K Number
K221002
Device Name
IPL Hair Removal Device, Model(s): UI04A, UI04B, UI04C
Date Cleared
2022-06-01

(58 days)

Product Code
Regulation Number
878.4810
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
IPL Hair Removal Device is indicated for the removal of unwanted hair. The device is also indicated for the permanent reduction in hair regrowth, 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.
Device Description
IPL Hair Removal Device (Model: UI04A, UI04B, UI04C), is an over-the-counter, home-use and single-person-use device for hair reduction by using Intense Pulsed Light (IPL). It works below the skin's surface and does not involve any cutting or pulling, reducing hair growth with minimal pain. The device is only powered by the external power adapter and its IPL emission activation is by finger switch. This product adopts irreplaceable treatment window and is suitable for multiple hair removal areas (such as: lips, underarms, bikini lines, arms, legs, etc.). It contains a skin sensor to detect appropriate skin contact, if the device is not in full contact with the skin, the device cannot emit the treatment light pulses. Besides, the device has the cooling function that will be activated throughout the whole hair removal process to provide users with a more comfortable experience.
More Information

No
The description focuses on basic safety features like a skin sensor and cooling function, and there is no mention of AI or ML in the device description, performance studies, or key metrics.

No
The device is indicated for hair removal and permanent reduction in hair regrowth, which are cosmetic rather than therapeutic indications.

No
The device is described as an IPL Hair Removal Device indicated for the removal of unwanted hair and the permanent reduction in hair regrowth. Its function is to reduce hair growth, not to diagnose a medical condition.

No

The device description clearly outlines hardware components such as an external power adapter, finger switch, treatment window, skin sensor, and cooling function, indicating it is a physical device that utilizes Intense Pulsed Light technology.

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

Here's why:

  • IVD Definition: In Vitro Diagnostic devices are used to examine specimens taken from the human body (like blood, urine, tissue) to provide information about a person's health, diagnose conditions, or monitor treatments.
  • Device Function: The IPL Hair Removal Device works by applying light energy to the skin to reduce hair growth. It does not analyze any biological samples taken from the body.
  • Intended Use: The intended use is for hair removal and reduction, which is a cosmetic or aesthetic purpose, not a diagnostic one.

The device description and intended use clearly indicate that it is a physical device that interacts with the skin's surface to achieve a desired outcome (hair reduction), rather than analyzing biological samples for diagnostic purposes.

N/A

Intended Use / Indications for Use

IPL Hair Removal Device is indicated for the removal of unwanted hair. The device is also indicated for the permanent reduction in hair regrowth, 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.

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

OHT

Device Description

IPL Hair Removal Device (Model: UI04A, UI04B, UI04C), is an over-the-counter, home-use and single-person-use device for hair reduction by using Intense Pulsed Light (IPL). It works below the skin's surface and does not involve any cutting or pulling, reducing hair growth with minimal pain.

The device is only powered by the external power adapter and its IPL emission activation is by finger switch. This product adopts irreplaceable treatment window and is suitable for multiple hair removal areas (such as: lips, underarms, bikini lines, arms, legs, etc.). It contains a skin sensor to detect appropriate skin contact, if the device is not in full contact with the skin, the device cannot emit the treatment light pulses. Besides, the device has the cooling function that will be activated throughout the whole hair removal process to provide users with a more comfortable experience.

IPL Hair Removal Device, model: UI04A, UI04B, UI04C have the same indication for use, performance, structure design and operation, the only deference is their enclosure color (UI04A is white, UI04B is mint green and UI04C is deep green).

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

lips, underarms, bikini lines, arms, legs

Indicated Patient Age Range

Not Found

Intended User / Care Setting

over-the-counter, home-use and single-person-use device

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 data were provided in support of the substantial equivalence determination.

  1. Biocompatibility Testing: The biocompatibility evaluation for the body-contacting components of the IPL Hair Removal Device was conducted in accordance with ISO 10993-1, and included ISO 10993-5:2009 (Tests for In Vitro Cytotoxicity) and ISO 10993-10:2010 (Tests for Irritation and Skin Sensitization). All tests passed.
  2. Electrical Safety and EMC: Electrical safety and EMC testing was performed to, and passed, as per IEC 60601-1-2, ANSI AAMI ES60601-1, IEC 60601-1-11, IEC 60601-2-57, and IEC 60601-2-83.
  3. Eye Safety: Compliance with IEC 62471 Photobiological safety of lamps and lamp systems was demonstrated.
  4. Software Verification and Validation: Software documentation consistent with a moderate level of concern was submitted. System validation testing demonstrated that all software requirement specifications are met and all software hazards have been mitigated to acceptable risk levels.
  5. Usability: The product usability has been evaluated and verified according to IEC 60601-1-6 and FDA guidance "Applying Human Factors and Usability Engineering to Medical 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.

K160968

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.

K173813, K212318

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

§ 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.

0

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

June 1, 2022

Shenzhen Ulike Smart Electronics Co.,Ltd % Tracy Che Registration engineer Feiying Drug & Medical Consulting Technical Service Group Rm 2401 Zhenye International Business Center, No. 3101-90. Oianhai Road Shenzhen, Guangdong 518052 China

Re: K221002

Trade/Device Name: IPL Hair Removal Device, Model(s): UI04A, UI04B, UI04C 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: OHT Dated: March 22, 2022 Received: April 4, 2022

Dear Tracy Che:

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.

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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 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.

Purva Pandya Assistant Director DHT4A: Division of General Surgery Devices OHT4: Office of Surgical and Infection Control Devices Office of Product Evaluation and Ouality Center for Devices and Radiological Health

Enclosure

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Indications for Use

510(k) Number (if known) K221002

Device Name IPL Hair Removal Device Model(s): UI04A, UI04B, UI04C

Indications for Use (Describe)

IPL Hair Removal Device is indicated for the removal of unwanted hair. The device is also indicated for the permanent reduction in hair regrowth, 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)

X Over-The-Counter Use (21 CFR 801 Subpart C)

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510(k) Summary K221002

"510(k) Summary" as required by 21 CFR Part 807.92.

I. Submitter

Shenzhen Ulike Smart Electronics Co.,Ltd

No.8, Keyuan Road, Yuehai Subb-district, Nanshan District, Shenzhen, Guangdong, China Post code: 518000 Tel.: +86 15915373017

Xiaoming Lin Regulation Manager Tel: +86 15915373017 Email: rd5(@ulikebeauty.com

II. Device

Name of Device: IPL Hair Removal Device Model(s): UI04A, UI04B, UI04C Common or Usual Name: Light Based Over-The-Counter Hair Removal Regulation Name: Laser surgical instrument for use in general and plastic surgery and in dermatology Regulatory Class: II Product Code: OHT Regulation Number: 21 CFR 878.4810

III. Predicate Device

Primary predicate device:

ManufacturerPredicate Device510(k) NumberApproval Date
CyDen Limited.iPulse SmoothSkin Gold
Hair Removal SystemK160968Apr.14, 2016

Reference devices:

ManufacturerReference Device510(k) NumberApproval Date
Shen Zhen CosBeauty Co., LtdIPL Hair Removal Device
Joy Version, CB-027K173813Sept. 07, 2018
Dongguan Define Beauty
Electronic Technology Co.
LtdIPL HAIR REMOVAL SG-
8025K212318Jan.14, 2022

IV. Device Description

IPL Hair Removal Device (Model: UI04A, UI04B, UI04C), is an over-the-counter, home-use and single-person-use device for hair reduction by using Intense Pulsed Light (IPL). It works below

4

the skin's surface and does not involve any cutting or pulling, reducing hair growth with minimal pain.

The device is only powered by the external power adapter and its IPL emission activation is by finger switch. This product adopts irreplaceable treatment window and is suitable for multiple hair removal areas (such as: lips, underarms, bikini lines, arms, legs, etc.). It contains a skin sensor to detect appropriate skin contact, if the device is not in full contact with the skin, the device cannot emit the treatment light pulses. Besides, the device has the cooling function that will be activated throughout the whole hair removal process to provide users with a more comfortable experience.

IPL Hair Removal Device, model: UI04A, UI04B, UI04C have the same indication for use, performance, structure design and operation, the only deference is their enclosure color (UI04A is white, UI04B is mint green and UI04C is deep green).

V. Indications for Use

IPL Hair Removal Device is indicated for the removal of unwanted hair. The device is also indicated for the permanent reduction in hair regrowth, 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. Materials

| Component

nameMaterial of ComponentBody Contact CategoryContact Duration
IPL Hair
Removal Device
(Enclosure and
treatment
window)ABS, PC,
Crystal applicationSurface-contacting
device: Intact skinLess than 24 hours

We have tested the device for biocompatibility by a reliable third-party lab. For details, please refer to Section 16 "Biocompatibility Discussion".

VII.Comparison of Technological Characteristics With the Predicate Device

The IPL Hair Removal Device has the same intended use, mode of action and similar operational characteristics as the predicate device. Any minor differences between the subject device and the listed predicate device and reference devices do no raise any issues of safety or efficacy. Performance data supports that the device is safe and as effective as the predicate device and reference devices for its intended use. Therefore, the IPL Hair Removal Device may be found substantially equivalent to its predicate device and reference devices.

IPL Hair Removal Device is compared with the following Predicate Device and Reference Devices in terms of intended use, design, material, specifications, and performance:

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| Comparison

ElementsSubject DevicePredicate DeviceReference Device 1Reference Device 2Remark
510(k)
NumberPendingK160968K173813K212318/
Trade nameIPL Hair Removal
Device (UI04A,
UI04B, UI04C)iPulse SmoothSkin
Gold Hair Removal
SystemIPL Hair Removal
Device Joy Version, CB-
027IPL HAIR
REMOVAL SG-/
8025/
ManufacturerShenzhen Ulike
Smart Electronics
Co.,LtdCyden Limited.Shen Zhen CosBeauty
Co., LtdDongguan Define
Beauty Electronic
Technology Co.
Ltd/
Regulation
number21 CFR 878.481021 CFR 878.481021 CFR 878.481021 CFR 878.4810Same
Product codeOHTOHT, GEXOHTOHTSame
Device
classificationClass IIClass IIClass IIClass IISame
Indication for
use/ Intended
useIPL Hair
Removal
Device is indicated
for the removal of
unwanted hair. The
device is also
indicated for the
permanent reduction
in hair regrowth,
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
iPulse
SmoothSkin Gold
Hair Removal System
is indicated for the
removal of unwanted
hair. The iPulse
Smoothskin Gold is
also indicated for the
permanent reduction
in hair regrowth,
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 IPL Hair Removal
Device Joy Version is
indicated for the
removal of unwanted
hair. The device is also
indicated for the
permanent reduction in
hair regrowth, 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
device is used for adults
with Fitzpatrick skin
types I - IV.The IPL Hair
Removal (Model:
SG-8025) is an
over the Counter
device intended for
the removal of
unwanted body
and/or facial hair
in adults. It is also
intended for
permanent
reduction in
unwanted hair.
Permanent hair
reduction is
defined as the
long-term stable
reduction in the
number of hairs re-
growing when
measured at 6. 9.
and 12 months
after the
completion of a
treatment regimen.Same, only
wording
difference
Prescription
or OTCOTCOTCOTCOTCSame
ApplicableFitzpatrick
SkinUnknownFitzpatrick skin types I -UnknownDifferent
Comparison
ElementsSubject DevicePredicate DeviceReference Device 1Reference Device 2Remark
skinTypes I-VIVNote 1
Treatment
arealarge areas (e.g. arms,
legs, chest) and small
areas (e.g. fingers,
lip)UnknownLarge areas (legs, arms,
back and abdomen), face
(upper lip, chin and
sideburns)Body and faceSimilar
Device design
Source
energySupplied by external
adapterExternal
Power
supplySupplied by external
adapterSupplied by
external adapterSame
Power supply100-240V~, 50/60Hz110V or 230V,
50/60Hz100-240 VAC, 50/60HzUnknownSame
Dimension60.5(W)x38(H)x169.
7(L)mmUnknown12678200mm2057656mm
(HWD)Different
Note 2
SterilizationNot requiredNot requiredNot requiredNot requiredSame
Output specification
Light sourceIntense Pulsed LightIntense Pulsed LightIntense Pulsed LightIntense Pulsed LightSame
Energy
mediumXenon Arc FlashlampXenon Arc FlashlampXenon Arc FlashlampXenon lampSame
Wavelength
range550-1200mm510-1100nm510-1200nm530nmSimilar
Note 3
Energy
density$3.03-5.3J/cm^2$$3-6J/cm^2$$1.8~5.1J/cm^2$$2.5J/cm^2$Similar
Note 4
Output
energy$10.0~17.5J$$9~18J$Body
lamp
cartridge11.77~22.21J
510~1200nmLevel 1: 7.5J
Level 2: 8.5J
Level 3: 9.5J
Level 4: 11J
Level 5: 12JSimilar
Note 4
Facial
lamp
cartridge3.65~7.04J
512~1197nm
Bikini
lamp
cartridge3.84~7.22J
511~1200nm
Spot size3.3cm²3cm² (3cm by 1cm)Body: 4.2cm²
Bikini and face: 2.0cm²3.0cm²Similar
Note 5
Pulse
duration7-10ms2ms to 10ms9.20~11.20ms1msSimilar
Note 6
Pulsing
controlFinger switchFinger switchFinger switchFinger switchSame
Delivery
deviceDirect illumination to
tissueDirect illumination to
tissueDirect illumination to
tissueDirect illumination
to tissueSame
Output
intensity level5 LevelsUnknown5 levels5 levelsSame
Comparison
ElementsSubject DevicePredicate DeviceReference Device 1Reference Device
2Remark
Software/
Firmware/
Microprocess
or Control?YesYesYesYesSame
Additional features
Electrical
safetyIEC 60601-1-2
IEC 60601-1-11
ANSI
AAMI
ES60601-1
IEC 60601-2-57
IEC 60601-2-83IEC 60601-1
IEC 60601-1-2
IEC 60601-2-57IEC 60601-1
IEC 60601-1-2
IEC 60601-2-57IEC 60601-1
IEC 60601-1-2
IEC 60601-1-11
IEC 60601-2-57Similar
Eye safetyIEC 62471IEC 62471UnknownIEC 62471Same
Biocompatibi
lityISO 10993-5
ISO 10993-10ISO 10993-5
ISO 10993-10
ISO 10993-12ISO 10993-5
ISO 10993-10ISO 10993-5
ISO 10993-10Same

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7

Note 1:

Though the applicable skin tone type is different from the reference devices, the commonly recognized applicable skin tone types for IPL hair removal device is mostly Fitzpatrick skin types I-IV or I-V. The applicable skin tone types of the subject device is Fitzpatrick skin types I-V and usability evaluation has been conducted to verify these skin types can use the device safely and effectively, so this difference will not raise any safety/ effectiveness problems.

Note 2:

Though the dimension is different from the predicate device and reference devices, this difference is insignificant and do not raise any safety/ effectiveness problems.

Note 3:

Though the wavelength of subject device is a little different from the predicate device, it's within the range of reference device 1, and they all comply with IEC 60601-2-57/IEC 60601-2-83 and IEC 62471 requirements, so this difference will not raise any safety or effectiveness issue.

Note 4:

Though the energy density and the output energy of subject device is a little different from the predicate device and reference devices, the energy density and the output energy of subject device is within the range of the minimum and maximum value of the predicate device and reference devices, and they all comply with IEC 60601-2-57/IEC 60601-2-83 and IEC 62471 requirement, so this difference will not raise any safety or effectiveness issue.

Note 5:

8

There is minor difference in spot size between the subject device and the predicate device. The spot size is related to energy density and since the difference in energy density is not significant as explained in note 4, so this difference will not raise any safety or effectiveness issue.

Note 6:

Though the pulse duration of subject device is a little different from the predicate device, it's basically within the range of the predicate and reference devices, and the subject device comply with IEC 60601-2-57/IEC 60601-2-83 and IEC 62471 requirement, so this difference will not raise any safety or effectiveness issue.

VIII. Performance Data

The following performance data were provided in support of the substantial equivalence determination.

1) Biocompatibility Testing

The biocompatibility evaluation for the body-contacting components of the IPL Hair Removal Device was conducted in accordance with the "Use of International Standard ISO 10993-1, 'Biological Evaluation of Medical Devices -Part 1: Evaluation and Testing Within a Risk Management Process, Document Issued on September 4, 2020", as recognized by FDA. The following testing was performed to, and passed, including:

  • ISO 10993-5:2009, Biological Evaluation of Medical Devices -Par t 5: Tests for In Vitro Cytotoxicity

  • ISO 10993-10:2010, Biological Evaluation of Medical Devices -Par t 10: Tests for Irritation and Skin Sensitization

2) Electrical Safety and EMC

Electrical safety and EMC testing was performed to, and passed, as per the following standards:

  • IEC 60601-1-2 Medical electrical equipment -Part 1-2: General requirements for basic safety and essential performance -Collateral standard: electromagnetic compatibility

  • ANSI AAMI ES60601-1 Medical electrical equipment Part 1: General requirements for basic safety and essential performance (IEC 60601-1:2005, MOD)

  • IEC 60601-1-11 Medical Electrical Equipment -Part 1: General Requirements for Basic Safety and Essential Performance -Collateral Standard: Requirements for Medical Electrical Equipment and Medical Electrical Systems Used in the Home Healthcare Environment

  • IEC 60601-2-57 Medical electrical equipment -- Part 2-57: Particular requirements for the basic safety and essential performance of non-laser source equipment intended for therapeutic, diagnostic, monitoring and cosmetic/aesthetic use

  • IEC 60601-2-83 Medical electrical equipment Part 2-83: Particular requirements for the basic safety and essential performance of home light therapy equipment

3) Eye Safety

  • IEC 62471 Photobiological safety of lamps and lamp systems

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4) Software Verification and Validation

Software documentation consistent with moderate level of concern was submitted in this 510(k). System validation testing presented in this 510(k) demonstrated that all software requirement specifications are met and all software hazards have been mitigated to acceptable risk levels.

5) Usability

The product usability has been evaluated and verified according to the following standard and FDA guidance

IEC 60601-1-6 Medical electrical equipment - Part 1-6: General requirements for basic safety and essential performance - Collateral standard: Usability

Applying Human Factors and Usability Engineering to Medical Devices, issued on FEBRUARY 2016

Summary

Based on the above performance as documented in this application, IPL Hair Removal Device was found to have a safety and effectiveness profile that is similar to the predicate device and reference devices.

IX. Conclusions

Based on the above analysis and non-clinical tests performed, it can be concluded that the subject device IPL Hair Removal Device is as safe, as effective, and performs as well as the legally marketed predicate device and reference devices.