(50 days)
The Laser Therapy Device is intended for hair removal, permanent hair reduction on all skin types (Fitzpatrick skin type I-VI), including tanned skin.
Permanent hair reduction is defined as the long-term, stable reduction in the number of hairs regrowing when measured at 6, 9, and 12 months after the completion of a treatment regime.
The Laser Therapy Device is a surgical device intended for use in dermatologic and general surgical procedure. It utilizes a diode laser source (808 nm). The laser power is delivered to the treatment area via a laser hand piece. The emission laser is activated by a foot switch and a hand piece. The components of the Laser Therapy Device are mainly including main unit, hand piece, watered cup, overflow tube, foot switch, key, interlock, power cord, fuse, glasses and blindfold, etc.
The proposed Laser Therapy Device is equipped with laser depilation function that is based on the theory of selective photo thermolysis. There is abundant melanin in hair follicle and hair stem. The melanin is distributed amidst the cells between the hair ball substrate and it can be transferred to the structure of hair stems (such as medulla, cortex and hair cuticle). The laser can precisely target at the melanin and apply the depilation treatment selectively. After the melanin absorbs laser energy, the temperature rises, in this way, the surrounding hair follicle tissues are damaged, and the hairs are removed.
This document is a 510(k) premarket notification for a Laser Therapy Device. It does not contain information about a study that proves the device meets specific acceptance criteria in the way typically found for algorithms or AI-driven diagnostic devices (e.g., sensitivity, specificity, AUC). Instead, it demonstrates substantial equivalence to predicate devices through technical comparisons and non-clinical testing against recognized standards.
Therefore, many of the requested fields regarding acceptance criteria and performance studies are not applicable or cannot be extracted from this type of regulatory submission.
Here's a breakdown of the information that can be extracted or inferred:
1. Table of Acceptance Criteria and Reported Device Performance
Generally, for a 510(k) for a physical medical device like a laser, acceptance criteria often revolve around meeting recognized safety and performance standards, and demonstrating substantial equivalence to a predicate device in terms of intended use and technological characteristics. The "performance" reported is adherence to these standards and similarity to predicates.
| Acceptance Criteria (Derived from Standards/Predicate Comparison) | Reported Device Performance |
|---|---|
| Electrical Safety: Comply with ANSI/AAMI ES60601-1, IEC 60601-2-22 | Complies with ANSI/AAMI ES60601-1, IEC 60601-2-22 |
| EMC: Comply with IEC 60601-1-2 | Complies with IEC 60601-1-2 |
| Laser Safety: Comply with IEC 60601-2-22, IEC 60825 | Complies with IEC 60601-2-22, IEC 60825 |
| Biocompatibility (Cytotoxicity): No Cytotoxicity | No Cytotoxicity (per ISO 10993-5) |
| Biocompatibility (Sensitization): No evidence of sensitization | No evidence of sensitization (per ISO 10993-10) |
| Biocompatibility (Irritation): No evidence of irritation | No evidence of irritation (per ISO 10993-10) |
| Spot Size Accuracy | Performance Testing for Spot Size Accuracy was conducted. (Result not detailed beyond "met all design specifications") |
| Energy Output Accuracy | Performance Testing for Energy Output Accuracy was conducted. (Result not detailed beyond "met all design specifications") |
| Software Verification and Validation (if applicable) | Conducted per "Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices", with Moderate level of concern. |
| Intended Use Equivalence: Hair removal, permanent hair reduction on all skin types (Fitzpatrick skin type I-VI), including tanned skin. | "The Laser Therapy Device is intended for hair removal, permanent hair reduction on all skin types (Fitzpatrick skin type I-VI), including tanned skin." Stated as same as predicate. |
| Technological Characteristics Equivalence: Similar fluence, laser wavelength, spot size, pulse duration etc. to predicates. | Detailed comparison table shows substantial equivalence or justified differences for all key parameters. |
2. Sample size used for the test set and the data provenance
- Not applicable / Not explicitly stated. This document describes non-clinical testing (electrical safety, EMC, laser safety, biocompatibility, and performance testing for accuracy), not a clinical trial with a "test set" of patient data. The "test set" in this context refers to hardware tests.
3. Number of experts used to establish the ground truth for the test set and the qualifications of those experts
- Not applicable / Not explicitly stated. This document covers regulatory compliance for a physical medical device, not a diagnostic algorithm requiring expert "ground truth" labeling of data.
4. Adjudication method for the test set
- Not applicable. This concept primarily applies to clinical studies or algorithm performance evaluations where expert consensus confirms labels.
5. If a multi reader multi case (MRMC) comparative effectiveness study was done, If so, what was the effect size of how much human readers improve with AI vs without AI assistance
- No. This document is for a laser therapy device, not an AI or diagnostic imaging device that would typically undergo an MRMC study.
6. If a standalone (i.e. algorithm only without human-in-the loop performance) was done
- Not applicable. This device is a physical laser therapy device, not an algorithm.
7. The type of ground truth used
- For the non-clinical tests (e.g., electrical safety, EMC, laser safety, biocompatibility), the "ground truth" is adherence to established regulatory standards (e.g., IEC, ISO) and internal design specifications.
- For the claim of "permanent hair reduction," this definition serves as the clinical outcome benchmark, but no clinical study was included in this submission to demonstrate the proposed device meets this definition. Instead, it relies on substantial equivalence to predicates that are already cleared for this indication.
8. The sample size for the training set
- Not applicable. This is not an AI/machine learning device.
9. How the ground truth for the training set was established
- Not applicable. This is not an AI/machine learning device.
Summary of the Study:
The "study" described in the 510(k) submission for the Shenzhen Leaflife Technology Co., Ltd Laser Therapy Device primarily consists of non-clinical testing to demonstrate compliance with recognized medical device safety and performance standards, and a comparison of technological characteristics to legally marketed predicate devices.
- Non-Clinical Tests: These included Electrical Safety (ANSI/AAMI ES60601-1, IEC 60601-2-22), EMC (IEC 60601-1-2), Laser Safety (IEC 60601-2-22, IEC 60825-1), Biocompatibility (ISO 10993-5 for Cytotoxicity, ISO 10993-10 for Irritation and Sensitization), and Performance Testing for Spot Size Accuracy and Energy Output Accuracy.
- Software Verification and Validation: Conducted for the device's software, determining a "Moderate" level of concern.
- Substantial Equivalence Comparison: The document extensively compares the proposed device's intended use, principle of operation, laser type, wavelength, spot size, irradiance, fluence, frequency, and pulse duration to those of two predicate devices (K162659 and K180353).
Conclusion drawn from the study:
The non-clinical tests verified that the proposed device met all design specifications and complied with the listed standards. Based on the comparison and analysis, the proposed device was determined to be "as safe, as effective, and performs as well as the legally marketed predicate devices," thereby establishing substantial equivalence. No clinical studies were included in this submission.
{0}------------------------------------------------
Image /page/0/Picture/0 description: The image shows 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 is in blue and includes the letters "FDA" followed by the words "U.S. Food & Drug Administration".
November 19, 2020
Shenzhen Leaflife Technology Co., Ltd Albert Ou Regulatory Affairs Manager Bldg. C, JMD Industrial Park, No.39 Qingfeng Blvd., Baolong Industrial Area, Longgang District Shenzhen, Shenzhen 518116 China
Re: K202980
Trade/Device Name: Laser Therapy Device Regulation Number: 21 CFR 878.4810 Regulation Name: Laser Surgical Instrument For Use In General And Plastic Surgery And In Dermatology Regulatory Class: Class II Product Code: GEX Dated: September 27, 2020 Received: September 30, 2020
Dear Albert Ou:
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.
{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 and Part 809); 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 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 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.
Purva Pandya Acting Assistant Director DHT4A: Division of General Surgery Devices OHT4: Office of Surgical and Infection Control Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health
Enclosure
{2}------------------------------------------------
Indications for Use
510(k) Number (if known) K202980
Device Name Laser Therapy Device
Indications for Use (Describe)
The Laser Therapy Device is intended for hair removal, permanent hair reduction on all skin types (Fitzpatrick skin type I-VI), including tanned skin.
Permanent hair reduction is defined as the long-term, stable reduction in the number of hairs regrowing when measured at 6, 9, and 12 months after the completion of a treatment regime.
| 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) |
CONTINUE ON A SEPARATE PAGE IF NEEDED.
This section applies only to requirements of the Paperwork Reduction Act of 1995.
DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.
The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to:
Department of Health and Human Services Food and Drug Administration Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff PRAStaff@fda.hhs.gov
"An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB number."
{3}------------------------------------------------
510(k) Summary
In accordance with 21 CFR 807.92 the following summary of information is provided:
l. SUBMITTER
Shenzhen Leaflife Technology Co., Ltd C-401, C-402, C-403, Bldg. C, JMD Industrial Park, No.39 Qingfeng Blvd., Baolong Industrial Area, Longgang Dist., Shenzhen, RP China Phone: 086-(0)17875910506 Fax: 086-0755-27215592
| Primary Contact Person: | Albert Ou |
|---|---|
| Regulatory Affairs Manager | |
| Shenzhen Leaflife Technology Co., Ltd | |
| Phone: 086-(0)13751890680 | |
| Email: Owen_newhorizon@outlook.com | |
| Secondary Contact Person: | Cheng Qiang |
| Regulatory registration supervisor | |
| Shenzhen Leaflife Technology Co., Ltd |
Tel: 086-0755-27216609
Fax: 086-0755-27215592
Email: cq@leaflife.cn
Date Prepared:
11/18/2020
{4}------------------------------------------------
II. PROPOSED DEVICE
| Trade Name: | Laser Therapy Device |
|---|---|
| Common Name: | Powered Laser Surgical Instrument |
| Classification Name: | Laser surgical instrument for use in general and plasticsurgery and in dermatology (21 CFR 878.4810) |
| Regulation Class: | II |
| Product Code: | GEX |
| Review Panel: | General & Plastic Surgery |
III. PREDICATE DEVICE
| Predicate device 1# | Diode Laser Hair Removal System, Model HM-DL100:K162659, Manufacturer: Shandong Huamei TechnologyCo., Ltd |
|---|---|
| Predicate device 2# | Diode laser hair removal device, Model PZ-806NVA:K180353, Manufacturer: Zhengzhou PZ Laser SlimTechnology Co., Ltd |
The predicate has not been subject to a design-related recall.
IV. DEVICE DESCRIPTION
The Laser Therapy Device is a surgical device intended for use in dermatologic and general surgical procedure. It utilizes a diode laser source (808 nm). The laser power is delivered to the treatment area via a laser hand piece. The emission laser is activated by a foot switch and a hand piece. The components of the Laser Therapy Device are mainly including main unit, hand piece, watered cup, overflow tube, foot switch, key, interlock, power cord, fuse, glasses and blindfold, etc.
The proposed Laser Therapy Device is equipped with laser depilation function that is based on the theory of selective photo thermolysis. There is abundant melanin in hair follicle and hair stem. The melanin is distributed amidst the cells between the hair ball substrate and it can be transferred to the structure of hair stems (such as medulla, cortex and hair cuticle). The laser can precisely target at the melanin and apply the depilation treatment selectively. After the melanin absorbs laser energy, the temperature rises, in this way, the surrounding hair follicle tissues are damaged, and the hairs are removed.
{5}------------------------------------------------
Image /page/5/Picture/1 description: The image shows the logo for LEAFLIFE, which is written in blue font. Above the word LIFE is a green leaf. To the right of the logo is the number K202980 in black font.
V. INDICATIONS for USE
The Laser Therapy Device is intended for hair removal, permanent hair reduction on all skin types (Fitzpatrick skin type I-VI), including tanned skin.
Permanent hair reduction is defined as the long-term, stable reduction in the number of hairs regrowing when measured at 6, 9, and 12 months after the completion of a treatment regime.
vi. COMPARISON OF TECHNOLOGICAL CHARACTERISTICS WITH THE PREDICATE DEVICE
The Laser Therapy Device (LM-L808A) has same intended use, and technological characteristics such as fluence, laser wavelength, spot size, and pulse duration, etc. with the predicates. Please refer to the following table for details:
{6}------------------------------------------------
Image /page/6/Figure/0 description: The image shows the logo for LEAFLIFE. The logo is composed of the word "LEAFLIFE" in blue and green, with a green leaf above the "I" in "LIFE". Below the word "LEAFLIFE" is some text in another language. The logo is simple and modern, and it conveys a sense of nature and sustainability.
| Item | Proposed Device | Predicate DeviceK162659 | Predicate DeviceK180353 | Remark |
|---|---|---|---|---|
| Device name | Laser Therapy Device | Diode Laser Hair Removal System | Diode laser hair removal device | / |
| Product model | LM-L808A | HM-DL100 | PZ-806NVA | / |
| K number | On pending | K162659 | K180353 | / |
| Product code | GEX | GEX | GEX | SE |
| Classificationregulation | 21 CFR 878.4810 | 21 CFR 878.4810 | 21 CFR 878.4810 | SE |
| Intended Use | The Laser Therapy Device isintended for hair removal,permanent hair reduction on allskin types (Fitzpatrick skin typeI-VI), including tanned skin.Permanent hair reduction isdefined as the long-term, stablereduction in the number of hairsregrowing when measured at 6,9, and 12 months after thecompletion of a treatmentregime. | The Diode Laser System is intendedfor hair removal, permanent hairreduction on all skin types(Fitzpatrick skin type I-VI), includingtanned skin.Permanent hair reduction is definedas the long-term, stable reduction inthe number of hairs regrowingwhen measured at 6, 9, and 12months after the completion of atreatment regime. | The Diode Laser Hair Removaldevice is intended for hair removal,permanent hair reduction on all skintypes (Fitzpatrick skin type I-VI),including tanned skin.Permanent hair reduction is definedas the long-term, stable reduction inthe number of hairs regrowingwhen measured at 6, 9, and 12months after the completion of atreatment regime. | SE |
| Prescription use ornot | Prescription use | Prescription use | Prescription use | SE |
| Configuration | Main UnitHand piece | Main UnitHandpiece | Main UnitHandpiece | SE |
| Item | Proposed Device | Predicate DeviceK162659 | Predicate DeviceK180353 | Remark |
| Foot Control | Foot Control | Foot Control | SE | |
| Principle ofOperation | Diode laser | Diode laser | Diode laser | SE |
| Laser Type | Diode laser | Diode laser | Diode laser | SE |
| Laser Classification | Class IV | Class IV | Class IV | SE |
| Laser Wavelength | 808 nm | 808 nm | 808 nm | SE |
| Spot size | 1.44cm² | 1.44cm² | 1.44cm² | SE |
| Irradiance | 360 W/cm² | 0.7-347.8 W/cm² | 14-360 W/cm² | SE |
| Fluence | 1-100J/cm² | 1-120J/cm² | 1-100J/cm² | SE |
| Frequency | 1-10Hz | 0.5-15Hz | 1-20Hz | Discussion |
| Pulse Duration | 5-400ms | 5-400ms | 10-400ms | SE |
| Power Supply | AC 220 | AC 110V/60Hz | AC 110V-230V/50-60Hz2000VA | Discussion |
| Dimension | 650mm x 430mm x 315mm | 450mm x 550mm x 380mm | 560mm x 380mm x 1180mm | Discussion |
| Weight | 22kg | 52kg | 60kg | Discussion |
{7}------------------------------------------------
Image /page/7/Figure/0 description: The image shows the logo for LEAFLIFE. The logo features the word "LEAFLIFE" in blue, with a green line running through the middle of the letters. Above the word is a green leaf and a blue arc. Below the word is the Chinese translation of the word.
{8}------------------------------------------------
Image /page/8/Picture/0 description: The image shows the logo for LEAFLIFE. The logo is in blue and green, with the word "LEAFLIFE" in blue, with a green line through the middle of the word. Above the word is a green leaf, and below the word is a blue curved line. Below the blue curved line are two Chinese characters.
Discussion
The proposed device is different in frequency range, power supply, dimension and weight from the predicate device.
{9}------------------------------------------------
Image /page/9/Picture/0 description: The image shows the logo for LEAFLIFE. The logo is blue and green, and it features a stylized leaf. The text "LEAFLIFE" is in blue, with a green line above it. Below the text is some smaller text in a different language. The logo is simple and modern, and it conveys a sense of nature and health.
| ltem | Proposed Device | Predicate DeviceK162659 | Predicate DeviceK180353 | Remark |
|---|---|---|---|---|
| Patient Contact Materials and Biocompatibility | ||||
| Patient ContactMaterials | Sapphire in handpiece | Sapphire in handpiece | Sapphire in handpiece | SE |
| Cytotoxicity | No Cytotoxicity | No Cytotoxicity | No Cytotoxicity | SE |
| Sensitization | No evidence of sensitization | No evidence of sensitization | No evidence of sensitization | SE |
| Irritation | No evidence of irritation | No evidence of irritation | No evidence of irritation | SE |
| EMC, Electrical and Laser Safety | ||||
| Electrical Safety | Comply with ANSI/AAMI ES60601-1, | Comply with IEC 60601-1, | Comply with IEC 60601-1, | SE |
| IEC 60601-2-22 | IEC 60601-2-22 | IEC 60601-2-22 | ||
| EMC | Comply with IEC 60601-1-2 | Comply with IEC 60601-1-2 | Comply with IEC 60601-1-2 | SE |
| Laser Safety | Comply with IEC 60601-2-22, IEC 60825 | Comply with IEC 60601-2-22, IEC 60825 | Comply with IEC 60601-2-22, IEC 60825 | SE |
{10}------------------------------------------------
Image /page/10/Picture/1 description: The image shows the logo for LEAFLIFE, which is written in blue and green. There is also some Chinese text below the logo. To the right of the logo is the text "K2029" in black.
VII. Non-Clinical Test Conclusion
Non-clinical tests were conducted to verify that the proposed device met all design specifications as was Substantially Equivalent (SE) to the predicate device. The test results demonstrated that the proposed device complies with the following standards:
ES60601-1:2005/(R) 2012 and A1:2012, C1:2009/(R)2012 and ANSI/AAMI A2:2010/(R)2012, Medical electrical equipment — Part 1: General requirements for basic safety and essential performance
IEC 60601-1-2:2014, Medical electrical equipment - Part 1-2: General requirements for basic safety and essential performance - Collateral Standard: Electromagnetic disturbances - Requirements and tests.
IEC 60601-2-22 Edition 3.1 2012-10, Medical Electrical Equipment - Part 2-22: Particular Requirements for Basic Safety and Essential Performance of Surgical, Cosmetic, Therapeutic and Diagnostic Laser Equipment.
IEC 60825-1:2014, Safety of laser products - Part 1: Equipment classification and requirements.
ISO 10993-5 Third Edition 2009-06-01, Biological Evaluation of Medical Devices - Part 5: Tests For In Vitro Cytotoxicity. (Biocompatibility)
ISO 10993-10 Third Edition 2010-08-01, Biological Evaluation of Medical Devices -Part 10: Tests for Irritation and Skin Sensitization. (Biocompatibility)
Performance Testing for Spot Size Accuracy and Energy Output Accuracy.
Software Verification and Validation Testing was conducted per "Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices", and the level of concern was determined to be Moderate for the proposed device.
viii. CLINICAL TEST CONCLUSION
No clinical study is included in this submission.
{11}------------------------------------------------
IX. CONCLUSION
Based on the comparison and analysis above, the proposed device is determined to be as safe, as effective, and performs as well as the legally marketed predicate devices.
§ 878.4810 Laser surgical instrument for use in general and plastic surgery and in dermatology.
(a)
Identification. (1) A carbon dioxide laser for use in general surgery and in dermatology is a laser device intended to cut, destroy, or remove tissue by light energy emitted by carbon dioxide.(2) An argon laser for use in dermatology is a laser device intended to destroy or coagulate tissue by light energy emitted by argon.
(b)
Classification. (1) Class II.(2) Class I for special laser gas mixtures used as a lasing medium for this class of lasers. The devices subject to this paragraph (b)(2) are exempt from the premarket notification procedures in subpart E of part 807 of this chapter, subject to the limitations in § 878.9.