K Number
K242385
Device Name
LED Therapy Mask (MN1, M226)
Date Cleared
2025-04-07

(238 days)

Product Code
Regulation Number
878.4810
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
Red light: Treatment of full- face wrinkles. Blue light (only suitable model M226 and MN1 LED Facial Mask): Treatment of mild to moderate inflammatory acne. Infrared light: Provide topical heating for the purpose of elevating tissue temperature; arthritis and muscle spasm; relieving stiffness; promoting the relaxation of muscle tissue; and to temporarily increase local blood circulation. Mixed light: Treatment of full face wrinkles.
Device Description
The subject device LED Therapy Mask is a home use wearable LED phototherapy device whose purpose is to produce an even and narrowband of light for the treatment of cosmetic indications including facial wrinkles and acnes. The subject device consists of a mask body unit that contains light emitting diodes (LEDs), a controller, straps and Type-C charging cable. And the device is powered by built-in rechargeable lithium battery on the controller.
More Information

No.
The document describes an LED phototherapy device that uses different light wavelengths for treatment, with no mention of AI, machine learning, or any form of data processing that would require an AI model.

Yes
The device is described as treating various medical conditions such as mild to moderate inflammatory acne, arthritis, and muscle spasm, and promoting relaxation of muscle tissue and increasing local blood circulation, which are therapeutic uses.

No

The device description and intended use clearly state that the LED Therapy Mask is for "treatment of full-face wrinkles," "treatment of mild to moderate inflammatory acne," and "providing topical heating" associated with certain conditions. It is a therapy device, not one that identifies or diagnoses medical conditions.

No

The device is described as an "LED Therapy Mask" consisting of a "mask body unit that contains light emitting diodes (LEDs), a controller, straps and Type-C charging cable." This explicitly indicates physical hardware components beyond just software. The mention of biocompatibility, electrical safety, EMC, and eye safety testing further confirms it is a hardware device with embedded software, not a software-only medical device.

No.

The device is an LED phototherapy mask for treating cosmetic indications (wrinkles, acne, muscle pain/stiffness). It directly applies light to the body for a therapeutic effect. It does not perform an in vitro examination of specimens derived from the human body.

N/A

Intended Use / Indications for Use

Red light: Treatment of full- face wrinkles.

Blue light (only suitable model M226 and MN1 LED Facial Mask): Treatment of mild to moderate inflammatory acne.

Infrared light: Provide topical heating for the purpose of elevating tissue temperature; arthritis and muscle spasm; relieving stiffness; promoting the relaxation of muscle tissue; and to temporarily increase local blood circulation.

Mixed light: Treatment of full face wrinkles.

Product codes

OHS, ILY, OLP

Device Description

The subject device LED Therapy Mask is a home use wearable LED phototherapy device whose purpose is to produce an even and narrowband of light for the treatment of cosmetic indications including facial wrinkles and acnes.

The subject device consists of a mask body unit that contains light emitting diodes (LEDs), a controller, straps and Type-C charging cable. And the device is powered by built-in rechargeable lithium battery on the controller.
The LEDs generate 4 kinds of light which include Blue light (460nm, only suitable model M226 and MN1 LED Facial Mask), Red light (630nm), Infrared light (850nm) and Mixed light (630nm and 850nm). A controller is connect to the mask body unit to control the device, such as turn on/off the device, switch LED output. And the straps used for securing the mask unit to the body part.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

Face and Neck

Indicated Patient Age Range

Not Found

Intended User / Care Setting

home use

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 Evaluation The biocompatibility evaluation for the body-contacting components of the Intense pulsed light 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 –Part 5: Tests for in vitro cytotoxicity
  • ISO 10993-10:2021, Biological evaluation of medical devices –Part 10: Tests for skin sensitization
  • ISO 10993-23:2021, Biological evaluation of medical devices –Part 23: Tests for skin irritation
  1. Electrical Safety and EMC Electrical safety and EMC testing was performed to, and passed, as per the following standards:
  • IEC 60601-1-2 Edition 4.1 2020-09 Medical electrical equipment –Part 1-2: General requirements for basic safety and essential performance –Collateral standard: electromagnetic compatibility
  • ANSI AAMI ES60601-1:2005/(R)2012 & A1:2012 C1:2009/(R)2012 & A2:2010/(R)2012 (Cons. Text) [Incl. AMD2:2021] Medical electrical equipment - Part 1: General requirements for basic safety and essential performance (IEC 60601-1:2005, MOD)
  • IEC 60601-1-11 Edition 2.1 2020-07 Medical electrical equipment - Part 1-11: 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 60601-2-83:2019 Medical electrical equipment - Part 2-83: Particular requirements for the basic safety and essential performance of home light therapy equipment
  • IEC 62133-2 Edition1.0 2017-02, Secondary cells and batteries containing alkaline or other non-acid electrolytes - Safety requirements for portable sealed secondary cells, and for batteries made from them, for use in portable applications - Part 2: Lithium systems
  1. Eye Safety
  • IEC 62471 Photobiological safety of lamps and lamp systems
  1. 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.

  2. Usability
    The product usability has been evaluated and verified according to the following FDA guidance - Applying Human Factors and Usability Engineering to Medical Devices, issued on FEBRUARY 2016.

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

Not Found

Predicate Device(s)

K223544

Reference Device(s)

K223147, K140471, K133896

Predetermined Change Control Plan (PCCP) - All Relevant Information

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.

FDA 510(k) Clearance Letter - LED Therapy Mask

Page 1

U.S. Food & Drug Administration
10903 New Hampshire Avenue Doc ID# 04017.07.05
Silver Spring, MD 20993
www.fda.gov

April 7, 2025

Shenzhen Borria Technology Co., Ltd
Chardy Wang
Project Leader
501, Floor 5, Building 6, Industrial Zone, No.2015, Shenyan Road, Pengwan Community, Haishan Street, Yantian District
Shenzhen,
China

Re: K242385
Trade/Device Name: LED Therapy Mask (MN1, M226)
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: OHS, ILY, OLP
Dated: August 12, 2024
Received: August 12, 2024

Dear Chardy Wang:

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.

Page 2

K242385 - Chardy Wang Page 2

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 (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-reporting-combination-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-devices/device-advice-comprehensive-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-devices/medical-device-safety/medical-device-reporting-mdr-how-report-medical-device-problems.

For comprehensive regulatory information about medical devices and radiation-emitting products, including information about labeling regulations, please see Device Advice (https://www.fda.gov/medical-devices/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.

Page 3

K242385 - Chardy Wang Page 3

See the DICE website (https://www.fda.gov/medical-devices/device-advice-comprehensive-regulatory-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,

TANISHA L. HITHE -S Digitally signed by TANISHA L. HITHE -S Date: 2025.04.07 17:08:19 -04'00'

Tanisha Hithe
Assistant Director
DHT4A: Division of General Surgery Devices
OHT4: Office of Surgical and Infection Control Devices
Office of Product Evaluation and Quality
Center for Devices and Radiological Health

Enclosure

Page 4

DEPARTMENT OF HEALTH AND HUMAN SERVICES
Food and Drug Administration

Indications for Use

Form Approved: OMB No. 0910-0120
Expiration Date: 06/30/2023
See PRA Statement below.

510(k) Number (if known): K242385

Device Name: LED Therapy Mask (MN1, M226)

Indications for Use (Describe):

Red light: Treatment of full- face wrinkles.

Blue light (only suitable model M226 and MN1 LED Facial Mask): Treatment of mild to moderate inflammatory acne.

Infrared light: Provide topical heating for the purpose of elevating tissue temperature; arthritis and muscle spasm; relieving stiffness; promoting the relaxation of muscle tissue; and to temporarily increase local blood circulation.

Mixed light: Treatment of full face wrinkles.

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

☐ Prescription Use (Part 21 CFR 801 Subpart D)
☒ Over-The-Counter Use (21 CFR 801 Subpart C)

CONTINUE ON A SEPARATE PAGE IF NEEDED.

This section applies only to requirements of the Paperwork Reduction Act of 1995.

DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.

The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to:

Department of Health and Human Services
Food and Drug Administration
Office of Chief Information Officer
Paperwork Reduction Act (PRA) Staff
PRAStaff@fda.hhs.gov

"An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB number."

Page 5

SHENZHEN BORRIA TECHNOLOGY CO.,LTD

K242385 –510(k) Summary

510(k) Summary-K242385

"510(k) Summary" as required by 21 CFR Part 807.92.
April 2, 2025

I. Submitter

SHENZHEN BORRIA TECHNOLOGY CO.,LTD
501, Floor 5, Building 6, Industrial Zone, No.2015, Shenyan Road, Pengwan Community, Haishan Street, Yantian District, Shenzhen
Chardy Wang
Project Leader
Tel: +86 133 1290 5505
Email: 466144494@qq.com

II. Device

Name of Device: LED Therapy Mask
Model(s): MN1, M226
Regulation Name: Laser Surgical Instrument For Use In General And Plastic Surgery And In Dermatology
Regulatory Class: II
Product Code: OHS, OLP, ILY
Regulation Number: 21 CFR 878.4810

III. Predicate Device and Reference Device

Predicate device:

ManufacturerPredicate Device510(k) NumberApproval Date
Guangdong Newdermo Biotech Co., LtdLED light therapy mask (FM-01, FM-02, FM-03)K223544Feb 23, 2023

Page 6

Reference device 1:

ManufacturerReference Device510(k) NumberApproval Date
myBlendMyLedMaskK223147May 14, 2023

Reference device 2:

ManufacturerReference Device510(k) NumberApproval Date
La Lumiere, LLCPro X OTC 5 Light Therapy DeviceK140471Jan 15, 2025

Reference device 3:

ManufacturerReference Device510(k) NumberApproval Date
Trophy Skin IncorporatedRejuvalite MDK133896Nov 13, 2014

IV. Device Description

The subject device LED Therapy Mask is a home use wearable LED phototherapy device whose purpose is to produce an even and narrowband of light for the treatment of cosmetic indications including facial wrinkles and acnes.

The subject device consists of a mask body unit that contains light emitting diodes (LEDs), a controller, straps and Type-C charging cable. And the device is powered by built-in rechargeable lithium battery on the controller.

Page 7

The LEDs generate 4 kinds of light which include Blue light (460nm, only suitable model M226 and MN1 LED Facial Mask), Red light (630nm), Infrared light (850nm) and Mixed light (630nm and 850nm). A controller is connect to the mask body unit to control the device, such as turn on/off the device, switch LED output. And the straps used for securing the mask unit to the body part.

V. Indications for Use

Red light: Treatment of full- face wrinkles.

Blue light (only suitable model M226 and MN1 LED Facial Mask): Treatment of mild to moderate inflammatory acne.

Infrared light: Provide topical heating for the purpose of elevating tissue temperature; arthritis and muscle spasm; relieving stiffness; promoting the relaxation of muscle tissue; and to temporarily increase local blood circulation.

Mixed light: Treatment of full face wrinkles.

VI. Comparison of Technological Characteristics With the Predicate Devices

Comparison ElementsSubject DevicePrimary Predicate DeviceReference Device 1Reference Device 2Reference Device 3Remark
510(k) NumberPendingK223544K223147K140471K133896/
Trade nameLED Therapy Mask (MN1, M226)LED light therapy mask (FM-01, FM-02, FM-03)MyLedMaskPro X OTC 5 Light Therapy DeviceRejuvalite MD/

Page 8

Comparison ElementsSubject DevicePrimary Predicate DeviceReference Device 1Reference Device 2Reference Device 3Remark
ManufacturerSHENZHEN BORRIA TECHNOLOGY CO., LTDGuangdong Newdermo Biotech Co., LtdmyBlendLa Lumiere, LLCTrophy Skin Incorporated/
Regulation number21 CFR 878.481021 CFR 878.481021 CFR 878.481021 CFR 878.481021 CFR 878.4810Same
Product codeOHS, OLP, ILYOHS, OLP, ILYOHSOHSOHS
Device classificationClass IIClass IIClass IIClass IIClass IISame
Indication for use/ Intended useRed light: Treatment of full-face wrinkles. Blue light (only suitable model M226 and MN1 LED Facial Mask): Treatment of mild to moderate inflammatory acne. Infrared light: Provide topical heating for the purpose of elevating tissue temperature; arthritis and muscle spasm; relieving stiffness; promotingRed light: Treatment of fullface wrinkles. Blue light: Treatment of mild to moderate inflammatory acne. Infrared light: Provide topical heating for the purpose of elevating tissue temperature; arthritis and muscle spasm; relieving stiffness; promoting the relaxation of muscle tissue; and to temporarilyMyLedMask is an over-the-counter device that is intended to emit energy in the visible and infrared region of the spectrum for use in the treatment of fullface wrinklesThe Pro XOTC 5is an Over-TheCounter device intended for use in the treatment of facial wrinkles. It is for people with wrinkles on their face and who have Fitzpatrick skin types I,II and/or III.The Rejuvalite MD is an Over the Counter device that is intended for the use in the treatment of full face wrinkles.Same

Page 9

Comparison ElementsSubject DevicePrimary Predicate DeviceReference Device 1Reference Device 2Reference Device 3Remark
the relaxation of muscle tissue; and to temporarily increase local blood circulation. Mixed light: Treatment of mild to moderate inflammatory acne.increase local blood circulation. Mixed light: Treatment of mild to moderate inflammatory acne.
Indication for use/ Intended useRed light: Treatment of full-face wrinkles. Blue light (only suitable model M226 and MN1 LED Facial Mask): Treatment of mild to moderate inflammatory acne. Infrared light: Provide topical heating for the purpose of elevating tissue temperature; arthritis and muscle spasm; relieving stiffness; promoting the relaxation of muscle tissue; and to temporarily increase local blood circulation. Mixed light: Treatment of full face wrinkles.Red light: Treatment of fullface wrinkles. Blue light: Treatment of mild to moderate inflammatory acne. Infrared light: Provide topical heating for the purpose of elevating tissue temperature; arthritis and muscle spasm; relieving stiffness; promoting the relaxation of muscle tissue; and to temporarilyMyLedMask is an over-the-counter device that is intended to emit energy in the visible and infrared region of the spectrum for use in the treatment of fullface wrinklesThe Pro XOTC 5is an Over-TheCounter device intended for use in the treatment of facial wrinkles. It is for people with wrinkles on their face and who have Fitzpatrick skin types I,II and/or III.The Rejuvalite MD is an Over the Counter device that is intended for the use in the treatment of full face wrinkles.Same

Page 10

Comparison ElementsSubject DevicePrimary Predicate DeviceReference Device 1Reference Device 2Reference Device 3Remark
Location for useFace and NeckFace and bodyFace and NeckFull FaceFull FaceSame
Prescription or OTCOTCOTCOTCOTCOTCSame
Power supplyInput:DC 5V, 1A Built-in rechargeable lithium battery: DC 3.7V 2500mAhInput: 100-240 V~, 50/60 Hz, 0.25 A Output: DC 5 V, 500 mAVoltage: 100 to 240 volts, AC Frequency:50-60Hz Intensity: 0.35 AUnknownAC to DCSame
Light sourceLEDsLEDsLEDsLight-emitting diodesLEDsSame
WavelengthRed: 630nm±5nm Blue: 470 nm± 5nm Near-Infrared: 850 nm±5nmRed: 620nm Blue: 460nm Infrared: 850nm Mixed: 620nm and 850nm and 460nmRed:630 nm (OSRAM LS T67F) NIR: 850 nm (OSRAM SFH 4253)Red: 620-640nm IR: 820-880nmRed 600,622,660nm IR 860nmSimilar Note 1

Page 11

Comparison ElementsSubject DevicePrimary Predicate DeviceReference Device 1Reference Device 2Reference Device 3Remark
Mixed light: 630nm and 850nm
LED IntensityRed: 0.892.55mW/cm² Blue: 1.444.09mW/cm² Near-Infrared: 1.833.05mW/cm² Mixed light: 0.952.64mW/cm²Red light: 2.03.0 mW/cm² Blue light: 2.04.0 mW/cm² Infrared light: 2.04.0 mW/cm² Mixed light: 9.012.0 mW/cm²18.7 mW/cm² (average of 6 measurement location (including one on the neck) between 10 to 27mW/cm²)Red light and IR light: 0.76 mW/cm²Red light and IR light: 2.35 mW/cm²Similar Note 2
Dimensions (mm)MN1: LED Facial Mask: 300208.55.5mm LED Neck Mask: 338.5249.75.5mm M226: LED Facial Mask: 300208.55.5mmFM-01: 207X277X43mm, FM-02: 198X383X33.5mm, FM-03: 237.5X108X8.1mmLED mask: 176 x342 x 122 Storage case:365 x 225 x150UnknownUnknownDifferent Note 3
Treatment Time10 minutes each timeManual Mode: 15minutes each time, Automatic Mode: 10minutes each timeAccording to skin phototype, daily - 1 fair skin: 5 min 35 (335 s) - 2 moderately dark skin: 11 min 10 (670 s) - 3 dark900 seconds3 minutes daily, 5 days per week for 8 weeks

Page 12

Comparison ElementsSubject DevicePrimary Predicate DeviceReference Device 1Reference Device 2Reference Device 3Remark
skin: 13 min 55 (835 s) during 6 to 8 week
Electrical safetyIEC 60601-1 IEC 60601-1-2 IEC 60601-1-11 IEC 60601-2-83 IEC 62471 IEC 62133-2IEC 60601-1 IEC 60601-1-2 IEC 60601-1-11 IEC 60601-2-57IEC 60601-1 IEC 60601-1-2 IEC 60601-2-57UnknownIEC 60601-1 IEC 60601-1-2Same
Biocompatibility featureAll body-contacting materials are complied with ISO 10993-5, ISO 10993-10 and ISO 10993-23All body-contacting materials are complied with ISO10993-5 and ISO 10993-10UnknownUnknownUnknownSame

VII. Performance Data

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

1) Biocompatibility Evaluation

The biocompatibility evaluation for the body-contacting components of the Intense pulsed light 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:

Page 13

  • ISO 10993-5:2009, Biological evaluation of medical devices –Part 5: Tests for in vitro cytotoxicity
  • ISO 10993-10:2021, Biological evaluation of medical devices –Part 10: Tests for skin sensitization

ISO 10993-23:2021, Biological evaluation of medical devices –Part 23: Tests for skin irritation

2) Electrical Safety and EMC

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

  • IEC 60601-1-2 Edition 4.1 2020-09 Medical electrical equipment –Part 1-2: General requirements for basic safety and essential performance –Collateral standard: electromagnetic compatibility
  • ANSI AAMI ES60601-1:2005/(R)2012 & A1:2012 C1:2009/(R)2012 & A2:2010/(R)2012 (Cons. Text) [Incl. AMD2:2021] Medical electrical equipment - Part 1: General requirements for basic safety and essential performance (IEC 60601-1:2005, MOD)
  • IEC 60601-1-11 Edition 2.1 2020-07 Medical electrical equipment - Part 1-11: 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 60601-2-83:2019 Medical electrical equipment - Part 2-83: Particular requirements for the basic safety and essential performance of home light therapy equipment
  • IEC 62133-2 Edition1.0 2017-02, Secondary cells and batteries containing alkaline or other non-acid electrolytes - Safety requirements for portable sealed secondary cells, and for batteries made from them, for use in portable applications - Part 2: Lithium systems

3) Eye Safety

  • IEC 62471 Photobiological safety of lamps and lamp systems

4) Software Verification and Validation

Page 14

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 FDA guidance

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

VIII. Conclusions

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