K Number
K241189
Device Name
Electric Wheelchair (ME23-EW16-BC200-01); Electric Wheelchair (ME23-EW16-BC200-02)
Date Cleared
2024-10-29

(183 days)

Product Code
Regulation Number
890.3860
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdparty
Intended Use
It is a motor driven, indoor and outdoor transportation vehicle with the intended use to provide mobility to a disabled or elderly person limited to a seated position.
Device Description
This Electric Wheelchair, models: ME23-EW16-BC200-01.ME23-EW16-BC200-02, is a motor driven, indoor and outdoor transportation vehicle, which a device for assisting action handicapped people and disabled people to move. It is suitabled people with mobility difficulties and elderly people. The device consists of front wheel, drive wheel, frame, controller, motor, armrest, backrest, seat cushion, seatbelt, pedal, battery box and charger. The device is powered by Li-ion Battery pack with 22 Km range, which can be recharged by an offboard battery charger that can be plugged into an AC socket outlet (100-240V, 50/60Hz) when the device is not in use. The patient can activate the controller handle (joystick) to control the speed and direction of the wheelchair movement. In addition, when the patient releases the joystick will return back to the central position and the wheelchair will be automatically stopped soon due to automatic electromagnetic brake system. Once the joystick is activated again move to other position, the wheelchair will be re-energized.
More Information

Not Found

No
The description details a standard electric wheelchair with a joystick control and automatic braking. There is no mention of AI/ML terms, image processing, or data training/testing, which are typically associated with AI/ML devices.

Yes.
The device's intended use is to provide mobility to disabled or elderly individuals, which is a therapeutic function addressing a medical condition.

No.

Explanation: The device is described as an electric wheelchair for transportation and mobility assistance, not for diagnosing medical conditions.

No

The device description explicitly lists numerous hardware components such as wheels, frame, controller, motor, battery box, and charger, indicating it is a physical device with integrated software for control.

Based on the provided information, this device is not an IVD (In Vitro Diagnostic).

Here's why:

  • Intended Use: The intended use is clearly stated as providing mobility to disabled or elderly individuals. This is a physical assistance device, not a diagnostic tool.
  • Device Description: The description details a motor-driven wheelchair with components related to transportation and control. There is no mention of analyzing biological samples or providing diagnostic information.
  • Lack of IVD Characteristics: The document does not mention any of the typical characteristics of an IVD, such as:
    • Analyzing biological specimens (blood, urine, tissue, etc.)
    • Detecting or measuring substances in the body
    • Providing information for diagnosis, monitoring, or screening of diseases or conditions.

The device is a mobility aid, falling under the category of medical devices that assist with physical function.

N/A

Intended Use / Indications for Use

It is a motor driven, indoor and outdoor transportation vehicle with the intended use to provide mobility to a disabled or elderly person limited to a seated position.

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

ITI

Device Description

This Electric Wheelchair, models: ME23-EW16-BC200-01.ME23-EW16-BC200-02, is a motor driven, indoor and outdoor transportation vehicle, which a device for assisting action handicapped people and disabled people to move. It is suitabled people with mobility difficulties and elderly people. The device consists of front wheel, drive wheel, frame, controller, motor, armrest, backrest, seat cushion, seatbelt, pedal, battery box and charger. The device is powered by Li-ion Battery pack with 22 Km range, which can be recharged by an offboard battery charger that can be plugged into an AC socket outlet (100-240V, 50/60Hz) when the device is not in use. The patient can activate the controller handle (joystick) to control the speed and direction of the wheelchair movement. In addition, when the patient releases the joystick will return back to the central position and the wheelchair will be automatically stopped soon due to automatic electromagnetic brake system. Once the joystick is activated again move to other position, the wheelchair will be re-energized.

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)

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:

  • ISO 10993-5: 2009 Biological Evaluation of Medical Devices -- Part 5: Tests For In Vitro A Cytotoxicity
  • ISO 10993-10:2021 Biological Evaluation of Medical Devices Part 10: Tests For Irritation And A Skin Sensitization
  • ISO 10993-23: 2021 Biological evaluation of medical devices Part 23: Tests for irritation A
  • A ISO 7176-1: 2014, Wheelchairs - Part 1: Determination of static stability
  • A ISO 7176-2:2017, Wheelchairs - Part 2: Determination of dynamic stability of Powered Wheelchairs
  • ISO 7176-3: 2012, Wheelchairs Part 3: Determination of effectiveness ofbrakes V
  • ISO 7176-4. Third edition 2008-10-01. Wheelchairs Part 4: Energy consumption of electric > wheelchairs and wheelchairs for determination of theoretical distance range
  • A ISO 7176-5, Second edition 2008-06-01, Wheelchairs - Part 5: Determination of overall dimensions, mass and manoeuvring space
  • ♪ ISO 7176-6: 2018, Wheelchairs - Part 6: Determination of maximum speed, acceleration and deceleration of Powered Wheelchairs
  • A ISO 7176-7, Wheelchairs - Part 7: Measurement of seating and wheel dimensions
  • ISO 7176-8:2014, Wheelchairs Part 8: Requirements and test methods for static, impact and ア fatigue strengths
  • ISO 7176-9:2009, Wheelchairs - Part 9: Climatic tests for Powered Wheelchairs

  • A ISO 7176-10:2008, Wheelchairs - Part 10: Determination of obstacle-climbing ability of electrically powered wheelchairs
  • ISO 7176-11:2012 Wheelchairs - Part 11: Test dummies.

  • ISO 7176-13, First edition 1989-08-01, Wheelchairs Part 13: Determination of coefficient A of friction of test surfaces
  • ア ISO 7176-14:2008, Wheelchairs - Part 14: Power and control systems for electrically powered wheelchairs and wheelchairs - Requirements and test methods
  • ISO 7176-15:1996, Wheelchairs - Part 15: Requirements for information disclosure, documentation and labeling

  • ISO 16840-10:2021 Wheelchair seating Part 10: Resistance to ignition of postural support > devices Requirements and test method.
  • ISO 7176-21:2009 Wheelchairs Part 21: Requirements and test methods for electromagnetic A compatibility of electrically powered wheelchairs and wheelchairs, and battery chargers
  • ISO 7176-25:2022 Wheelchairs Part 25: Lead-acid batteries and chargers for powered wheelchairs A Requirements and test methods

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.

K220747

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

§ 890.3860 Powered wheelchair.

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

0

Image /page/0/Picture/0 description: The image contains the logo of the U.S. Food and Drug Administration (FDA). On the left is the Department of Health and Human Services logo. To the right of that 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.

October 29, 2024

JiaXing XiaoXiang Medical Equipment Technology Co., Ltd. % Jarvis Wu Senior Consultant Shanghai SUNGO Management Consulting Co., Ltd. 14th Floor, Dongfang Building, 1500# Century Ave. Shanghai, Shanghai 200122 China

Re: K241189

Trade/Device Name: Electric Wheelchair (ME23-EW16-BC200-01); Electric Wheelchair (ME23-EW16-BC200-02) Regulation Number: 21 CFR 890.3860 Regulation Name: Powered Wheelchair Regulatory Class: Class II Product Code: ITI Dated: October 15, 2024 Received: October 15, 2024

Dear Jarvis Wu:

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 (the 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 available 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

Additional information about changes that may require a new premarket notification are provided in the FDA guidance documents entitled "Deciding When to Submit a 510(k) for a Change to an Existing Device" (https://www.fda.gov/media/99812/download) and "Deciding When to Submit a 510(k) for a Software Change to an Existing Device" (https://www.fda.gov/media/99785/download).

Your device is also subject to, among other requirements, the Quality System (QS) regulation (21 CFR Part 820), which includes, but is not limited to, 21 CFR 820.30. Design controls; 21 CFR 820.90. Nonconforming product; and 21 CFR 820.100, Corrective and preventive action. Please note that regardless of whether a change requires premarket review, the QS regulation requires device manufacturers to review and approve changes to device design and production (21 CFR 820.30 and 21 CFR 820.70) and document changes and approvals in the device master record (21 CFR 820.181).

Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies. You must comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); medical device reporting of medical device-related adverse events) (21 CFR Part 803) for devices or postmarketing safety reporting (21 CFR Part 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 Part 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR Parts 1000-1050.

All medical devices, including Class I and unclassified devices and combination product device constituent parts are required to be in compliance with the final Unique Device Identification System rule ("UDI Rule"). The UDI Rule requires, among other things, that a device bear a unique device identifier (UDI) on its label and package (21 CFR 801.20(a)) unless an exception or alternative applies (21 CFR 801.20(b)) and that the dates on the device label be formatted in accordance with 21 CFR 801.18. The UDI Rule (21 CFR 830.300(a) and 830.320(b)) also requires that certain information be submitted to the Global Unique Device Identification Database (GUDID) (21 CFR Part 830 Subpart E). For additional information on these requirements, please see the UDI System webpage at https://www.fda.gov/medical-device-advicecomprehensive-regulatory-assistance/unique-device-identification-system-udi-system.

Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR 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-regulatory

2

assistance/contact-us-division-industry-and-consumer-education-dice) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).

Sincerely,

Heather L. Dean -S

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

Enclosure

3

Indications for Use

Form Approved: OMB No. 0910-0120 Expiration Date: 07/31/2026 See PRA Statement below.

Submission Number (if known)

K241189

Device Name

Electric Wheelchair (ME23-EW16-BC200-01); Electric Wheelchair (ME23-EW16-BC200-02)

Indications for Use (Describe)

It is a motor driven, indoor and outdoor transportation vehicle with the intended use to provide mobility to a disabled or elderly person limited to a seated position.

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

Prescription Use (Part 21 CFR 801 Subpart D)

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

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."

4

JiaXing XiaoXiang Medical Equipment Technology Co.,Ltd No.24-101,Lane 587,Taoyuan Road,Xiuzhou,Jiaxing,Zhejiang,China

510(k) Summary K241189

Document Prepared Date: 2024/4/28

Applicant: A. JiaXing XiaoXiang Medical Equipment Technology Co.,Ltd Address: No.24-101,Lane 587,Taoyuan Road,Xiuzhou, Jiaxing, Zhejiang, China

Contact Person: Jun Sun

Tel: +86-13755443131

Submission Correspondent:

Primary contact: Mr. Jarvis Wu

Title: Senior Consultant

Shanghai SUNGO Management Consulting Co., Ltd.

14th Floor, Dongfang Building, 1500# Century Ave.,

Shanghai 200122, China

Tel: +86-21-58817802

Email: jiawei.wu@sungoglobal.com

Secondary contact: Mr. Raymond Luo Title: Technical Director

Shanghai SUNGO Management Consulting Co., Ltd. 14th Floor, Dongfang Building, 1500# Century Ave.,

Shanghai 200122, China Tel: +86-21-68828050 Email: zxfda(@sungoglobal.com

B. Device:

Trade Name: Electric Wheelchair

Common Name: Powered wheelchair

Models: ME23-EW16-BC200-01, ME23-EW16-BC200-02

Regulatory Information

Classification Name: Powered wheelchair Classification: Class II Product code: ITI Regulation Number: 890.3860 Review Panel: Physical Medicine

5

JiaXing XiaoXiang Medical Equipment Technology Co.,Ltd No.24-101,Lane 587,Taoyuan Road,Xiuzhou,Jiaxing,Zhejiang,China

C. Predicate device:

510(k) number: K220747 Classification Name: Powered wheelchair Regulation Number: 890.3860 Device Name: Power Wheelchair Model: N5515B Zhejiang Innuovo Rehabilitation Devices Co.,Ltd

D. Indications for use of the device:

It is a motor driven, indoor and outdoor transportation vehicle with the intended use to provide mobility to a disabled or elderly person limited to a seated position.

E. Device Description:

This Electric Wheelchair, models: ME23-EW16-BC200-01.ME23-EW16-BC200-02, is a motor driven,

indoor and outdoor transportation vehicle, which a device for assisting action handicapped people and disabled people to move. It is suitabled people with mobility difficulties and elderly people.

The device consists of front wheel, drive wheel, frame, controller, motor, armrest, backrest, seat cushion, seatbelt, pedal, battery box and charger.

The device is powered by Li-ion Battery pack with 22 Km range, which can be recharged by an offboard battery charger that can be plugged into an AC socket outlet (100-240V, 50/60Hz) when the device is not in use.

The patient can activate the controller handle (joystick) to control the speed and direction of the wheelchair movement. In addition, when the patient releases the joystick will return back to the central position and the wheelchair will be automatically stopped soon due to automatic

electromagnetic brake system. Once the joystick is activated again move to other position, the wheelchair will be re-energized.

F. 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:

  • ISO 10993-5: 2009 Biological Evaluation of Medical Devices -- Part 5: Tests For In Vitro A Cytotoxicity
  • ISO 10993-10:2021 Biological Evaluation of Medical Devices Part 10: Tests For Irritation And A Skin Sensitization
  • ISO 10993-23: 2021 Biological evaluation of medical devices Part 23: Tests for irritation A
  • A ISO 7176-1: 2014, Wheelchairs - Part 1: Determination of static stability
  • A ISO 7176-2:2017, Wheelchairs - Part 2: Determination of dynamic stability of Powered Wheelchairs
  • ISO 7176-3: 2012, Wheelchairs Part 3: Determination of effectiveness ofbrakes V
  • ISO 7176-4. Third edition 2008-10-01. Wheelchairs Part 4: Energy consumption of electric > wheelchairs and wheelchairs for determination of theoretical distance range

6

  • A ISO 7176-5, Second edition 2008-06-01, Wheelchairs - Part 5: Determination of overall dimensions, mass and manoeuvring space
  • ♪ ISO 7176-6: 2018, Wheelchairs - Part 6: Determination of maximum speed, acceleration and deceleration of Powered Wheelchairs
  • A ISO 7176-7, Wheelchairs - Part 7: Measurement of seating and wheel dimensions
  • ISO 7176-8:2014, Wheelchairs Part 8: Requirements and test methods for static, impact and ア fatigue strengths
  • ISO 7176-9:2009, Wheelchairs - Part 9: Climatic tests for Powered Wheelchairs

  • A ISO 7176-10:2008, Wheelchairs - Part 10: Determination of obstacle-climbing ability of electrically powered wheelchairs
  • ISO 7176-11:2012 Wheelchairs - Part 11: Test dummies.

  • ISO 7176-13, First edition 1989-08-01, Wheelchairs Part 13: Determination of coefficient A of friction of test surfaces
  • ア ISO 7176-14:2008, Wheelchairs - Part 14: Power and control systems for electrically powered wheelchairs and wheelchairs - Requirements and test methods
  • ISO 7176-15:1996, Wheelchairs - Part 15: Requirements for information disclosure, documentation and labeling

  • ISO 16840-10:2021 Wheelchair seating Part 10: Resistance to ignition of postural support > devices Requirements and test method.
  • ISO 7176-21:2009 Wheelchairs Part 21: Requirements and test methods for electromagnetic A compatibility of electrically powered wheelchairs and wheelchairs, and battery chargers
  • ISO 7176-25:2022 Wheelchairs Part 25: Lead-acid batteries and chargers for powered wheelchairs A Requirements and test methods

G. Clinical Test Conclusion

No clinical study is included in this submission.

H. Comparison with predicate Device

Table 1 General Comparison

| Elements of

ComparisonSubject DevicePredicate Device (K220747)Remark
ManufacturerJiaXing XiaoXiang Medical
Equipment Technology Co.,LtdZhejiang Innuovo
Rehabilitation Devices Co.,Ltd-
Common or Usual
namePower WheelchairPower WheelchairSame
Model(s)ME23-EW16-BC200-01,
ME23-EW16-BC200-02N5515B--
Indications for useIt is a motor driven, indoor and
outdoor transportation vehicle with
the intended use to provide
mobility to a disabled or elderly
person limited to a seated position.It is a motor driven, indoor and
outdoor transportation vehicle
with the intended use to provide
mobility to a disabled or elderly
person limited to a seated
position.S.E.
Use conditionindoor and outdoor useindoor and outdoor useS.E.
Number of wheels4,including two front wheels and
two rear Wheels4,including two front wheels
and two rear WheelsS.E
Function of wheelsFront wheels: driven wheels
suitable for rotation, acceleration,
retrograde.
Rear wheels: driving wheels to
control the speed and directionFront wheels:driven
wheels
suitable
for
rotation,
acceleration, retrograde.
Rear wheels: driving wheels to
control the speed and directionS.E
Movement control
methodBy Joystick controlBy Joystick controlS.E
Driving systemDirect drive on the rear
wheelsDirect drive on the rear
wheelsS.E
Brake systemAutomatic electromagnetic
brake systemAutomatic electromagnetic
brake systemS.E
Braking distance≤ 1.9 m≤ 1.5 mAnalysis
Maximum safe
operational incline
degree10 °9 °S.E
ArmrestPUR (polyurethane)PUS.E
Battery chargerOff-board charger
Input: 100-240V, 50/60Hz, 2.0A,
Output: 29.4 Vdc, 2.8A;Off-board charger
Input: 100-240V, 50/60Hz, 1.5A,
Output: 24 Vdc, 2A;S.E
Main frame materialMagnesium alloyCarbon fiber materialAnalysis
Back cushionPUR (polyurethane)Polyester fabricAnalysis
Seat cushionPUR (polyurethane)rubber patch cloth and Oxford
fabricAnalysis
Overall Dimension
( length* width* height)11506701030mm940610960mmS.E
Folded Dimension
( length* width* height)860670730mm720310610mmS.E
Front wheel size/type7" x 2"/PU Solid tire7" x 1.75"/PU Solid tireS.E
Rear wheel size/type10" x 2.5"/ PU solid tire8.5" x 2"/ PU Solid tireAnalysis
Max speed forwardUp to 7.9 km/h (2.2 m/s),
adjustableUp to 6 km/h (1.6 m/s),
adjustableAnalysis
Max Speed backwardLess than 3 km/h (0.5 m/s)Less than 3 km/h (0.5 m/s)S.E
Max loading weight125kg136kgAnalysis
BatteryLi-ion battery pack; rechargeable,
25.6 VDC 16AhLi-ion battery pack; rechargeable, 24 VDC 12AhAnalysis
Maximum distance of
travel on the fully
charged battery22 km15 kmAnalysis
MotorBrushless DC motor; 24VDC;
200W; 2pcsBrushless DC motor; 24VDC;
250W; 2pcsS.E
Electronic controllerBrushless dual-drive rocker
controllerBrushless dual-drive rocker
controllerS.E
Turning Radius1100 mm900 mmAnalysis
Maximum obstacle
climbing10 mm40 mmAnalysis

7

8

JiaXing XiaoXiang Medical Equipment Technology Co.,Ltd No.24-101,Lane 587,Taoyuan Road,Xiuzhou,Jiaxing,Zhejiang,China

Difference analysis:

The design and technological characteristics of the Electric Wheelchair is similar to the predicates chosen. There are minor differences between the devices including Braking distance, Main frame material, Back & Seat cushion, Rear wheel size, Max speed forward, Max loading weight, Maximum distance of travel on the fully charged battery, Battery, Turning Radius and Maximum obstacle climbing. All of the parameter with difference have been tested according to ISO7176 series standards and the test records support its safety and effectiveness. There is no deleterious effect on safety and effectiveness due to the minor differences do not influence the intended use of the device. Therefore, the proposed Wheelchair is substantially equivalent (SE) to The Power Wheelchair (K220747).

Different material used for parts in contact with user, which such differences will not impact the safety and effectiveness of the subject device as biocompatibility tests are carried out according to ISO 10993 series.

Table 2 Safety comparison

ItemProposed DevicePredicate DevicesResults
BiocompatibilityAll user directly contacting
materials are compliance with
ISO10993-5, ISO10993-10 and
ISO 10993-23 requirements.All user directly contacting
materials are compliance with
ISO10993-5 and
ISO10993-10 requirements.S.E.
EMCISO7176-21 & IEC 60601-2-1ISO7176-21S.E.
PerformanceISO7176 seriesISO7176 seriesS.E.
Label and labelingConforms to FDA RegulatoryConforms to FDA RegulatoryS.E.

Table 3 Safety comparison

| Item | Proposed Device | Predicate Devices | Resu
lts |
|-------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------|
| ISO7176-1 | The Static stability has been determined
after the testing according to the ISO
7176-1, and test results meet its design
specification. | The Static stability has been determined
after the testing according to the ISO
7176-1, and test results meet its design
specification. | S.E. |
| No.24-101, Lane 587, Taoyuan Road, Xiuzhou,Jiaxing,Zhejiang,China | | | |
| ISO7176-2 | The dynamic stability has been determined after the testing according to the ISO 7176-2, and test results meet its design specification. | The dynamic stability has been determined after the testing according to the ISO 7176-2, and test results meet its design specification. | S.E. |
| ISO7176-3 | The effectiveness of brakes has been determined after the testing according to the ISO 7176-3, and test results meet its design specification. | The effectiveness of brakes has been determined after the testing according to the ISO 7176-3, and test results meet its design specification. | S.E. |
| ISO7176-4 | The theoretical distance range has been determined after the testing according to the ISO 7176-4, and test results meet its design specification. | The theoretical distance range has been determined after the testing according to the ISO 7176-4, and test results meet its design specification. | S.E. |
| ISO7176-5 | The dimensions, mass has been determined after the testing according to the ISO 7176-5 | The dimensions, mass has been determined after the testing according to the ISO 7176-5 | S.E. |
| ISO7176-6 | The dimensions, mass has been determined after the testing according to the ISO 7176-6 | The dimensions, mass has been determined after the testing according to the ISO 7176-6 | S.E. |
| ISO7176-7 | The seating and wheel dimensions has been determined after the testing according to the ISO 7176-7 | The seating and wheel dimensions has been determined after the testing according to the ISO 7176-7 | S.E. |
| ISO7176-8 | All test results meet the requirements in Clause 4 of ISO 7176-8 | All test results meet the requirements in Clause 4 of ISO 7176-8 | S.E. |
| ISO7176-9 | The test results shown that the device under tests could continue to function according to manufacturer's specification after being subjected to each of the tests specified in Clause 8 of ISO 7176-9 | The test results shown that the device under tests could continue to function according to manufacturer's specification after being subjected to each of the tests specified in Clause 8 of ISO 7176-9 | S.E. |
| ISO7176-10 | The obstacle-climbing ability of device has been determined after the testing according to the ISO 7176-10 | The obstacle-climbing ability of device has been determined after the testing according to the ISO 7176-10 | S.E. |
| ISO7176-11 | The test dummies used in the testing of ISO 7176 series are meet the requirements of ISO 7176-11 | The test dummies used in the testing of ISO 7176 series are meet the requirements of ISO 7176-11 | S.E. |
| ISO7176-13 | The coefficient of friction of test surfaces has been determined, which could be used in other 7176 series tests involved | The coefficient of friction of test surfaces has been determined, which could be used in other 7176 series tests involved | S.E. |
| ISO7176-14 | All test results meet the requirements in Clause 7, 8, 9, 10, 11, 12, 13, 14, 15, 17 of ISO 7176-14 | All test results meet the requirements in Clause 7, 8, 9, 10, 11, 12, 13, 14, 15, 17 of ISO 7176-14 | S.E. |
| ISO7176-15 | information disclosure, documentation
and labelling of device meet the
requirements of ISO 7176-15 | information disclosure, documentation
and labelling of device meet the
requirements of ISO 7176-15 | |
| ISO7176-16/
ISO 16840-
10 | The performance of resistance to
ignition meet the requirements of
ISO 16840-10 | The performance of resistance to
ignition meet the requirements of
ISO 7176-16 | S.E. |
| ISO 7176-21 | The EMC performance results meet the
requirements of ISO 7176-21 | The EMC performance results meet the
requirements of ISO 7176-21 | S.E. |

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JiaXing XiaoXiang Medical Equipment Technology Co.,Ltd No.24-101,Lane 587,Taoyuan Road,Xiuzhou,Jiaxing,Zhejiang,China

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JiaXing XiaoXiang Medical Equipment Technology Co.,Ltd No.24-101,Lane 587,Taoyuan Road,Xiuzhou,Jiaxing,Zhejiang,China

I. Conclusion

The conclusion drawn from the nonclinical tests demonstrates that the subject device in 510(K) submission, Power Wheelchair, Models: ME23-EW16-BC200-01, E23-EW16-BC200-02, is as safe, as effective, and performs as well as or better than the legally marketed predicate device cleared under K220747.