K Number
K242747
Device Name
FAQ™ (302)
Manufacturer
Date Cleared
2024-12-11

(90 days)

Product Code
Regulation Number
890.5500
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
FAQ™ 302 is indicated to promote hair growth in males with androgenetic alopecia who have Hamilton-Norwood Classifications of Ila-V and females with androgenetic alopecia who have Ludwig-Savin Classifications of I-II and Fitzpatrick Classification of Skin Phototypes I to IV.
Device Description
FAQ™ 302 is a handheld rechargeable square shaped device designed for improving hair growth with 20 laser diodes (wavelength 650±10m) and 20 RED LED beads (640-660nm) on the inside surface. By pressing the universal button, the user can power the device on, start treatment and change the intensity by quick-pressing the button again. Once the treatment is complete, the device is turned off by pressing and holding the universal power button for 3 seconds. The device can also be connected wirelessly via Bluetooth to an FAQ App in order to manage treatment. After the treatment is completed, the device automatically powers off. The device uses a non-detachable polymer lithium battery for power supply in compliance with IEC 62133-2:2017+A1:2021 standard.
More Information

Not Found

No
The description focuses on the hardware (laser diodes, LEDs) and basic functionality (powering on/off, intensity control, Bluetooth connectivity to an app for management). There is no mention of AI, ML, or any features that would suggest adaptive learning, image analysis, or complex data processing beyond simple control and logging.

Yes
The device is indicated to "promote hair growth in males with androgenetic alopecia" by using laser diodes and RED LED beads, which aligns with the definition of a therapeutic device designed for treating a medical condition.

No

The device is indicated to promote hair growth in individuals with androgenetic alopecia and does not mention any diagnostic functions or capabilities.

No

The device description explicitly states it is a "handheld rechargeable square shaped device" with "20 laser diodes" and "20 RED LED beads," indicating it is a physical hardware device, not software only.

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

Here's why:

  • Intended Use: The intended use is to "promote hair growth in males with androgenetic alopecia" and "females with androgenetic alopecia". This is a therapeutic or cosmetic purpose, not a diagnostic one.
  • Device Description: The device uses laser diodes and LED beads to deliver light therapy. This is a physical intervention, not a method for examining specimens from the human body to provide information for diagnosis, monitoring, or treatment.
  • Lack of Diagnostic Elements: There is no mention of analyzing biological samples (blood, urine, tissue, etc.), detecting biomarkers, or providing diagnostic information.

IVD devices are specifically designed to be used in vitro (outside the body) to examine specimens and provide information for diagnostic purposes. This device operates in vivo (on the body) and aims to treat a condition.

N/A

Intended Use / Indications for Use

FAO™ 302 is indicated to promote hair growth in males with androgenetic alopecia who have Hamilton-Norwood Classifications of Ila-V and females with androgenetic alopecia who have Ludwig-Savin Classifications of I-II and Fitzpatrick Classification of Skin Phototypes I to IV.

Product codes

OAP

Device Description

FAQ™ 302 is a handheld rechargeable square shaped device designed for improving hair growth with 20 laser diodes (wavelength 650±10m) and 20 RED LED beads (640-660nm) on the inside surface.

By pressing the universal button, the user can power the device on, start treatment and change the intensity by quick-pressing the button again. Once the treatment is complete, the device is turned off by pressing and holding the universal power button for 3 seconds.

The device can also be connected wirelessly via Bluetooth to an FAQ App in order to manage treatment. After the treatment is completed, the device automatically powers off.

The device uses a non-detachable polymer lithium battery for power supply in compliance with IEC 62133-2:2017+A1:2021 standard.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

hair growth / hair loss

Indicated Patient Age Range

Not Found

Intended User / Care Setting

Home Use, over the counter

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 Performed:
Clinical testing was considered not to be needed for this 510(k).

The following non-clinical testing was provided in this 510(k):

Biocompatibility Testing
The subject device has been tested in compliance with the following standards and no additional risks concerning safety and effectiveness were noted;

  • ISO 10993-5, Biological Evaluation of Medical Devices Part 5: Tests for In Vitro Cytotoxicity
  • ISO 10993-10, Biological Evaluation of Medical Devices Part 10: Tests for Irritation and Skin Sensitization.
  • ISO 10993-23 Biological evaluation of medical devices Part 23: Tests for irritation

Electrical Safety and Electromagnetic Compatibility Testing

CategoryStandardsStandards Desc
SafetyIEC 60601-1:2005/AMD1:2012/AMD2:2020 CAN/CSA-C22.2 NO. 60601-1:14 AAMI 60601-1:2005 + AMD 1:2012Medical electrical equipment - Part 1: General requirements for basic safety and essential performance
SafetyIEC 60601-1-6:2010+ AMD1:2013 +AMD2:2020Medical electrical equipment - Part 1-6: General requirements for basic safety and essential performance - Collateral standard: Usability
SafetyIEC 62366-1:2015+ AMD1:2020Medical devices - Part 1: Application of usability engineering to medical devices
SafetyIEC 60601-1-11:2015+AMD1:2020Medical 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
SafetyIEC 60601-2-57: 2011Medical electrical equipment - Part 2-57: Particular requirements for the basic safety and essential performance of non-laser light source equipment intended for therapeutic, diagnostic, monitoring and cosmetic/aesthetic use
EMCEN 60601-1-2: 2015 IEC 60601-1-2: 2014 (Edition 4)Medical electrical equipment - Part 1-2: General requirements for basic safety and essential performance - Collateral Standard: Electromagnetic disturbances - Requirements and tests
EMCIEC TR 60601-4-2:2016Medical electrical equipment - Part 4-2: Guidance and interpretation - Electromagnetic immunity: performance of medical electrical equipment and medical electrical systems

Software Verification and Validation
Software documentation consistent with Minor level of concern was submitted in this 510(k) per the FDA guidance document, "Content of Premarket Submissions for Device Software Functions" issued on June 14, 2023. 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.

Cybersecurity
The cybersecurity risks associated with the FAQ™ 302 were evaluated as follows:

  • Identification of assets, threats, and vulnerabilities;
  • Assessment of impact of threats and vulnerabilities on device functionality and end user;
  • Assessment of the likelihood of threats and of a vulnerability being exploited;
  • Determination of risk levels and suitable mitigation strategies;
  • Assessment of residual risk and risk acceptance criteria

The cybersecurity risk analysis performed, the controls identified, the comparison with the National Vulnerability Database, and the labeling information detailed with the Cybersecurity Assessment demonstrated that all risks associated with network capable interfaces of the device have been adequately mitigated.

Usability Study:
Usability validation testing was conducted with 15 adults enrolled to assure that the user could follow the directions we provided to safely use the device. Test results can be located in the "Usability validation report" that clearly indicate that the user instruction of FAQ 302 provides adequate guidance for the independent and appropriate home use for Laser and LED treatment.

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

Not Found

Predicate Device(s)

K210169, K142573

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 890.5500 Infrared lamp.

(a)
Identification. An infrared lamp is a device intended for medical purposes that emits energy at infrared frequencies (approximately 700 nanometers to 50,000 nanometers) to provide topical heating.(b)
Classification. Class II (special controls). The device, when it is an infrared therapeutic heating lamp, is exempt from the premarket notification procedures in subpart E of part 807 of this chapter subject to the limitations in § 890.9.

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December 11, 2024

Foreo Inc. % Danijela Domljanovic Consultant DD Consulting 401-4080 Living Arts Drive Mississauga, ON L5B4N# Canada

Re: K242747

Trade/Device Name: Faq™ (302) Regulation Number: 21 CFR 890.5500 Regulation Name: Infrared Lamp Regulatory Class: Class II Product Code: OAP Dated: August 13, 2024 Received: September 12, 2024

Dear Danijela Domljanovic:

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.

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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 medical devices and radiation-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,

Digitally signed by YAN

YAN FU -S FU-S
Date: 2024.12.11 17:37:39
-05'00'

for 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

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Indications for Use

510(k) Number (if known) K242747

Device Name FAOTM (302)

Indications for Use (Describe)

FAO™ 302 is indicated to promote hair growth in males with androgenetic alopecia who have Hamilton-Norwood Classifications of Ila-V and females with androgenetic alopecia who have Ludwig-Savin Classifications of I-II and Fitzpatrick Classification of Skin Phototypes I to IV.

Type of Use (Select one or both, as applicable)
Prescription Use (Part 21 CFR 801 Subpart D)
Over-The-Counter Use (21 CFR 801 Subpart C)

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510(k) Summary

Date of Summary Revision: 28-Aug-2024

Submitter's Identifications 1.

Submitter's Name: FOREO Inc. Address: 1525 E Pama Lane, Las Vegas, NV, USA ZIP Code: 89119 Contact Person: Evan Feldstein Contact Title: General Manager Contact E-mail Address: evan.feldstein@foreo.com Telephone: 419 376 1923

2. Correspondent's Identifications

Correspondent's Name: DD Consulting Address: 401-4080 Living Arts Drive, Mississauga, ON Canada ZIP Code: L5B 4N3 Contact Person: Danijela Domljanovic Contact Title: Regulatory Consultant Contact E-mail Address: regulatoryna@foreo.com Telephone: 647 928 6919

Name of the Device 3.

Trade Name: FAQ Model: FAQ 302 Regulation Number: 21 CFR 890.5500 Regulation Name: Infrared Lamp Common Name: Laser, Comb, Hair Regulatory Class: Class II Product Code: OAP Review Panel: General & Plastic Surgery

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4. The Predicate Devices

Primary Predicate: K210169 Hair Growth Device Primary Predicate: HairMax LaserComb 41

Device Description 5.

FAQ™ 302 is a handheld rechargeable square shaped device designed for improving hair growth with 20 laser diodes (wavelength 650±10m) and 20 RED LED beads (640-660nm) on the inside surface.

By pressing the universal button, the user can power the device on, start treatment and change the intensity by quick-pressing the button again. Once the treatment is complete, the device is turned off by pressing and holding the universal power button for 3 seconds.

The device can also be connected wirelessly via Bluetooth to an FAQ App in order to manage treatment. After the treatment is completed, the device automatically powers off.

The device uses a non-detachable polymer lithium battery for power supply in compliance with IEC 62133-2:2017+A1:2021 standard.

Intended Use of Device 6.

FAQ™ 302 is indicated to promote hair growth in males with androgenetic alopecia who have Hamilton-Norwood Classifications of Ila-V and females with androgenetic alopecia who have Ludwig-Savin Classifications of I-II and Fitzpatrick Classification of Skin Phototypes I to IV.

Comparison with Predicate Device 7.

Table 1 Table Comparison of FAQ 302,LS-D601 (K210169) and HairMax LaserComb 41(K142573)

FeaturesSubject DevicePredicate DevicePredicate DeviceRemarks
Regulatory Information
Device NameFAQ™ 302Hair Growth DeviceHairMax LaserComb 41/
510(K) No.K242747K210169K142573/
Regulation Number890.5500890.5500890.5500Same
Regulation nameInfrared LampInfrared LampInfrared LampSame
Regulatory ClassIIIIIISame
Product CodeOAPOAPOAPSame
Indications for UseFAQ™ 302 is indicated to
promote hair growth in
males with androgenetic
alopecia who have
Hamilton-Norwood
Classifications of IIa-V and
females with androgenetic
alopecia who have Ludwig-
Savin Classifications of I-II
and Fitzpatrick
Classification of Skin
Phototypes I to IVThe Hair Growth Device
is indicated to promote
hair growth in males
with androgenetic
alopecia who have
Hamilton-Norwood
Classifications of IIa-V
and females with
androgenetic alopecia
who have Ludwig-Savin
Classifications of1-II and
Fitzpatrick Classification
of Skin Phototypes I to
IV.The HairMax LaserComb
41 is indicated to treat
Androgenetic alopecia
and promote hair growth
in males who have
Norwood Hamilton
Classifications of IIa to V
patterns of hair loss and
treat Androgenetic
alopecia and, promote
hair growth in females
who have Ludwig (Savin)
Scale I-4, II-1, II-2, or
frontal, both with
Fitzpatrick Skin Types I to
IV.Same
Treatment
regimen8 minutes every other day25 minutes every other day3 minutes per use,
three times per weekDifferent
Note 1
Use EnvironmentHome Use, over the
counterHome Use, over the
counterHome Use, over the
counterSame
Power Source(s)Internal rechargeable
Lithium batteryPower adapterInternal rechargeable
Lithium batteryDifferent
Note 2
Maximum charging time90 minsNot applicableUnknown/
Electrical Power Source
Frequency (Nominal)60Hz60 Hz60 HzSame
Method of Channel
IsolationType BFType BFType BFSame
Automatic Shut OffYesYesYesSame
Mode of operationLow-level laser diodes and
light emitting diodesLow-level laser diodes and
light emitting diodesLow-level laser diodesSimilar
Output modeContinuous lightContinuous lightContinuous lightSame
Classification
according to IEC
60825-1Class 3RClass 3RClass 3RSame
Energy of per
laser diode