K Number
K200098
Device Name
VagiVital Aktivgel
Date Cleared
2020-11-10

(299 days)

Product Code
Regulation Number
884.5300
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdparty
Intended Use
VagiVital Aktivgel is a personal lubricant for vaginal application intended to moisturize and lubricate, to enhance the ease and comfort of intimate sexual activity and supplement the body's natural lubrication. This product is compatible with polyisoprene condoms. This product is not compatible with natural rubber latex and polyurethane condoms.
Device Description
VagiVital Aktivgel is a water-based personal lubricant containing water, hypromellose, benzoic acid, lactic acid, and sodium hydroxide. VagiVital Aktivgel is provided in a 36 ml aluminum tube and may be packaged together with a reusable applicator.
More Information

Not Found

No
The device description and performance studies focus on the chemical composition, physical properties, and biocompatibility of a personal lubricant, with no mention of AI or ML technologies.

No.
The intended use states it is a personal lubricant to moisturize, lubricate, and enhance comfort during sexual activity, not to treat or cure a disease or condition.

No

Explanation: The "Intended Use / Indications for Use" section states that VagiVital Aktivgel is a personal lubricant intended to moisturize and lubricate to enhance comfort and supplement natural lubrication. It does not mention any diagnostic purpose.

No

The device description clearly states it is a water-based personal lubricant provided in an aluminum tube, indicating it is a physical product, not software.

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

Here's why:

  • Intended Use: The intended use clearly states it's a personal lubricant for vaginal application to moisturize and lubricate for comfort during sexual activity. This is a physical function, not a diagnostic test performed on samples taken from the body.
  • Device Description: The description lists ingredients that are typical of a lubricant, not reagents or components used for in vitro testing.
  • Performance Studies: The performance studies focus on shelf life, biocompatibility (how it interacts with the body), and condom compatibility. These are relevant to a topical medical device, not an IVD.
  • Lack of Diagnostic Elements: There is no mention of analyzing samples (blood, urine, tissue, etc.), detecting biomarkers, or providing diagnostic information about a disease or condition.

IVD devices are designed to perform tests on samples taken from the human body to provide information for the diagnosis, monitoring, or treatment of diseases or conditions. VagiVital Aktivgel does not fit this description.

N/A

Intended Use / Indications for Use

VagiVital Aktivgel is a personal lubricant for vaginal application intended to moisturize and lubricate, to enhance the ease and comfort of intimate sexual activity and supplement the body's natural lubrication. This product is compatible with polyisoprene condoms. This product is not compatible with natural rubber latex and polyurethane condoms.

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

NUC

Device Description

VagiVital Aktivgel is a water-based personal lubricant containing water, hypromellose, benzoic acid, lactic acid, and sodium hydroxide. VagiVital Aktivgel is provided in a 36 ml aluminum tube and may be packaged together with a reusable applicator.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Vaginal

Indicated Patient Age Range

Not Found

Intended User / Care Setting

Over-The-Counter Use

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)

Shelf life:
VagiVital Aktivgel has a shelf-life of 24 months in accordance with the results of an accelerated aging and real-time stability study. Results from testing demonstrated that the device can maintain its specifications (as shown in Table 1) over the duration of its shelflife.

Biocompatibility:
Biocompatibility studies were performed in accordance with the 2016 FDA guidance document "Use of International Standard ISO 10993-1, Biological Evaluation of Medical Devices - Part 1: Evaluation and testing within a risk management process" and ISO 10993- 1:2009 as follows:

  • Cytotoxicity (ISO 10993-5: 2009)
  • Vaginal Irritation (ISO 10993-10: 2010) .
  • Guinea Pig Maximization Sensitization Test (ISO 10993-10: 2010)
  • Acute Systemic Toxicity (ISO 10993-11: 2006)
    The biocompatibility testing demonstrated that the subject device is non-cytotoxic, nonirritating, non-sensitizing, and not systemically toxic.

Condom Compatibility:
Vagi Vital Aktivgel was tested in accordance with ASTM D7661-10 "Standard Test Method for Determining Compatibility of Personal Lubricants with Natural Rubber Latex Condoms" and was determined to be compatible with polyisoprene condoms. It was determined not to be compatible with natural rubber latex and polyurethane condoms.

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.

K150883

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

§ 884.5300 Condom.

(a)
Identification. A condom is a sheath which completely covers the penis with a closely fitting membrane. The condom is used for contraceptive and for prophylactic purposes (preventing transmission of sexually transmitted infections). The device may also be used to collect semen to aid in the diagnosis of infertility.(b)
Classification. (1) Class II (special controls) for condoms made of materials other than natural rubber latex, including natural membrane (skin) or synthetic.(2) Class II (special controls) for natural rubber latex condoms. The guidance document entitled “Class II Special Controls Guidance Document: Labeling for Natural Rubber Latex Condoms Classified Under 21 CFR 884.5300” will serve as the special control. See § 884.1(e) for the availability of this guidance document.

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, with the letters "FDA" in a blue square. Next to that is the text "U.S. FOOD & DRUG ADMINISTRATION" in blue.

November 10, 2020

Peptonic Medical AB % Jane Campbell President J & D Campbell Associates, Inc. 164 Hammock Ave. Pawleys Island, South Carolina 29585

K200098 Trade/Device Name: VagiVital Aktivgel Regulation Number: 21 CFR§ 884.5300 Regulation Name: Condom Regulatory Class: II Product Code: NUC Dated: September 30, 2020 Received: October 13, 2020

Dear Jane Campbell:

Re:

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, 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.

1

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 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-regulatoryinformation/postmarketing-safety-reporting-combination-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 medical devices and radiation-emitting products, including information about labeling regulations, please see Device (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,

Monica D. Garcia, Ph.D. Assistant Director DHT3B: Division of Reproductive. Gynecology and Urology Devices OHT3: Office of GastroRenal. ObGyn. General Hospital and Urology Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health

Enclosure

2

Indications for Use

510(k) Number (if known) K200098

Device Name VagiVital Aktivgel

Indications for Use (Describe)

Vagi Vital Aktivgel is a personal lubricant for vaginal application intended to moisturize and lubricate, to enhance the ease and comfort of intimate sexual activity and supplement the body's natural lubrication. This product is compatible with polyisoprene condoms. This product is not compatible with natural rubber latex and polyurethane condoms.

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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3

510(K) SUMMARY – K200098

| Applicant: | Peptonic Medical AB
Gustavslundsvägen 143
SE-167 51 Bromma
Sweden
Phone: +46 8 530 20 110 |
|--------------------|-------------------------------------------------------------------------------------------------------|
| Contact Person: | Dan Markusson
Chief Operating Officer
Gustavslundsvägen 143
SE-167 51 Bromma
Sweden |
| Date Prepared: | November 5, 2020 |
| Proprietary Name: | VagiVital Aktivgel |
| Common Name: | Personal Lubricant |
| Regulation Number: | 21 CFR 884.5300 |
| Regulation Name: | Condom |
| Product Code: | NUC (Lubricant, Personal) |
| Regulatory Class: | II |

Predicate Device:

  • HyaloGYN Hydrating Gel, Fidia Farmaceutici, S.p.A. K150883 .
    The predicate device has not been subject to a design-related recall.

4

Device description

VagiVital Aktivgel is a water-based personal lubricant containing water, hypromellose, benzoic acid, lactic acid, and sodium hydroxide. VagiVital Aktivgel is provided in a 36 ml aluminum tube and may be packaged together with a reusable applicator.

Device specifications are listed in the table below:

ParameterSpecification
Appearance/ColorClear gel with
fine visible
particles
OdorOdorless
pH3.6-4.0
Viscosity per USP13800-75000 s
Osmolality per USP32-150 mOsmol/kg
Antimicrobial Effectiveness per
USPCategory 2 per
USP
Total Microbial Count per USP
                                                                                                    |                                                                                                      | 

Pseudomonas aeruginosa
Staphylococcus aureous
Candida albicans | Absent |

Indications for use

VagiVital Aktivgel is a personal lubricant for vaginal application intended to moisturize and lubricate, to enhance the ease and comfort of intimate sexual activity and supplement the body s natural lubrication. This product is compatible with polyisoprene condoms. This product is not compatible with natural rubber latex and polyurethane condoms.

Comparison of Intended Use and Technological Characteristics of the subject and predicate device:

A comparison of the intended use and technological features of the subject and predicate devices is provided in the table below:

| Device & Predicate Device(s): | VagiVital Aktivgel
Subject Device (K200098) | HyloGyn Hydrating Gel
Predicate Device
(K150883) |

---------------------------------------------------------------------------------------------------------------------------------------

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General Device Characteristics
Indications for UseVagiVital Aktivgel is a personal
lubricant for vaginal application
intended to moisturize and
lubricate, to enhance the ease and
comfort of intimate sexual
activity and supplement the
body's natural lubrication. This
product is compatible with
polyisoprene condoms. This
product is not compatible with
natural rubber latex and
polyurethane condoms.HyaloGYN is a personal
lubricant for vaginal
application intended to
mositurize and lubricate,
to enhance the ease and
comfort to intimate
sexual activity and
supplement for body's
natural lubrication. This
product is compatible
with
polyisoprene
condoms.
Primary IngredientsWater
S-lactic acid
Sodium Hydroxide 2M solution
Benzoic Acid
Hydroxypropyl methylcelluloseHyaluronic Acid
(Hydeal-D)
Propylene glycol
Carbopol 974P
(carbomer)
Sodium hydroxide
Purified water
Condom compatibilityCompatible with polyisoprene
condomsCompatible with
polyisoprene
condoms
Base TypeWaterWater
Biocompatibility TestedYesYes
Antimicrobial TestedYesYes

The subject and predicate device have similar indications for use statements and have the same intended use.

The subject device and predicate device have different technological characteristics, including different formulations. The differences in technological characteristics between the subject and predicate devices do not raise different questions of safety and effectiveness.

Summary of Performance Data:

Shelf life:

6

VagiVital Aktivgel has a shelf-life of 24 months in accordance with the results of an accelerated aging and real-time stability study. Results from testing demonstrated that the device can maintain its specifications (as shown in Table 1) over the duration of its shelflife.

Biocompatibility:

Biocompatibility studies were performed in accordance with the 2016 FDA guidance document "Use of International Standard ISO 10993-1, Biological Evaluation of Medical Devices - Part 1: Evaluation and testing within a risk management process" and ISO 10993- 1:2009 as follows:

  • Cytotoxicity (ISO 10993-5: 2009) ●
  • Vaginal Irritation (ISO 10993-10: 2010) .
  • Guinea Pig Maximization Sensitization Test (ISO 10993-10: 2010)
  • . Acute Systemic Toxicity (ISO 10993-11: 2006)

The biocompatibility testing demonstrated that the subject device is non-cytotoxic, nonirritating, non-sensitizing, and not systemically toxic.

Condom Compatibility:

Vagi Vital Aktivgel was tested in accordance with ASTM D7661-10 "Standard Test Method for Determining Compatibility of Personal Lubricants with Natural Rubber Latex Condoms" and was determined to be compatible with polyisoprene condoms. It was determined not to be compatible with natural rubber latex and polyurethane condoms.

Conclusion:

The results of the performance testing described above demonstrate that the VagiVital Aktivgel is as safe and effective as the predicate device and supports a determination of substantial equivalence.