K Number
K221194
Device Name
LEDEX
Date Cleared
2022-09-16

(144 days)

Product Code
Regulation Number
872.6070
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
LEDEX WL-120 is a visible curing unit programmed for polymerization of dental light cured materials by dental professionals.
Device Description
The LEDEX WL-120 device using highly efficient LEDs with a thermal management system, while maintaining consistent performance even in the most challenging and demanding curing needs. The light has four LED curing chips with a range of 390 nm, thus effectively curing all composites. About the light guide rod, it is made of genuine optical fiber which can optimize light conduction and minimize loss of light from source to tip. It therefore ensures the most possible intensity of light at the light guide tip. Furthermore, we design advanced efficient cooling heat sink which accompanies with over temperature protection. The thermal protection circuits prevent the light from overheating and help to keep the device in a safety mode. Automatic memorizing the last group of operation is another unique feature of this device.
More Information

Not Found

No
The description focuses on hardware components, thermal management, and basic operational features like automatic memorization, with no mention of AI or ML algorithms for analysis, decision-making, or image processing.

No
The device is a dental curing unit used to polymerize dental light-cured materials, which is a procedural/device-related function rather than a therapeutic treatment for a disease or condition.

No

The device is a visible curing unit used for polymerization of dental light-cured materials, which is a treatment function, not a diagnostic one.

No

The device description clearly details hardware components such as LEDs, a thermal management system, a light guide rod made of optical fiber, a cooling heat sink, and thermal protection circuits. The performance studies also focus on hardware-related metrics like irradiation, spectral irradiance, and depth of cure.

Based on the provided information, the LEDEX WL-120 is not an IVD (In Vitro Diagnostic) device.

Here's why:

  • Intended Use: The intended use is "polymerization of dental light cured materials by dental professionals." This describes a process performed directly on a patient (or materials that will be placed in a patient's mouth), not a test performed on a sample taken from the body to diagnose a condition.
  • Device Description: The description focuses on the technical aspects of a light curing unit used in dentistry. It doesn't mention any components or functions related to analyzing biological samples.
  • Lack of IVD Characteristics: The document does not mention any of the typical characteristics of an IVD, such as:
    • Analyzing biological samples (blood, urine, tissue, etc.)
    • Detecting or measuring substances in samples
    • Providing information for diagnosis, monitoring, or screening of diseases or conditions

The device is clearly intended for use in a dental setting for a therapeutic or restorative purpose, not for in vitro diagnostic testing.

N/A

Intended Use / Indications for Use

LEDEX WL-120 is a visible curing unit programmed for polymerization of dental light cured materials by dental professionals.

Product codes

EBZ

Device Description

The LEDEX WL-120 device using highly efficient LEDs with a thermal management system, while maintaining consistent performance even in the most challenging and demanding curing needs. The light has four LED curing chips with a range of 390 nm, thus effectively curing all composites.

About the light guide rod, it is made of genuine optical fiber which can optimize light conduction and minimize loss of light from source to tip. It therefore ensures the most possible intensity of light at the light guide tip.

Furthermore, we design advanced efficient cooling heat sink which accompanies with over temperature protection. The thermal protection circuits prevent the light from overheating and help to keep the device in a safety mode. Automatic memorizing the last group of operation is another unique feature of this device.

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

dental professionals

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 tests were conducted to evaluate the functionality, performance and substantial equivalence.

  • a) Irradiation (Optical power testing)
  • b) Spectral irradiance plot (Wavelength spectrum testing)
  • c) Depth of cure (Composite hardness testing)

The tests are in accordance with the following standards:

●American National Standard/American Dental Association (ANSI/ADA) Specification No. 48-2: 2010, Reaffirmed 2015, LED Curing Lights

●American National Standard/American Dental Association (ANSI/ADA) Specification No. 48:

2020, Approved 2020, Curing Lights (Powered Polymerization Activators)

●FDA Guidance for Industry and FDA Staff, Dental Curing Lights -Premarket Notification 510(k) Submissions, Clause 8. Performance Specifications

The test results conformed to the requirements of the standards.

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

Not Found

Predicate Device(s)

K131042

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 872.6070 Ultraviolet activator for polymerization.

(a)
Identification. An ultraviolet activator for polymerization is a device that produces ultraviolet radiation intended to polymerize (set) resinous dental pit and fissure sealants or restorative materials by transmission of light through a rod.(b)
Classification. Class II.

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September 16, 2022

Dentmate Technology Co. Ltd. Cheng-Feng Chou President 8F, No.8-11, Sec. 1, Zhongxing Road, Wugu District. New Taipei, 24872 Taiwan

Re: K221194

Trade/Device Name: LEDEX WL-120 Regulation Number: 21 CFR 872.6070 Regulation Name: Ultraviolet Activator For Polymerization Regulatory Class: Class II Product Code: EBZ Dated: July 11, 2022 Received: July 18, 2022

Dear Cheng-Feng Chou:

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 statutes and regulations administered by other Federal agencies. You must comply with all the Act's

1

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 (OS) regulation (21 CFR Part 820) for devices or current good manufacturing practices (21 CFR 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.

Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to https://www.fda.gov/medical-device-safety/medical-device-reportingmdr-how-report-medical-device-problems.

For comprehensive regulatory information about 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,

For 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) K221194

Device Name LEDEX WL-120

Indications for Use (Describe)

LEDEX WL-120 is a visible curing unit programmed for polymerization of dental light cured materials by dental professionals.

Type of Use (Select one or both, as applicable)

X Prescription Use (Part 21 CFR 801 Subpart D)

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

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K221194

510(k) Summary

Date: 04/21/2022

This summary of 510(k) information is being submitted in accordance with requirements of 21 CFR Part 807.92.

1. Applicant/Submitter

DENTMATE TECHNOLOGY CO., LTD. Registration Number: 3007662989 Address: 8F, No. 8-11, Sec. 1, Zhongxing Road, Wugu District, New Taipei City, 24872 Taiwan TEL: +886 2 8976 9226 Fax: +886 2 8976 9236 Email: info@dentmate.com.tw

2. Official/Submission correspondent

Mr. Cheng-Feng Chou Address: 8F, No. 8-11, Sec. 1, Zhongxing Road, Wugu District, New Taipei City, 24872 Taiwan TEL: +886 2 8976 9226 Fax: +886 2 8976 9236 Email: info@dentmate.com.tw

3. Device Information

Common Name: LED Dental Curing Light Device Trade Name: LEDEX Model Number: WL-120 Classification name: Ultraviolet Activator for Polymerization Device class: II Panel: Dental Product Code: EBZ Regulation Number: 872.6070

Indications for use ব

LEDEX WL-120 is a visible curing unit programmed for polymerization of dental light cured materials by dental professionals.

5. Predicate device

LEDEX WL-090/WL-090+, (K)131042 by DENTMATE TECHNOLOGY CO., LTD.,

6. Description of device

4

The LEDEX WL-120 device using highly efficient LEDs with a thermal management system, while maintaining consistent performance even in the most challenging and demanding curing needs. The light has four LED curing chips with a range of 390 nm, thus effectively curing all composites.

About the light guide rod, it is made of genuine optical fiber which can optimize light conduction and minimize loss of light from source to tip. It therefore ensures the most possible intensity of light at the light guide tip.

Furthermore, we design advanced efficient cooling heat sink which accompanies with over temperature protection. The thermal protection circuits prevent the light from overheating and help to keep the device in a safety mode. Automatic memorizing the last group of operation is another unique feature of this device.

7. Substantial Equivalence

LEDEX WL-120 is substantially equivalent to the predicate devices LEDEX WL-090+ (K)131042 by DENTMATE TECHNOLOGY CO., LTD. in terms of intended use, technology and principle of operation.

The following comparison table is presented to demonstrate substantial equivalence.

| Descriptive

InformationSubject DevicePredicate device
Trade name and
model numberLEDEX WL-120LEDEX WL-090/WL-090+
ManufacturerDENTMATE TECHNOLOGY CO.,
LTD.DENTMATE TECHNOLOGY CO.,
LTD.
510(k) number--K131042
Product CodeEBZEBZ
Regulatory
ClassIIII
Indications for useLEDEX WL-120 is a visible curing unit
programmed for polymerization of
dental light cured materials by dental
professionals.LEDEX (Family model: WL-090,
WL-090+) is a visible curing unit
programmed for polymerization of
dental light cured materials by dental
professionals.
Device Design –
Operational modesLow, Ramp, Standard, High, Turbo,
Plasma, WhiteLow, Ramp, Standard, High, Fast
Ortho, Turbo, Plasma
Device Design -
Light source10W LED10W LED
Device Design -
Power source3.7V Rechargeable Li-ion battery3.7V Rechargeable Li-ion battery
Device Design -
Power supplyInput: AC100~240V, 50/60Hz
Output: DC 5V/2AInput: AC100~240V, 50/60Hz
Output: DC 5V/2A
Device Design -
AccessoriesHandpiece, Power supply, Optical
fiber light guide rod, Filter, Light guide
sleeves, Cradle, Anti-glare shieldHandpiece, Power supply, Optical
fiber light guide rod, Filter, Light guide
sleeves, Cradle, Anti-glare shield
Composition of
Materials -
outer casingABS plastic materialABS plastic material
Technical
Specifications -
Light intensityMAX. 3200 mW/cm²MAX. 3200 mW/cm²
Technical
Specifications -
Peak wavelength405 & 460 nm405 & 460 nm
FDA-Recognized
Standards -
Electrical safetyIEC 60601-1:2005 (Third Edition) +
CORR. 1:2006 + CORR. 2:2007
  • A1:2012 (or IEC 60601-1: 2012
    reprint)
    ISO 10650:2015 Dentistry - Powered
    polymerization activators | IEC 60601-1:1988, Medical Electrical
    Equipment - Part 1: General
    Requirements for Safety; including
    Amendment 1(1991) and Amendment
    2(1995). |
    | FDA-Recognized
    Standards -
    Electromagnetic
    compatibility | 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
    ISO 10650:2015 Dentistry - Powered
    polymerization activators | IEC 60601-1-2, (Second Edition,
    2001), Medical electrical equipment -
    Part 1-2: General requirements for
    safety; Electromagnetic Compatibility -
    Requirements and tests. |

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6

7.1 The same between subject device and predicate device:

  • a) Product Code, Regulatory Class and Manufacturer
  • b) Indications for use
  • c) Light source, Power supply and Accessories
  • d) Outer casing material
  • e) Light intensity and Peak wavelength

7.2 The different between subject device and predicate device:

  • a) Operational modes
    The subject devices have several modes corresponding to the light output intensity and available times. The light output safety and performance test was conducted according to IEC 60601-1, ANSI/ADA specification no.42, ANSI/ADA specification no. 42-2 and FDA guidance performance testing requirements with the difference. The testing results show that these differences do not raise any problems in the safety and performance.

  • b) FDA-Recognized Standards Electrical safety & Electromagnetic compatibility
    The subject devices accord to new version of Electrical safety & Electromagnetic compatibility Standard; the predicate device was made in 2013, it accorded to old version of Electrical safety & Electromagnetic compatibility Standard.

8. Identification of the risk analysis method

The risk analysis method used to assess the impact of the modifications was a Failure Modes and Effects Analysis (FMEA). The design verification tests that were performed as a result of this risk analysis assessment are listed as below. The test methods used are the same as those submitted in the original submission.

| Descriptive

InformationTest PerformedAcceptance Criteria
FDA-Recognized
Standards:
ANSI/ADA
Standard No.
48-2-2010
(R2015)Ask to Electromagnetic Compatibility testPass test and got Verification of
Compliance
Ask to Electrical Safety testPass test and got Verification of
Compliance

9. Performance Testing

7

The following tests were conducted to evaluate the functionality, performance and substantial equivalence.

  • a) Irradiation (Optical power testing)
  • b) Spectral irradiance plot (Wavelength spectrum testing)
  • c) Depth of cure (Composite hardness testing)

The tests are in accordance with the following standards:

●American National Standard/American Dental Association (ANSI/ADA) Specification No. 48-2: 2010, Reaffirmed 2015, LED Curing Lights

●American National Standard/American Dental Association (ANSI/ADA) Specification No. 48:

2020, Approved 2020, Curing Lights (Powered Polymerization Activators)

●FDA Guidance for Industry and FDA Staff, Dental Curing Lights -Premarket Notification 510(k) Submissions, Clause 8. Performance Specifications

The test results conformed to the requirements of the standards.

10. Conclusion

Validation and verification tests have been conducted to FDA guidance document Dental Curing Lights =Premarket Notification [510(k)]. In comparing between subject device and predicate device, there are the same product code, regulatory classifications for use, light source, power supply, outer casing material, light intensity and peak wavelength of patient contacting portions.

In summary, the WL-120 LED Dental Curing Light in this submission are, in our opinion, substantially equivalent to the predicate device. Safety and performance testing supports substantial equivalence of the subject device to the predicate devices.