K Number
K243362
Device Name
SmoothSkin Pure Switch (SSC1)
Manufacturer
Date Cleared
2024-11-27

(29 days)

Product Code
Regulation Number
878.4810
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The SmoothSkin Pure Switch is intended for the removal of unwanted hair. The SmoothSkin Pure Switch is also indicated for the permanent reduction in hair regrowth, defined as the long-term, stable reduction in the number of hairs regrowing when measured at 6, 9 and 12 months after the completion of a treatment regime.
Device Description
The SSC1 device is an over the counter IPL (Intense Pulsed Light) Hair Removal device for home use. The device is mains powered and consists of the handset, hardwired base unit and AC power cord. AC mains is fed into the AC to DC converter that is used to charge the electrical storage capacitor, the stored energy is used to produce an optical output from the flash lamp. Light energy is transferred through the skin's surface and is absorbed by melanin present in the hair shaft. The absorbed light energy is converted to heat energy (below the surface of the skin), which reduces the hairs growing back.
More Information

Not Found

No
The summary describes a standard IPL hair removal device and does not mention any AI or ML components or capabilities.

No
The device is used for hair removal and reduction of hair regrowth, which are cosmetic rather than therapeutic functions.

No

Explanation: The device is an IPL hair removal device for the permanent reduction of hair regrowth. Its intended use is not for diagnosing any medical condition.

No

The device description clearly states it is an IPL hair removal device consisting of a handset, base unit, and power cord, indicating it is a hardware device with electrical components.

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

Here's why:

  • Intended Use: The intended use is for "removal of unwanted hair" and "permanent reduction in hair regrowth." This is a cosmetic or therapeutic purpose, not a diagnostic one.
  • Device Description: The device uses Intense Pulsed Light (IPL) to target melanin in hair follicles. This is a physical interaction with the body, not an in vitro test of a sample taken from the body.
  • Lack of IVD Characteristics: The description does not mention any of the typical characteristics of an IVD, such as:
    • Analyzing a biological sample (blood, urine, tissue, etc.)
    • Detecting or measuring substances in a sample
    • Providing information for the diagnosis, monitoring, or treatment of a disease or condition based on sample analysis.

In summary, the SmoothSkin Pure Switch is a hair removal device that works by applying light energy to the skin. It does not perform any in vitro diagnostic testing.

N/A

Intended Use / Indications for Use

The SmoothSkin Pure Switch is intended for the removal of unwanted hair. The SmoothSkin Pure Switch is also indicated for the permanent reduction in hair regrowth, defined as the long-term, stable reduction in the number of hairs regrowing when measured at 6, 9 and 12 months after the completion of a treatment regime.

Product codes

OHT

Device Description

The SSC1 device is an over the counter IPL (Intense Pulsed Light) Hair Removal device for home use.

The device is mains powered and consists of the handset, hardwired base unit and AC power cord. AC mains is fed into the AC to DC converter that is used to charge the electrical storage capacitor, the stored energy is used to produce an optical output from the flash lamp.

Light energy is transferred through the skin's surface and is absorbed by melanin present in the hair shaft. The absorbed light energy is converted to heat energy (below the surface of the skin), which reduces the hairs growing back.

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

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

The device is compliant with the following Electrical Safety and Electromagnetic Compatibility standards.

  1. AAM / IEC 60601-1 : Medical Electrical Equipment - Part 1: General Requirements For Basic Safety And Essential Performance

  2. IEC 60601-1-6 : Medical Electrical Equipment - Part 1-6: General requirements for basic safety and essential performance - Collateral standard: Usability

  3. IEC 60601-2-57 : Medical 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, cosmetic and aesthetic use

  4. IEC 60601-2-83 : Medical Electrical Equipment Part 2-83: Particular requirement for the basic safety and essential performance of home light therapy equipment

  5. IEC 60601-1-2 : Part 1-2: General requirements for basic safety and essential performance - Collateral Standard: Electromagnetic disturbances - Requirements and tests

  6. IEC 62471 : Photobiological safety of lamps and lamp systems

The device is compliant with the following Biocompatibility standards

  1. ISO 10993-1 : Biological evaluation of medical devices Part 1: Evaluation and testing within a risk management process

  2. ISO 10993-5 : Biological evaluation of medical devices Part 5: Tests for in vitro cytotoxicity

  3. ISO 10993-10 : Biological evaluation of medical devices Part 10: Tests for skin sensitization

Key Metrics

Not Found

Predicate Device(s)

K233782, K143003

Reference Device(s)

Not Found

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.

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Image /page/0/Picture/2 description: The image contains the logo of the U.S. Food and Drug Administration (FDA). On the left is the Department of Health & Human Services logo. To the right of that is the FDA logo, which is a blue square with the letters "FDA" in white. To the right of the square is the text "U.S. FOOD & DRUG ADMINISTRATION" in blue.

November 27, 2024

CyDen Limited Adam Stephens Regulatory Engineer Block A, Bay Studios Business Park, Fabian Way, SA1 8QB Swansea. United Kingdom

Re: K243362

Trade/Device Name: SmoothSkin Pure Switch (SSC1) Regulation Number: 21 CFR 878.4810 Regulation Name: Laser Surgical Instrument For Use In General And Plastic Surgery And In Dermatology Regulatory Class: Class II Product Code: OHT Dated: October 29, 2024 Received: October 29, 2024

Dear Adam Stephens:

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

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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 Fu J = S Date: 2024.11.27 14:54:39
Date: 2024.11.27 14:54:39
-05:00 Date: 2024.11.27 14:54:39
-05:00 -05:00' Yan -05'00'

for Tanisha Hithe

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

Enclosure

3

Indications for Use

510(k) Number (if known) K243362

Device Name SmoothSkin Pure Switch (SSC1)

Indications for Use (Describe)

The SmoothSkin Pure Switch is intended for the removal of unwanted hair. The SmoothSkin Pure Switch is also indicated for the permanent reduction in hair regrowth, defined as the long-term, stable reduction in the number of hairs regrowing when measured at 6, 9 and 12 months after the completion of a treatment regime.

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

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510(k) #:510(k) SummaryPrepared on: 2024-10-29
Contact Details21 CFR 807.92(a)(1)
Applicant NameCyDen Limited
Applicant AddressBlock A, Bay Studios Business Park, Fabian Way, SA1 8QB Swansea United Kingdom
Applicant Contact Telephone+44 1792 274009
Applicant ContactMr. Adam Stephens
Applicant Contact Emailastephens@cyden.com
Device Name21 CFR 807.92(a)(2)
Device Trade NameSmoothSkin Pure Switch (SSC1)
Common NameLaser surgical instrument for use in general and plastic surgery and in dermatology
Classification NameLight Based Over-The-Counter Hair Removal
Regulation Number878.4810
Product Code(s)OHT
Legally Marketed Predicate Devices 21 CFR 807.92(a)(3)
Predicate #Predicate Trade Name (Primary Predicate is listed first)Product Code
K233782SmoothSkin Pure AdaptOHT
K143003SmoothSkin GoldOHT, GEX, Q
Device Description Summary21 CFR 807.92(a)(4)
The SSC1 device is an over the counter IPL (Intense Pulsed Light) Hair Removal device for home use.
The device is mains powered and consists of the handset, hardwired base unit and AC power cord. AC mains is fed into the AC to DC converter that is used to charge the electrical storage capacitor, the stored energy is used to produce an optical output from the flash lamp.
Light energy is transferred through the skin's surface and is absorbed by melanin present in the hair shaft. The absorbed light energy is converted to heat energy (below the surface of the skin), which reduces the hairs growing back.
Intended Use/Indications for Use21 CFR 807.92(a)(5)
The SmoothSkin Pure Switch is intended for the removal of unwanted hair. The SmoothSkin Pure Switch is also indicated for the permanent reduction in hair regrowth, defined as the long-term, stable reduction in the number of hairs regrowing when measured at 6, 9 and 12 months after the completion of a treatment regime.

Indications for Use Comparison

21 CFR 807.92(a)(5)

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Technological Comparison

The SSC1 device has the same following characteristics.

  • The same intended use.
  • Operates with the same mode of actions.
  • Has the same technological characteristics.
  • Has the same shelf-life.
  • Is manufactured and packed in the same manner.
  • Has the same safety features.

The following modification have been made to the SSC1 device.

  • Electronic design changes to incorporate a cooling function.

  • Attachments to allow the user to use the device in difficult areas.

  • Energy Output Parameters 2 - 6J/cm2 vs 3-6J/cm2 for predicate

Non-Clinical and/or Clinical Tests Summary & Conclusions

The device is compliant with the following Electrical Safety and Electromagnetic Compatibility standards.

  1. AAM / IEC 60601-1 : Medical Electrical Equipment - Part 1: General Requirements For Basic Safety And Essential Performance 2) IEC 60601-1-6 : Medical Electrical Equipment - Part 1-6: General requirements for basic safety and essential performance - Collateral standard: Usability

  2. IEC 60601-2-57 : Medical 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, cosmetic and aesthetic use

  3. IEC 60601-2-83 : Medical Electrical Equipment Part 2-83: Particular requirement for the basic safety and essential performance of home light therapy equipment

  4. IEC 60601-1-2 : Part 1-2: General requirements for basic safety and essential performance - Collateral Standard: Electromagnetic disturbances - Requirements and tests

  5. IEC 62471 : Photobiological safety of lamps and lamp systems

The device is compliant with the following Biocompatibility standards

  1. ISO 10993-1 : Biological evaluation of medical devices Part 1: Evaluation and testing within a risk management process

  2. ISO 10993-5 : Biological evaluation of medical devices Part 5: Tests for in vitro cytotoxicity

  3. ISO 10993-10 : Biological evaluation of medical devices Part 10: Tests for skin sensitization

21 CFR 807.92(a)(6)

21 CFR 807.92(b)