K Number
K202632
Device Name
Electric wheelchair (S7204/S7205)
Date Cleared
2021-04-08

(209 days)

Product Code
Regulation Number
890.3860
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The device is a power wheelchair intended to provide mobility to persons restricted to a sitting position.
Device Description
The Electric wheelchair (Model S7204, S7205) is a power wheelchair intended to provide mobility to persons restricted to a sitting position. The Electric wheelchair (Model S7204, S7205) is about 136 kg weight capacity. It is basic conventional rear wheels drive, rigid frame vehicle that are battery powered. It consists primarily of a welded-aluminum frames, sealed transaxle motors drive system, electromagnetic braking system, electric motor controller and Li-ion batteries with an off-board battery charger. It is powered by rechargeable batteries with 45 km which maximum speed up to 7 km/h. The controller with a joystick attaches to either armrest and allows the rider to control the movement and velocity of the powered wheelchair. When the joystick is released. the electromagnetic brake will be actuated and the power wheelchair is slow to stop. It consists of three parts which are chair part, control part and drive part. Overall it mainly has a basic aluminum alloy frame, two front wheels, two rear wheels, two anti-tip wheels, a seat, a footrest, an controller, an electric motor, an electromagnetic brake and a Lithium battery with an off-board charger. The result of "tiltover" tests performed laterally (12° ), posteriorly (16° ), and anteriorly (12° ) with a user of maximum allowable weight in the least stable configuration: No overturn performed laterally, posteriorly, and anteriorly with 136kg in the least stable configuration.
More Information

No
The description details a conventional power wheelchair with standard components and control mechanisms, with no mention of AI or ML.

No

Explanation: The device is described as a power wheelchair intended to provide mobility, not to treat or cure a disease or condition, which is the primary function of a therapeutic device.

No

The device description explicitly states its purpose is "to provide mobility to persons restricted to a sitting position." There is no mention of it being used to detect, diagnose, monitor, or treat any medical condition; it is solely a mobility aid.

No

The device description clearly outlines numerous hardware components including a frame, wheels, motors, batteries, brakes, and a joystick controller. The performance studies also reference standards related to the physical characteristics and safety of wheelchairs, not solely software.

No, this device is not an IVD (In Vitro Diagnostic).

Here's why:

  • IVD Definition: In Vitro Diagnostics are medical devices used to perform tests on samples taken from the human body (like blood, urine, tissue) to provide information about a person's health.
  • Device Description: The provided description clearly states the device is a "power wheelchair intended to provide mobility to persons restricted to a sitting position." It describes a mechanical and electrical device for transportation and mobility.
  • Intended Use: The intended use is for mobility, not for testing biological samples.
  • Lack of IVD Characteristics: The description does not mention any components or functions related to collecting, analyzing, or testing biological samples.

Therefore, based on the provided information, the device is a mobility aid, not an In Vitro Diagnostic.

N/A

Intended Use / Indications for Use

The device is a power wheelchair intended to provide mobility to persons restricted to a sitting position.

Product codes

ITI

Device Description

The Electric wheelchair (Model S7204, S7205) is a power wheelchair intended to provide mobility to persons restricted to a sitting position.

The Electric wheelchair (Model S7204, S7205) is about 136 kg weight capacity. It is basic conventional rear wheels drive, rigid frame vehicle that are battery powered. It consists primarily of a welded-aluminum frames, sealed transaxle motors drive system, electromagnetic braking system, electric motor controller and Li-ion batteries with an off-board battery charger. It is powered by rechargeable batteries with 45 km which maximum speed up to 7 km/h. The controller with a joystick attaches to either armrest and allows the rider to control the movement and velocity of the powered wheelchair. When the joystick is released. the electromagnetic brake will be actuated and the power wheelchair is slow to stop.

It consists of three parts which are chair part, control part and drive part. Overall it mainly has a basic aluminum alloy frame, two front wheels, two rear wheels, two anti-tip wheels, a seat, a footrest, an controller, an electric motor, an electromagnetic brake and a Lithium battery with an off-board charger. The result of "tiltover" tests performed laterally (12° ), posteriorly (16° ), and anteriorly (12° ) with a user of maximum allowable weight in the least stable configuration: No overturn performed laterally, posteriorly, and anteriorly with 136kg in the least stable configuration.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Not Found

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

The following performance and safety tests were conducted with Electric wheelchair:

· ISO 7176-1: 2014, Wheelchairs - Part 1: Determination of static stability

• ISO 7176-2: Third edition 2017-10, Wheelchairs - Part 2:Determination of dynamic stability of electrically powered wheelchairs

• ISO 7176-3: 2012, Wheelchairs - Part 3: Determination of effectiveness of brakes

• ISO 7176-4: Third edition 2008-10-01, Wheelchairs - Part 4: Energy consumption of electric wheelchairs and scooters for determination of theoretical distance range

· ISO 7176-5: Second edition 2008-06-01, Wheelchairs - Part 5: Determination of overall dimensions, mass and manoeuvring space

• ISO 7176-6: Third edition 2018-06 Wheelchairs - Part 6: Determination of maximum speed, acceleration and deceleration of electric wheelchairs

• ISO 7176-7: First Edition 1998-05-15, Wheelchairs - Part 7: Measurement of seating and wheel dimensions

• ISO 7176-8: 2014, Wheelchairs - Part 8: Requirements and test methods for static, impact and faligue strenaths

· ISO 7176-9: 2009, Wheelchairs - Part 9: Climatic tests for Powered Wheelchairs

• ISO 7176-10: 2008, Wheelchairs - Part 10: Determination of obstacle-climbing ability of electrically powered wheelchairs

• ISO 7176-11: Second edition 2012-12-01. Wheelchairs - Part 11: Test dummies

• ISO 7176-13: First edition 1989-08-01, Wheelchairs - Part 13: Determination of coefficient of friction of test surfaces

• ISO 7176-14: 2008, Wheelchairs - Part 14: Power and control systems for electrically powered wheelchairs and scooters - Requirements and test methods

• ISO 7176-15: 1996, Wheelchairs - Part 15: Requirements for information disclosure, documentation and labeling

• ISO 7176-16: Second edition 2012-12-01, Wheelchairs - Part 16: Resistance to ignition of postural support devices

• ISO 7176-21: Second edition 2009-04-01 Wheelchairs - Part 21: Requirements and test methods for electromagnetic compatibility of electrically powered wheelchairs and battery chargers

• ISO 7176-22: Second Edition 2014-09-01 Wheelchairs - Part 22: Set-Up Procedures

· IEC 62304: 2006 (First Edition), Medical device software. Software life- cycle processes

• IEC 60601-1-6: Medical electrical equipment- Part1-6: General requirements for safety- Collateral Standard: Usability Edition 3.0, 2010

• IEC 62366 Medical devices – Application of usability engineering to medical devices Edition 1.0, 2007

The materials and manufacturing used for the Electric wheelchair are identical to those of the predicate device K122749, which were demonstrated to conform with the following biocompatibility standards:

• ISO 10993-5:2009, Biological evaluation of medical devices - Part 5: Tests for In Vitro cytotoxicity

• ISO 10993-10: 2009, Biological evaluation of medical devices - Part 10: Tests for irritation and delayed-type hypersensitivity

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

Not Found

Predicate Device(s)

K173315, K123290

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 890.3860 Powered wheelchair.

(a)
Identification. A powered wheelchair is a battery-operated device with wheels that is intended for medical purposes to provide mobility to persons restricted to a sitting position.(b)
Classification. Class II (performance standards).

0

Image /page/0/Picture/0 description: The image contains the logo of the U.S. Food and Drug Administration (FDA). The logo consists of two parts: the Department of Health & Human Services logo on the left and the FDA logo on the right. The FDA logo features the letters 'FDA' in a blue square, followed by the words 'U.S. FOOD & DRUG ADMINISTRATION' in blue text.

April 8, 2021

Dongguan Prestige Sporting Goods Co., Ltd. % Cassie Lee Manager Guangzhou GLOMED Biological Technology Co., Ltd. 2231, Building 1, Rui Feng Center, Kaichuang Road Huangpu District Guangzhou, Guangdong 510663 China

Re: K202632

Trade/Device Name: Electric wheelchair, Models: S7204, S7205 Regulation Number: 21 CFR 890.3860 Regulation Name: Powered Wheelchair Regulatory Class: Class II Product Code: ITI Dated: January 8, 2021 Received: January 11, 2021

Dear Cassie Lee:

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/cfpm/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.

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-regulatory-information/postmarketing-safety-reportingcombination-products); good manufacturing practice requirements as set forth in the quality systems (QS) 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 53 1 -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.

Heather L. Dean -S

Heather Dean, PhD Assistant Director. Acute Injurv Devices Team DHT5B: Division of Neuromodulation and Physical Medicine Devices OHT5: Office of Neurological and Physical Medicine Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health

2

Indications for Use

510(k) Number (if known) K202632

Device Name Electric wheelchair, Models: S7204, S7205

Indications for Use (Describe)

The device is a power wheelchair intended to provide mobility to persons restricted to a sitting position.

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

This summary of 510(K) safety and effectiveness information is being submitted in accordance with the requirement of 21 CFR 807.92.

1. Submitter's Information

  • � 510(k) Owner's Name: Dongguan Prestige Sporting Goods Co., Ltd
  • Establishment Registration Number: 3008841035 �
  • � Address: 3rd industrial, Qiaotou Area, Houjie Town, Dongguan City, Guangdong province, China, 523950
  • � Tel: 13763128800
  • � Fax: 86-769-85922505
  • Contact Person: Zhang Zhao (General Manager) �
  • � E-mail: leon@solaxtech.com

Application Correspondent:

  • Contact Person: Ms. Cassie Lee �
  • � Guangzhou GLOMED Biological Technology Co., Ltd.
  • � Address: 2231, Building 1, Rui Feng Center, Kaichuang Road, Huangpu District, Guangzhou, Guangdong, China
  • � Tel: +86 20 8266 2446
  • � Email: regulatory@glomed-info.com

2. Subject Device Information

  • � Trade Name: Electric wheelchair, Model: S7204, S7205
  • Powered Wheelchair Common Name: �
  • Wheelchair, Powered Classification name: �
  • Physical Medicine Device Review Panel: �
  • ITI Product Code: �
  • ll Regulation Class: �
  • 890.3860 � Regulation Number:

4

3. Predicate Device Information

  • � Sponsor: Eurogreen International Inc.
  • � Device Trade name: "SupaChair" Powered Wheelchair: Safari, Safari Sport, Mini
  • Common name: Powered Wheelchair �
  • � Classification name: Wheelchair, Powered
  • � 510K Number: K173315
  • � Medical specialty (Panel): Physical Medicine Device
  • Requlation number: 890,3860 �
  • Product Code: ITI �
  • � Classification: Class II

Predicate Device 2

  • Sponsor: Permobil AB �
  • � Device Trade name: M300 & M400
  • � Common name: Powered Wheelchair
  • � Classification name: Wheelchair, Powered
  • 510K Number: K123290
  • Medical specialty (Panel): Physical Medicine Device �
  • � Regulation number: 890.3860
  • � Product Code: ITI
  • � Classification: Class II

Device Description ব

The Electric wheelchair (Model S7204, S7205) is a power wheelchair intended to provide mobility to persons restricted to a sitting position.

The Electric wheelchair (Model S7204, S7205) is about 136 kg weight capacity. It is basic conventional rear wheels drive, rigid frame vehicle that are battery powered. It consists primarily of a welded-aluminum frames, sealed transaxle motors drive system, electromagnetic braking system, electric motor controller and Li-ion batteries with an off-board battery charger. It is powered by rechargeable batteries with 45 km which maximum speed up to 7 km/h. The controller with a joystick attaches to either armrest and allows the rider to control the movement and velocity of the powered wheelchair. When the joystick is released. the electromagnetic brake will be actuated and the power wheelchair is slow to stop.

It consists of three parts which are chair part, control part and drive part. Overall it mainly has a basic aluminum alloy frame, two front wheels, two rear wheels, two anti-tip wheels, a seat, a footrest, an controller, an electric motor, an electromagnetic brake and a Lithium battery with an off-board charger. The result of "tiltover" tests performed laterally (12° ), posteriorly (16° ), and anteriorly (12° ) with a user of maximum allowable weight in the least stable configuration: No overturn performed laterally, posteriorly, and anteriorly with 136kg in the least stable configuration.

5

5. Intended Use / Indications for Use

The device is a power wheelchair intended to provide mobility to persons restricted to a sitting position

6. Tests Summary

The following performance and safety tests were conducted with Electric wheelchair:

· ISO 7176-1: 2014, Wheelchairs - Part 1: Determination of static stability

• ISO 7176-2: Third edition 2017-10, Wheelchairs - Part 2:Determination of dynamic stability of electrically powered wheelchairs

• ISO 7176-3: 2012, Wheelchairs - Part 3: Determination of effectiveness of brakes

• ISO 7176-4: Third edition 2008-10-01, Wheelchairs - Part 4: Energy consumption of electric wheelchairs and scooters for determination of theoretical distance range

· ISO 7176-5: Second edition 2008-06-01, Wheelchairs - Part 5: Determination of overall dimensions, mass and manoeuvring space

• ISO 7176-6: Third edition 2018-06 Wheelchairs - Part 6: Determination of maximum speed, acceleration and deceleration of electric wheelchairs

• ISO 7176-7: First Edition 1998-05-15, Wheelchairs - Part 7: Measurement of seating and wheel dimensions

• ISO 7176-8: 2014, Wheelchairs - Part 8: Requirements and test methods for static, impact and faligue strenaths

· ISO 7176-9: 2009, Wheelchairs - Part 9: Climatic tests for Powered Wheelchairs

• ISO 7176-10: 2008, Wheelchairs - Part 10: Determination of obstacle-climbing ability of electrically powered wheelchairs

• ISO 7176-11: Second edition 2012-12-01. Wheelchairs - Part 11: Test dummies

• ISO 7176-13: First edition 1989-08-01, Wheelchairs - Part 13: Determination of coefficient of friction of test surfaces

• ISO 7176-14: 2008, Wheelchairs - Part 14: Power and control systems for electrically powered wheelchairs and scooters - Requirements and test methods

• ISO 7176-15: 1996, Wheelchairs - Part 15: Requirements for information disclosure, documentation and labeling

• ISO 7176-16: Second edition 2012-12-01, Wheelchairs - Part 16: Resistance to ignition of postural support devices

• ISO 7176-21: Second edition 2009-04-01 Wheelchairs - Part 21: Requirements and test methods for electromagnetic compatibility of electrically powered wheelchairs and battery chargers

• ISO 7176-22: Second Edition 2014-09-01 Wheelchairs - Part 22: Set-Up Procedures

· IEC 62304: 2006 (First Edition), Medical device software. Software life- cycle processes

• IEC 60601-1-6: Medical electrical equipment- Part1-6: General requirements for safety- Collateral Standard: Usability Edition 3.0, 2010

• IEC 62366 Medical devices – Application of usability engineering to medical devices Edition 1.0, 2007

The materials and manufacturing used for the Electric wheelchair are identical to those of the predicate device K122749, which were demonstrated to conform with the following biocompatibility standards:

• ISO 10993-5:2009, Biological evaluation of medical devices - Part 5: Tests for In Vitro cytotoxicity

• ISO 10993-10: 2009, Biological evaluation of medical devices - Part 10: Tests for irritation and delayed-type hypersensitivity

6

7. Comparison to predicate device and conclusion

The technological characteristics, features, specifications, materials, mode of operation, and intended use of Electric wheelchair is substantially equivalent to the predicate devices quoted above. The differences between the subject device and predicate devices do not raise new issues of safety or effectiveness.

| Elements of

ComparisonSubject DevicePredicate Device 1Predicate Device 2Remark
CompanyDongguan Prestige
Sporting Goods Co.,
Ltd.Eurogreen International
Inc.Permobil AB--
Trade NameElectric wheelchair"SupaChair" Powered
Wheelchair: Safari,
Safari Sport, Mini
SafariM300 & M400--
ModelS7204, S7205------
Classification
NameWheelchair, PoweredWheelchair, PoweredWheelchair, PoweredSE
510K
NumberK202632K173315K123290--
Product
CodeITIITIITISE
Common or
Usual namePowered WheelchairPowered WheelchairPowered WheelchairSE
Intended
use/Indications for UseThe device is a power
wheelchair intended to
provide mobility to
persons restricted to a
sitting position.The device is a power
wheelchair intended to
provide mobility to
persons restricted to a
sitting position.The intended use of
the M300 & M400
powered wheelchair is
to provide outdoor and
indoor mobility to
persons limited to a
seated position that
are capable of
operating a powered
wheelchair.SE
SizeFor model S7204:
1000mm x 680mm x
1330mm
For model S7205:
1000mm x 700mm x
1340mm870mm600mm840mm1256 mm x 620mm x
1260 mmSE
Note 1
Overall
lengthFor model S7204:
1000mm
For model S7205:
1000mm870mm1256 mmSE
Note 1
Overall widthFor model S7204:
680mm
For model S7205:
700mm600mm620mmSE
Note 1
Total massFor model S7204:
150kg approx.
For model S7205:
145kg approx.37.7kg155kg (342 lbs)SE
Note 1
Mass of
heaviest partFor model S7204:
134kg approx.
For model S7205:
129kg approx.17.9kgNot publicSE
Note 1
Effective seat
depth480mm400mmNot publicSE
Note 1
Effective seat
width520mm410mmNot publicSE
Note 1
Back support
height810mm370mmNot publicSE
Note 1
Front of arm
support to
back support250mm200mmNot publicSE
Note 1
Minimum
turning
diameter1200mm700mmNot publicSE
Note 1
Tires6" for front wheel
(solid wheel)
14" for middle wheel
(solid wheel)
6" for rear wheel (solid
wheel)Drive wheels size:
200mm (8")
Caster wheels size:
178mm (7")Caster wheel: 200x50
mm
Drive wheel: 3.00-8"SE
Note 1
Speed7km/h(4.3mph)6.5kph (4mph)Up to 12 km/h (7,5
mph)SE
Note 2
Safe
Gradient /
Maximum
Gradient10°Not publicSE
Note 2
Range45kmSLA: 10km
Lithium: 16.5kmUp to 25 kmSE
Note 2
Turning
Radius700mm700mm800mmSE
Base weight
(not including
battery)For model S7204:
134kg approx.
For model S7205:
129kg approx.28.5kgNot publicSE
Note 1
Battery
weight16 kgSLA: 9.2kg
Lithium: 4kgNot publicSE
Note 1
BrakeElectromagneticElectromagneticElectronic braking via
drive motors and
magneticSE
Drive systemDynamicDynamicNot publicSE
Maximum
capacity136 kg150 kg136 kgSE
Ground
clearance50mm70mm77 mmSE
Note 2
Minimum
Braking Time1.54sNot publicNot publicSE
Note 4
Minimum
Braking
Distance1.5mNot publicNot publicSE
Note 4
Brake
distance-
Normal
operation
(Horizontal-
Forward-Max
speed)1.5-1.8m1.0-1.5mNot publicSE
Note 4
BatteryLi-ion Battery 25.2V
30AH*2SLA/Lithium: 24V 15AhNot publicSE
Note 3
charger24V 15ASLA: 2A off board
Lithium: 4A off boardNot publicSE
Note 3
Frame
designRigid frameRigid frameNot publicSE
MaterialAluminumAluminumNot publicSE
Biocompatibil
ityAll user directly
contacting materials
are compliance with
ISO10993-5 and
ISO10993-10
requirements.All user directly
contacting materials are
compliance with
ISO10993-5 and
ISO10993-10
requirements.Not publicSE
Electrical
SafetyISO 7176 seriesISO 7176 seriesISO 7176 seriesSE
EMCISO 7176 - 21ISO 7176 - 21ISO 7176 - 21SE

7

8

Comparison in Detail(s):

Note 1:

Although "Size", "Overall width", "Stowage length", "Stowage width", "Stowage height", "Mass of heaviest part" "Total mass", "Effective seat width", "Back support height", "Effective seat depth", "Minimum turning diameter", "Tires", "Base weight", "Front of arm support to back support" and "Battery weight" which are parameters required in ISO 7176-5 and ISO 7176-7 of the subject device are different from the predicate devices, however, these are some mechanical parameters, and they are very similar, Besides, the subtle changes of the physical characteristics will not affect the critical functions or the normal use, so these parameters' differences will not raise any safety or effectiveness issue.

Note 2:

Although the "Speed", " Safe Gradient / Maximum Gradient", " Range", " Ground clearance" of the subject device are different from the predicate device, as they very similar and all also comply with ISO 7176 series standards requirements, it will not affect the main function and the intended use of the device, so these parameters' differences will not raise any safety or effectiveness issue.

Note 3:

Although the "Battery", "Charger" of the subject device are a little different from the predicate device, but both of them are comply with the standards IEC 62133, it will not raise any safety or effectiveness issue.

9

Note 4:

Although the "Minimum Braking Time", "Minimum Braking Distance" and "Brake distance-Normal operation (Horizontal-Forward-Max speed)" of the subject device are a little different from the predicate device, but both of them are comply with the standards ISO 7176-3, it will not raise any safety or effectiveness issue.

Final Conclusion:

The subject device Electric wheelchair (Model: S7204, S7205) is Substantial Equivalent to the predicate devices K173315 and K123290.

8. Date of the summary prepared

March 11, 2021