K Number
K210421
Device Name
Diafil & Diafil Capsule
Date Cleared
2021-06-28

(137 days)

Product Code
Regulation Number
872.3690
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
DiaFil & DiaFil Capsule composite material which has resin organic and inorganic fillers as ingredients, which are being used for aesthetic restoration by getting polymerized directly in the oral cavity. - Direct anterior and posterior restorations
Device Description
The product belongs to Group 1, Class 2 of Type 1 according to the standard classification of ISO 4049. It is a nano hybrid typed light-curved complex resin for aesthetic restoration for both anterior and posterior parts, which is used for restoration that requires aesthetics through decay and damage in a form of paste with unpolymerized dimethacrylate monomer, inorganic filler, and photoinitiators mixed. That is, after recovering with the unpolymerized product, to make a hard restoration by polymerizing through dental visible-ray polymerizer.
More Information

Not Found

No
The device description and performance studies focus on the material properties and biocompatibility of a dental composite, with no mention of AI or ML.

No
The device is described as a composite material for aesthetic restoration of teeth, not for treating a disease or condition.

No.
The device is described as a composite material for "aesthetic restoration" of teeth, functioning as a "light-curved complex resin" that is "polymerized directly in the oral cavity" to mend "decay and damage." It is used for "recovering" and forming a "hard restoration." This indicates a therapeutic or restorative function, not a diagnostic one.

No

The device description clearly states it is a "composite material" and a "paste" that is polymerized in the oral cavity, indicating it is a physical substance, 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 "aesthetic restoration by getting polymerized directly in the oral cavity" for "Direct anterior and posterior restorations." This describes a material used in the body for structural repair, not a test performed on a sample taken from the body to diagnose a condition.
  • Device Description: The description details a "light-curved complex resin" that is applied as a paste and then hardened by light. This is consistent with a dental restorative material, not an IVD.
  • Anatomical Site: The anatomical site is the "oral cavity; anterior and posterior parts (of teeth)." This is where the device is applied and functions, not where a sample is collected for testing.
  • Lack of IVD Characteristics: There is no mention of analyzing biological samples (blood, urine, tissue, etc.), detecting analytes, or providing diagnostic information about a patient's health status.

In summary, the DiaFil & DiaFil Capsule is a dental restorative material used for filling cavities and repairing teeth, which is a medical device but not an in vitro diagnostic device.

N/A

Intended Use / Indications for Use

DiaFil & DiaFil Capsule composite material which has resin organic and inorganic fillers as ingredients, which are being used for aesthetic restoration by getting polymerized directly in the oral cavity. - Direct anterior and posterior restorations

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

EBF, KLE

Device Description

The product belongs to Group 1, Class 2 of Type 1 according to the standard classification of ISO 4049. It is a nano hybrid typed light-curved complex resin for aesthetic restoration for both anterior and posterior parts, which is used for restoration that requires aesthetics through decay and damage in a form of paste with unpolymerized dimethacrylate monomer, inorganic filler, and photoinitiators mixed. That is, after recovering with the unpolymerized product, to make a hard restoration by polymerizing through dental visible-ray polymerizer.

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)

No clinical data was collected or provided to support substantial equivalence between the subject and predicate 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.

K192510, K192392, K192273

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

§ 872.3690 Tooth shade resin material.

(a)
Identification. Tooth shade resin material is a device composed of materials such as bisphenol-A glycidyl methacrylate (Bis-GMA) intended to restore carious lesions or structural defects in teeth.(b)
Classification. Class II.

0

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June 28, 2021

Diadent Group International Kab Sun Lee Quality Assurance Manager 16, Osongsaengmyeong 4-ro, Osong-eup, Heungdeok-gu Cheongji-si, Chungcheongbuk-do 28161 SOUTH KOREA

Re: K210421/S002

Trade/Device Name: Diafil & Diafil Capsule Regulation Number: 21 CFR 872.3690 Regulation Name: Tooth shade resin material Regulatory Class: Class II Product Code: EBF, KLE Dated: May 26, 2021 Received: June 1, 2021

Dear Kab 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/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

1

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 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,

Michael E. Adjodha, M.ChE. Assistant Director DHT1B: Division of Dental and ENT 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) K210421

Device Name DIAFIL & DIAFIL CAPSULE

Indications for Use (Describe)

DiaFil & DiaFil Capsule

composite material which has resin organic and inorganic fillers as ingredients, which are being used for aesthetic restoration by getting polymerized directly in the oral cavity.

  • Direct anterior and posterior restorations
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 - K210421

1 Application Information

Date Prepared:February 8, 2021
Company Name
and
Address:DiaDent Group International
16, Osongsaengmyeong 4-ro, Osong-eup, Heungdeok-gu,
Cheongju-si, Chungcheongbuk-do, 28161, Republic of Korea
Contact Person:Kab Sun, Lee
Quality Assurance Manager
Phone: +82-43-266-2315
FAX: +82-43-235-2315
Email: diadent32@diadent.co.kr

2 Device Information

Subject Device
Device Name:DIAFIL & DIAFIL CAPSULE
Device Type:Tooth shade resin material
Regulation Number:21 CFR 872.3690
21 CFR 872.3200
Regulation Description:Material, Tooth Shade, Resin
Product Code:EBF
KLE
Device Class:II

3 Predicate Devices

The legally marketed devices to which substantial equivalence is being claimed are:

| | Primary Predicate
Device | Predicate Device
(Subsequent device 1) | Predicate Device
(Subsequent device 2) |
|-----------------------|--------------------------------|-------------------------------------------|-------------------------------------------|
| Device Name: | DIAFIL & DIAFIL
CAPSULE | DIAPLUS | DIAETCH |
| 510(k) Number: | K192510 | K192392 | K192273 |
| Applicant: | Diadent Group
International | Diadent Group
International | Diadent Group
International |
| Regulation
Number: | 21 CFR 872.3690 | 21 CFR 872.3200 | 21 CFR 872.3200 |
| Product Code: | EBF | KLE | KLE |
| Device Class: | II | II | II |

4

4 Products configuration

DiaFil Refill package1 syringe of DiaFil (4g)
DiaFil Intro Kit1 syringe of DiaFil (1g)
DiaFil Start Kit5 syringes of DiaFil (4g each)
A bottle of DiaPlus (5ml)
A syringe of DiaEtch (3ml)
Accessories
DiaFil Capsule type20 capsule of DiaFil (0.25g)

The subject device is packaged with the following:

5 Device Description

The product belongs to Group 1, Class 2 of Type 1 according to the standard classification of ISO 4049. It is a nano hybrid typed light-curved complex resin for aesthetic restoration for both anterior and posterior parts, which is used for restoration that requires aesthetics through decay and damage in a form of paste with unpolymerized dimethacrylate monomer, inorganic filler, and photoinitiators mixed. That is, after recovering with the unpolymerized product, to make a hard restoration by polymerizing through dental visible-ray polymerizer.

6 Indications for Use

DiaFil

A composite material which has resin organic fillers or complex fillers as ingredients, which are being used for aesthetic restoration by getting polymerized directly in the oral cavity. - Direct anterior and posterior restorations

DiaPlus (DiaFil Start Kit Component)

As a dentine/enamel total etching bonding system for direct adhesion, it is used in the adhesion of all direction restoration substances.

  • Bonding of direct composite
  • Bonding to composite and set amalgam
  • Bonding of indirect restoration-Porcelain, Composite (Inlays, Onlays, Veneers, Crowns)

DiaEtch (DiaFil Start Kit Component)

DiaEtch is a 37% phosphoric acid etchant used for etching enamel and dentin to promote adhesion of primer/bonding agent adhesives to tooth structure and restorative materials.

7 Non-Clinical Performance Data

This device has demonstrated conformance with non-clinical performance requirements through evaluation and testing in accordance with the following harmonized standards:

-ISO 4049Dentistry -- Polymer-based restorative materials
-ISO 7405Dentistry - Evaluation Of Biocompatibility Of Medical
Devices Used In Dentistry [Including: Amendment 1
(2013)]
-ISO 10993-1Biological evaluation of medical devices - Part
1:Evaluation and testing within a risk management
process
-ISO 10993-3Biological evaluation of medical devices - Part 3: Tests
for genotoxicity, Carcinogenicity and reproductive

5

Diadent Group International

Product Name : DIAFIL & DIAFIL CAPSULE

toxicity
-ISO 10993-5Biological evaluation of medical devices - Part 5. Tests
for in vitro Cytotoxicity
-ISO 10993-10Biological Evaluation Of Medical Devices - Part 10:
Tests For Irritation And Skin
Sensitization
-ISO 10993-11Biological Evaluation Of Medical Devices - Part 11:
Tests For Systemic Toxicity

Additional non-clinical bench testing demonstrates the safety and effectiveness of the subject device.

6

510k SUBMISSION

Product Name : DIAFIL & DIAFIL CAPSULE

8 Substance Equivalence discussions

8.1 Comparison Table

This device compares to the legally marketed devices as follows:

| | Primary Predicate Device
(Original) | Predicate Device
(Subsequent device 1) | Predicate Device
(Subsequent device 2) | Subject Device |
|----------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| | DIAFIL & DIAFIL CAPSULE | DIAPLUS | DIAETCH | DIAFIL & DIAFIL CAPSULE |
| 510(k) Number | K192510 | K192392 | K192273 | K210421 |
| Indication for Use | A composite material which has resin
organic and inorganic fillers or
complex fillers as ingredients, which
are being used for aesthetic
restoration by getting polymerized
directly in the oral cavity.

  • Direct anterior and posterior
    restorations | As a dentine/enamel total etching
    bonding system for direct adhesion, it
    is used in the adhesion of all direction
    restoration substances.
  • Bonding of direct composite
  • Bonding to composite and set
    amalgam
  • Bonding of indirect restoration-
    Porcelain, Composite (Inlays, Onlays,
    Veneers, Crowns) | DiaEtch is a 37% phosphoric acid
    etchant used for etching enamel and
    dentin to promote adhesion of
    primer/bonding agent adhesives to
    tooth structure and restorative
    materials. | DiaFil & DIAFIL CAPSULE: Same
    DiaPlus : Same
    DiaEtch : Same |
    | Device
    Description | The product belongs to Group 1,
    Class 2 of Type 1 according to the
    standard classification of ISO 4049. It
    is a nano hybrid typed light-curved
    complex resin for aesthetic
    restoration for both anterior and
    posterior parts, which is used for
    restoration that requires aesthetics
    through decay and damage in a form
    of paste with unpolymerized
    dimethacrylate monomer, inorganic
    filler, and photoinitiators mixed. That
    is, after recovering with the
    unpolymerized product, to make a
    hard restoration by polymerizing | DiaPlus is a photopolymerization type
    dentine and enamel adhesive as a
    5th generation dentine adhesion
    system that can be applied to all
    types of composite resin restorations.
    As a dentine/enamel total etching
    bonding system for direct adhesion. It
    is used in the adhesion of all direction
    restoration substances. | Thixotropic dental etchant gel with
    37% phosphoric acid | DiaFil & DIAFIL CAPSULE: Same
    DiaPlus : Same
    DiaEtch : Same |
    | | through dental visible-ray
    polymerizer. | | | |
    | Construction | 1) Refill package :
    1 syringe of DiaFil (4g)
  1. Intro Kit
    1 syringe of DiaFil (1g)
  2. Capsule type :
    20 capsule of DiaFil (0.25g) | One bottle of DiaPlus(5ml) | 1) Economic package
    5 syringe of DiaEtch (5ml each)
    20 disposable tips
  3. Regular package
    2 syringe of DiaEtch (3ml each)
    10 disposable tips
  4. Refill package
    1 syringe of DiaEtch(5ml)
    5 disposable tips | Model addition :
    DiaFil Start Kit
    5 syringes of DiaFil (4g each)
    A bottle of DiaPlus (5ml)
    A syringe of DiaEtch (3ml)
    Accessories :
    50 brush tips
    1 brush handle,
    A mixing well,
    A mixing pad,
    10 disposable tips,
    A shade sheet. |
    | Composition | - Bis-GMA
  • TEGDMA
  • UDMA
  • Barium-alumino-silicate
  • Silica
  • Pigments | - Ethanol
  • UDMA (Urethane Dimethacrylate)
  • BisGMA (bisphenolA-glycidyl
    methacrylate)
    -TEGDMA (Triethylene glycol
    dimethacrylate)
  • HEMA succinate
  • Champhor quinone | - Phosphoric acid 37%
  • Water
  • Citric acid anhydrous
  • Silicon dioxide, (chemically
    prepared)
  • 1%-Methylene Blue solution
  • Xanthan Gum
  • Ethyl alcohol | DiaFil & DIAFIL CAPSULE: Same
    DiaPlus : Same
    DiaEtch : Same |
    | Human factor | Ready to use dispensing system | Ready to use dispensing system | Ready to use dispensing system | DiaFil & DIAFIL CAPSULE: Same
    DiaPlus : Same
    DiaEtch : Same |
    | Shelf life | 3 years | 2 years | 2 years | DiaFil & DIAFIL CAPSULE: Same
    DiaPlus : Same
    DiaEtch : Same |
    | Period of Use | Permanent (> 30 d) | Permanent (> 30 d) | -limited (≤24 h) | DiaFil & DIAFIL CAPSULE: Same
    DiaPlus : Same
    DiaEtch : Same |
    | Biocompatibility | Conforming to ISO 10993-1 | Conforming to ISO 10993-1 | Conforming to ISO 10993-1 | DiaFil & DIAFIL CAPSULE: Same
    DiaPlus : Same
    DiaEtch : Same |
    | Performance
    Standard
    conformance | Meet ISO 4049 standard | Meet ISO 4049 standard | Meet ISO 4049 standard | DiaFil & DIAFIL CAPSULE: Same
    DiaPlus : Same
    DiaEtch : Same |

CONFIDENTIAL

7

510k SUBMISSION

Diadent Group International

Product Name : DIAFIL & DIAFIL CAPSULE

CONFIDENTIAL

Pages 5 of 6

8

8.2 Discussion :

The Change is only a package addition of DiaFil Capsule. The package includes 5" generation bonding agent (DiaPlus, K192392) and Etching agent (DiaEtch, K192273), which have already been proven to have Substantial product equivalence through the 510(k) decision of each product. The final package design of DIAFL START KT is added according to the configuration of package, but the products labeling of each components of package is not changed.

As the result of discussion of comparison, the package addition of DIAFIL CAPSULE does not affect to the original product.

9 Clinical Performance Data

No clinical data was collected or provided to support substantial equivalence between the subject and predicate devices.

10 Conclusions

Since the comparative products are components of the safely and effectiveness of subject product has already been proven in each aproved product. According to the conclusion, the subject device is practically the same as the predicale devices that are legally sold in market.

CONFIDENTIAL