K Number
K180952
Device Name
Ceramic Bracket
Date Cleared
2019-06-07

(422 days)

Product Code
Regulation Number
872.5470
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdparty
Intended Use
Ceramic Bracket is indicated for orthodontic movement of natural teeth.
Device Description
Ceramic bracket are designed to move teeth to improve their alignment. Ceramic bracket are bonded to natural teeth by dental professionals to connect with orthodontic wires to cause tooth movement to a more preferred position. Ceramic bracket are intended for use in affixed to a tooth so that pressure can be exerted on the teeth. Use bonding supplies to bond the bracket on to a tooth. Use bonding supplies to bond the bracket on to a tooth. Ceramic bracket are bonded to natural teeth by dental professionals to connect with orthodontic wires to cause tooth movement to a more preferred position.
More Information

Not Found

No
The device description and performance studies focus on the mechanical properties and function of a physical orthodontic bracket, with no mention of software, algorithms, or data processing that would indicate AI/ML.

Yes
The device is described as moving teeth to improve their alignment, which is a therapeutic purpose.

No
The device, a ceramic bracket for orthodontic movement, is designed to physically move teeth, not to diagnose any condition. Its intended use and description focus on treatment rather than diagnosis.

No

The device description explicitly states it is a "Ceramic Bracket" which is a physical component bonded to teeth. The performance studies also focus on mechanical properties like shear bond strength and torque strength, which are relevant to a physical device, not software.

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

Here's why:

  • Intended Use: The intended use is for "orthodontic movement of natural teeth." This is a mechanical function performed directly on the patient's body (in vivo).
  • Device Description: The description clearly states the device is "bonded to natural teeth" and used to "cause tooth movement." This is a physical intervention, not a diagnostic test performed on samples outside the body.
  • Lack of Diagnostic Activity: There is no mention of analyzing samples (blood, tissue, etc.) or providing diagnostic information about a patient's health condition.
  • Performance Studies: The performance studies focus on mechanical properties like shear bond strength and torque strength, which are relevant to the device's physical function in the mouth, not its ability to diagnose.

IVD devices are used to examine specimens derived from the human body (like blood, urine, tissue) to provide information for diagnostic, monitoring, or compatibility purposes. This ceramic bracket does not fit that description.

N/A

Intended Use / Indications for Use

Ceramic Bracket is indicated for orthodontic movement of natural teeth.

Product codes (comma separated list FDA assigned to the subject device)

NJM

Device Description

Ceramic bracket are designed to move teeth to improve their alignment. Ceramic bracket are bonded to natural teeth by dental professionals to connect with orthodontic wires to cause tooth movement to a more preferred position. Ceramic bracket are intended for use in affixed to a tooth so that pressure can be exerted on the teeth. Use bonding supplies to bond the bracket on to a tooth. Ceramic bracket are bonded to natural teeth by dental professionals to connect with orthodontic wires to cause tooth movement to a more preferred position.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

natural teeth

Indicated Patient Age Range

Not Found

Intended User / Care Setting

dental professionals

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 (study type, sample size, AUC, MRMC, standalone performance, key results)

Performance testing has been carried out to demonstrate that this device meets the performance specifications for its intend use. The following tests were performed on the device:
· ISO 27020 First edition 2010-12-15 Dentistry - Brackets and Tubes for use in Orthodontics Ceramic Bracket.
The biocompatibility evaluation and testing of the Product name was conducted in accordance with the following standards and guidance, as recognized by the FDA:

  • . FDA Draft Guidance - Use of International Standard ISO- 10993, "Biological Evaluation of Medical Devices, Part 1: Evaluation and Testing", dated 04-23-2013
  • . ISO 10993-3,Biological evaluation of medical device-Part 3: Test for genotoxicity, carcinogenicity and reproductive toxicity.
  • . ISO 10993-5, Biological evaluation of medical device-Part 5: Tests for in vitro cytotoxicity.
  • . ISO 10993-10. Biological evaluation of medical device-Part 10: Tests for irritation and skin sensitization.
  • ISO 10993-11, Biological evaluation of medical device-Part 11: Tests for systemic toxicity.
  • . ISO 10993-12, Biological evaluation of medical device-Part 12: Sample preparation and reference materials.
    Ceramic bracket's mechanical function including Shear Bond Strength, Torque Strength test and structure integrity were tested. The results were compared to recognized standards (ISO 6872:2015, ISO 29022:2013, ISO 27020:2010, ISO 6474-2:2012) and clinical literature data to demonstrate substantial equivalence.
    No animal studies or clinical testing have been required for these devices.

Key Metrics (Sensitivity, Specificity, PPV, NPV, etc.)

Not Found

Predicate Device(s): If the device was cleared using the 510(k) pathway, identify the Predicate Device(s) K/DEN number used to claim substantial equivalence and list them here in a comma separated list exactly as they appear in the text. List the primary predicate first in the list.

K160615

Reference Device(s): Identify the Reference Device(s) K/DEN number and list them here in a comma separated list exactly as they appear in the text.

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information for the subject device only (e.g. presence / absence, what scope was granted / cleared under the PCCP, any restrictions, etc).

Not Found

§ 872.5470 Orthodontic plastic bracket.

(a)
Identification. An orthodontic plastic bracket is a plastic device intended to be bonded to a tooth to apply pressure to a tooth from a flexible orthodontic wire to alter its position.(b)
Classification. Class II.

0

Image /page/0/Picture/0 description: The image shows the logo of the U.S. Food and Drug Administration (FDA). On the left is the Department of Health & Human Services logo. To the right of that is the FDA logo, which is a blue square with the letters "FDA" in white. To the right of the blue square is the text "U.S. FOOD & DRUG ADMINISTRATION" in blue.

June 7, 2019

MEM Dental Technology Co., Ltd Anita Chen Official Correspondent 2F., No.22, Ln.31, Sec.1, Huandong Rd., Xinshi Dist. Tainan City, 74146 Tw

Re: K180952

Trade/Device Name: Ceramic Bracket Regulation Number: 21 CFR 872.5470 Regulation Name: Orthodontic Plastic Bracket Regulatory Class: Class II Product Code: NJM Dated: April 20, 2019 Received: May 6, 2019

Dear Anita Chen:

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. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies combination product submissions. 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

1

requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); medical device reporting of medical device-related adverse events) (21 CFR 803) for devices or postmarketing safety reporting (21 CFR 4, Subpart B) for combination products (see https://www.fda.gov/combination-products/guidance-regulatory-information/postmarketing-safety-reportingcombination-products); good manufacturing practice requirements as set forth in the quality systems (OS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.

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 https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.

For comprehensive regulatory information about mediation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/medicaldevices/device-advice-comprehensive-regulatory-assistance) and CDRH Learn (https://www.fda.gov/training-and-continuing-education/cdrh-learn). Additionally, you may contact the Division of Industry and Consumer Education (DICE) to ask a question about a specific regulatory topic. See the DICE website (https://www.fda.gov/medical-device-advice-comprehensive-regulatoryassistance/contact-us-division-industry-and-consumer-education-dice) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).

Sincerely,

Srinivas Nandkumar, Ph.D. Assistant Director DHT1B: Division of Dental Devices OHT1: Office of Ophthalmic, Anesthesia, Respiratory, ENT and Dental Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health

Enclosure

2

Indications for Use

510(k) Number (if known) K180952

Device Name Ceramic Bracket

Indications for Use (Describe)

Ceramic Bracket is indicated for orthodontic movement of natural teeth.

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

Prescription Use (Part 21 CFR 801 Subpart D)
Over-The-Counter Use (21 CFR 801 Subpart C)

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510(k) Summary

This 510(k) summary information is submitted as part of the Premarket Notification in compliance with requirements of CFR Part 807, Subpart E and Section 807.92

The assigned 510(k) Number:K180952
1.Submitter
Mailing AddressMEM Dental Technology Co., Ltd
2F., No.22, Ln.31, Sec.1, Huandong Rd.,
Xinshi Dist., Tainan City 74146, Taiwan
Phone: +886 6 5053939
Establishment Registration No.: 3009011037
Contact PersonAnita Chen
Phone:+886(0) 939-855-759
Fax:+886 6 5051212
E-mail:m9104303@gmail.com
Date Prepared2019.06.06
  • Device Name 2
Proprietary Name:Ceramic Bracket
Common or Usual NameBracket, Ceramic, Orthodontic
Classification NameBracket Orthodontic Plastic Bracket (21 CFR
872.5470)
Product CodeNJM
DeviceCeramic Bracket
CFR ClassificationCFR Part 872.5470
Device ClassII
Classification PanelDental
Primary Predicate
510(k) numberK160615

3

4

Device nameOrthodontic Ceramic Brackets 1.1
ManufacturerTOMY, INC
6 tenko blg. 3-16-7
midoricho, fuchu city, JP 183-0006
4 Device DescriptionCeramic bracket are designed to move teeth to
improve their alignment. Ceramic bracket are bonded
to natural teeth by dental professionals to connect
with orthodontic wires to cause tooth movement to a
more preferred position.

Ceramic bracket are intended for use in affixed to a
tooth so that pressure can be exerted on the teeth. Use
bonding supplies to bond the bracket on to a tooth.
Use bonding supplies to bond the bracket on to a
tooth. Ceramic bracket are bonded to natural teeth
by dental professionals to connect with orthodontic
wires to cause tooth movement to a more preferred
position. |
| 5. Indication for Use: | Ceramic bracket is indicated for orthodontic
movement of natural teeth. |

6. TechnologicalA comparison of the device features, intended use,
Characteristics andand other information demonstrates that the
Substantial EquivalenceCeramic bracket is substantially equivalent to the
Comparison with Predicate:predicate device as summarized in Table 1.

Table 1

5

ManufacturerMEM Dental Technology Co., Ltd.Tomy, Inc.
Subject DevicePrimary Predicate Device
Device nameCeramic bracketOrthodontic Ceramic Brackets 1.1
510(k) NumberK180952K160615
Indication for UseCeramic bracket is indicated for
orthodontic movement of
natural teeth.Orthodontic Ceramic Brackets
1.1 are indicated for orthodontic
movement of natural teeth.
Classification nameOrthodontic Plastic BracketOrthodontic Plastic Bracket
Rag Number872.5470872.5470
Product CodeNJMNJM
ClassIIII
Medical SpecialtyDentalDental
LigationNon-Self-LigatingNon-Self-Ligating
Self-LigatingSelf-Ligating
BaseMechanical Lock BaseMechanical Lock Base
SterilityNon-SterileNon-Sterile
MaterialsPolycrystalline (translucent) aluminaPolycrystalline (translucent) alumina
UtilitySingle-use onlySingle-use only
DesignArchwire slot, tiewings for ligature and
identification marks for placement
Hooks for ligation, for additional tooth
movement
Molded ceramic body with rounded
corners and e Slot to hold orthodontic
wires edgesArchwire slot, tiewings for ligature and
identification marks for placement
Hooks for ligation, for additional tooth
movement
Molded ceramic body with rounded
corners and e Slot to hold orthodontic
wires edges

6

ManufacturerMEM Dental Technology Co., Ltd.Tomy, Inc.
Subject DevicePrimary Predicate Device
Device nameCeramic bracketOrthodontic Ceramic Brackets 1.1
510(k) NumberK180952K160615
Picture of DeviceImage: Non-Self-Ligating
Image: Self-LigatingImage: Non-Self-Ligating Mandibular Bicuspid
Image: Non-Self-Ligating for all other Teeth
Image: Self-Ligating Mandibular Bicuspid
Image: Self-Ligating for all other Teeth

7. Performance Testing

Performance testing has been carried out to demonstrate that this device meets the performance specifications for its intend use. The following tests were performed on the device:

· ISO 27020 First edition 2010-12-15 Dentistry - Brackets and Tubes for use in Orthodontics

Ceramic Bracket.

All of the components found in the Ceramic Bracket have been used in legally marketed devices, such as the primary predicate Orthodontic Ceramic Brackets 1.1.

Biocompatibility Testing

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The biocompatibility evaluation and testing of the Product name was conducted in accordance with the following standards and guidance, as recognized by the FDA:

  • . FDA Draft Guidance - Use of International Standard ISO- 10993, "Biological Evaluation of Medical Devices, Part 1: Evaluation and Testing", dated 04-23-2013
  • . ISO 10993-3,Biological evaluation of medical device-Part 3: Test for genotoxicity, carcinogenicity and reproductive toxicity.
  • . ISO 10993-5, Biological evaluation of medical device-Part 5: Tests for in vitro cytotoxicity.
  • . ISO 10993-10. Biological evaluation of medical device-Part 10: Tests for irritation and skin sensitization.
  • ISO 10993-11, Biological evaluation of medical device-Part 11: Tests for systemic toxicity.
  • . ISO 10993-12, Biological evaluation of medical device-Part 12: Sample preparation and reference materials.

Sterilization Status

The Ceramic Bracket are provided non-sterile and are not processed prior to use.

Mechanical testing

Ceramic bracket's mechanical function including Shear Bond Strength, Torque Strength test and structure integrity were tested. The results were compared to recognized standards (ISO 6872:2015, ISO 29022:2013, ISO 27020:2010, ISO 6474-2:2012) and clinical literature data to demonstrate substantial equivalence.

No animal studies or clinical testing have been required for these devices.

8. Conclusion

Based on the intended use and/or indications for use, technological characteristics, performance testing and comparison to the predicate device, the Ceramic bracket is substantially equivalent.