negative portions of the square waves at the electrodes. This then translates to the values for "maximum current density" and "maximum power density" which are premised on the calculated value of the peak current in use.

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Substantial Equivalence Discussion & Summary of Comparison Data (§807.92(a)(6)((a)(b))

The ZIIP device has the same intended use and indications for use as the claimed predicate device. The device also has similar technological characteristics. During the design and development, risk management tools were employed in accordance with ISO 14971 (Medical devices — Application of risk management to medical devices) requirements. The risk assessment for the ZIIP Device was used to identify potential hazards that could occur during the use of the device, or in the event of failure modes associated with device components. Risk analysis was used to identify risk reduction measures which have been incorporated in the device design and labeling.

| Basic Unit

CharacteristicsZIIP DeviceNuFace® Plus
510(k) NumberK161484K103472
Regulation Number21 CFR, Part 882.589021 CFR, Part 882.5890
Regulation NameTranscutaneous Electrical Nerve
StimulatorTranscutaneous Electrical
Nerve Stimulator
Regulation ClassClass IIClass II
Product CodeNFONFO
Intended UseStimulate the Face - Skin ToningStimulate the Face - Skin
Toning
Indications for UseOver-the-counter cosmetic useOver-the-counter cosmetic use
Technological
CharacteristicsThe ZIIP Device is a Facial Toning
Device intended for facial
stimulation. It produces a small
electrical current discharged
through the two electrodes. The
current delivered is an aesthetic
modality providing a small
electric current in millionths of
an ampere and has the ability to
increase facial contour and firm
the skin and muscles by
supplying a maximum of +/- 200
micro amperes of current. The
device measures 2.00" W x 3.9"
L x 1.40" D (fits in the palm of a
hand) and weighs 3.2 ounces.
The outer case of the ZIIP Device
is manufactured using injection-
molded of thermoplastic resin
and the output contacts
(probes) consist of chrome-
plated spheres. The device is
powered by Lithium-Ion
rechargeable batteries (3.7V,
700mAh (503048-2C) / 2.59Wh,
1.4A rate), The ZIIP Device isThe Nu-Face Plus is a Facial
Toning Device intended for
facial stimulation. It produces a
micro-current discharged
through the two spherical
probes. Micro-current is an
aesthetic modality providing
electric current in millionths of
an ampere and has the ability
to increase facial contour and
firm the skin and muscles by
supplying 80 - 400 pA.
The device measures 3" W x
5.25' L x 1.25' D. Its outer case
is injection molded of
thermoplastic resin and the
output contacts (probes)
consist of chrome-plated
spheres. The device is powered
by 4 rechargeable batteries.
The NuFACE® Plus comes with
a rechargeable base, which
measures 3.25" W x 4" L x
3.25" D.

Device Descriptions - Comparison ZIIP Device with Predicate (§807.92(a)(6)(a)(b))

6

' shipped with a portable batter-
' charger (Charging Rate: 0.7A
Max. 1.0C rate).

Basic Unit & Output Characteristics (§807.92(a)(6)(a)(b))

Basic Unit CharacteristicsZIIP DeviceNuFace® Plus
510(k) NumberK161484K103472
Device Name & ModelZIIP DeviceNuFace® Plus
ManufacturerZIIP, LLCCarol Cole Company
Regulation NameTranscutaneous
Electrical Nerve
StimulatorTranscutaneous
Electrical Nerve
Stimulator
Power Source(s)
a. Method of Line Current IsolationOne Rechargeable
Lithium-Ion Battery,
and External Charger
Isolation
(External Charger
Included)4 rechargeable AA
NiMH batteries
b. Patient Leakage Current
1. Normal Condition46uAN/A - Battery
Operated
2. Single Fault Condition46uAN/A - Battery
Operated
Number of Output ModulesN/A1
Number of Output Channels11
a. Synchronous or AlternatingN/A - 1 Output
ChannelN/A - 1 Output
Channel
b. Method of Channel IsolationN/A - 1 Output
ChannelN/A - 1 Output
Channel
Regulated Current or Regulated VoltageBothBoth
Software/Firmware/Microprocessor
ControlledYesYes
Automatic Overload TripNot required because
of circuit design
(Current and Voltage
Limited by Circuit
Design and Firmware)Not required because
of circuit design
Automatic No-Load TripYes (Reversion to
Fixed Voltage Output)Yes
Automatic Shut OffYesYes
Patient Override ControlYesYes
Indicator Display
a. On/Off StatusYes (LED Illumination
on Conduction)Yes
b. Low BatteryYesYes
c. Voltage/Current LevelYes (LED Illumination
on Target Current
Levels)Yes
Timer RangeYesYes (21-Minutes)

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Basic Unit CharacteristicsZIIP DeviceNuFace® Plus
Compliance with Voluntary StandardsIEC 60601-1
IEC 60601-1-2IEC 60601-1
IEC 60601-1-2
Weight3.2 oz9 oz
Dimensions2" X 3.9" X 1.4"3" x 5.2" x 1.25"
Housing Material ConstructionThermo PlasticThermo Plastic
Electro-conductive Material required?Conductive Gel
(§882.1275)NuFACE Primer

Waveform/Output Comparison (§807.92(a)(6)(a)(b))

Basic Unit CharacteristicsZIIP DeviceNuFace® Plus
WaveformPulsed BiphasicPulsed Monophasic
ShapeModulated Square WaveModulated Square Wave
Maximum Output Voltage154mV@ 500Ω137mV @ 500Ω
465mV@ 2KΩ769mV @ 2KΩ
2.2V @ 10ΚΩ3.82V @ 10KΩ
Maximum Output Current308μA @ 500Ω274μA @ 500Ω
232μA @ 2KΩ387μΑ @ 2ΚΩ
202μΑ @ 10ΚΩ383μΑ @ 10ΚΩ
Output Tolerance+/- 10%+/- 2%
Pulse Width50µs119ms
Frequency50.0Hz8.4Hz
For Interferential Modes Only
Beat FrequencyNo Beat FrequencyNo Beat Frequency
For Multiphasic Waveforms
Symmetric Phases?MultiphasicNot Multiphasic
Phase Duration10.0ms Positive/10.0ms
NegativeNot Determined
Net Charge(μC per pulse)N/A - Battery OperatedN/A - Battery Operated
On Time (Seconds)ConstantConstant
Off Time (Seconds)NoneNone
Maximum Phase Charge (μC)6.16μC @ 500Ω23.06μC @ 500Ω
Maximum Current Density (mA/cm²)0.034mA/cm² @ 500Ω0.419mA/cm² @ 500Ω
Maximum Power Density (μW/cm²)3.44μW/cm²@ 500Ω3.22μW/cm² @ 500Ω

Nonclinical Testing in Support of Substantial Equivalence Determination (§807.92(a)(6)(b)(1)

The ZIIP Device was tested and found to be in compliance with FDA's performance standards in accordance with 21 CDR, Part 898 (Performance Standards for Electrode Lead Wires and Patient Cables). Additionally, the ZIP Device was tested and found to be in compliance with IEC 60601-1 -2 (Medical electrical equipment – Part 1-2: General requirements for basic safety and essential performance – Collateral Standard: Electromagnetic disturbances – requirements and tests) for radiated and power line conducted emissions. Furthermore, the ZIIP Device was evaluated and found to be in compliance with IEC 60601-1 (Medical electrical equipment: Part 1: General requirements for basic safety and essential performance) for Electrical Safety. Finally, the ZIIP Device has been tested to demonstrate its performance specifications are equivalent to

8

the NuFace Plus, and has been validated in accordance with IEC 60601-1 and IEC 60601-1-2 requirements. Note: the materials that come in contact with the user skin have been assessed in accordance with ISO 10993 (Biological evaluation of medical devices package).

LIST OF NONCLINICAL SAFETY TESTS PERFORMED

Table below delineates the compilation of nonclinical testing employed for the testing of the ZIIP Device.

Non-clinical Testing Employed

TestNameTesting FacilityResults
IEC 60601-1Medical electrical equipment: Part 1:
General requirements for basic safety
and essential performanceITC Engineering servicesPass
IEC 60601-1-2Medical electrical equipment — Part 1-2:
General requirements for basic safety
and essential performance – Collateral
Standard: Electromagnetic disturbances
– requirements and testsITC EngineeringPass

Product Testing

The ZIIP Device was thoroughly tested during design verification testing and design validation testing. A brief summary has been placed into the table above. Additionally, performance testing was performed in accordance with IEC 60601-1-2:2007, Medical Electrical Equipment.

Compilation of Test Protocols & Reports

Protocol & Report NumberTitleDateResults
199001-005, Rev 0ZiiP 1.00 Validation Plan and Protocol2/28/16N/A
199001-006, Rev 0ZiiP 1.00 Validation Report2/28/16Pass
199001-007, Rev 0ZiiP 1.00 Verification Plan and Protocol2/28/16N/A
199001-008, Rev 0ZiiP 1.00 Verification Report2/28/16Pass

CLINICAL TESTING (§807.92(a)(6)(b)(2)

There was no clinical testing performed in support of this 510(k) submission.

Conclusion (§807.92(a)(6)(b)(3)

The ZIIP Device is substantially equivalent to the predicate device identified in this summary and previously cleared by FDA in accordance with 21 CFR, Part 807 requirements.