(106 days)
PureLift GLOW is intended for facial and neck stimulation, treatment of wrinkles, treatment of mild to moderate inflammatory acne, and indicated for over-the-counter cosmetic use.
PureLift GLOW is a hand-held device intended to apply electrical impulses to strategic locations on the face and Light Emitting Diode (LED) technology that is intended for the treatment of wrinkles and mild to moderate inflammatory acne. The PureLift GLOW probes are designed for optimal contact with the LED technology is not intended to come into contact with the user. The device continually alternates between the positive probes and allows the user to adjust the settings for personalized comfort level by pressing the intensity starts at (1) and continues to (10). The LED treatment area is approximately 36.3cm2 and available five levels of blue (465nm) and red (634nm) wavelengths. The device housing is injection molded of biocompatible thermoplastic resin and the probes consist of chrome-plated spheres. The device, powered by a 3.7-volt rechargeable battery, produces low-level current that is transmitted through the two fixed, smooth spherical probes. To turn the device on, the power button is pressed, and a green light illuminates to indicate that the unit is ready for use. Users then follow the instructions for use. The two probes gently glide over the skin to deliver low-level to strategic locations on the face and neck with the use of a conductive gel and the LED light is directed to the treatment area.
The document does not contain information regarding acceptance criteria or a study proving the device meets acceptance criteria. The document is an FDA 510(k) clearance letter for the PureLift GLOW device, which primarily discusses its substantial equivalence to predicate devices based on technological characteristics and intended use.
While the document states that "Clinical testing was not required to support a substantial equivalence determination" (page 6), it does not describe any specific acceptance criteria for performance metrics (such as sensitivity, specificity, or accuracy for medical devices often associated with AI/ML solutions) nor does it provide details of a study demonstrating the device meets such criteria.
The information provided pertains to bench performance testing to ensure safety and electrical performance, and a comparison table highlighting technological aspects with predicate devices. None of these describe acceptance criteria or a study in the context you've requested.
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March 6, 2025
Xtreem Pulse LLC Jacqueline Schmainda Regulatory Consultant 353 W. 29th St., Suite 3 New York, New York 10001
Re: K243587
Trade/Device Name: PureLift GLOW Regulation Number: 21 CFR 882.5890 Regulation Name: Transcutaneous Electrical Nerve Stimulator For Pain Relief Regulatory Class: Class II Product Code: NFO. OHS Dated: February 4, 2025 Received: February 4, 2025
Dear Jacqueline Schmainda:
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.
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"
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(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 OS 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 Rue"). 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-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-regulatoryassistance/contact-us-division-industry-and-consumer-education-dice) for more information or contact DICE by email (DICE@fda.hhs.gov) or phone (1-800-638-2041 or 301-796-7100).
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Sincerely,
Heather L. Dean -S
Heather Dean, PhD Assistant Director, Acute Injury Devices Team DHT5B: Division of Neuromodulation and
Physical Medicine Devices OHT5: Office of Neurological and
Physical Medicine Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health
Enclosure
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Indications for Use
Submission Number (if known)
Device Name
PureLift GLOW
Indications for Use (Describe)
PureLift GLOW is intended for facial and neck stimulation, treatment of wrinkles, treatment of mild to moderate inflammatory acne, and indicated for over-the-counter cosmetic use.
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)
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| 510(k) #: | K243587 |
|---|---|
| ----------- | --------- |
510(k) Summary
Prepared on: 2025-02-04
Contact Details
21 CFR 807.92(a)(1)
| Applicant Name | Xtreem Pulse LLC | |
|---|---|---|
| Applicant Address | 353 W. 29th St., Suite 3 New York NY 10001 United States | |
| Applicant Contact Telephone | 917-597-5436 | |
| Applicant Contact | Mr. Andrew Barile | |
| Applicant Contact Email | andrew@xtreempulse.com | |
| Correspondent Name | Jacqueline Schmainda | |
| Correspondent Address | United States | |
| Correspondent Contact Telephone | 763-269-2069 | |
| Correspondent Contact | jaschmainda@gmail.com | |
| Correspondent Contact Email | jaschmainda@gmail.com | |
| Device Name21 CFR 807.92(a)(2) | ||
| Device Trade Name | PureLift GLOW | |
| Common Name | Transcutaneous electrical nerve stimulator for pain relief | |
| Classification Name | Stimulator, Transcutaneous Electrical, Aesthetic Purposes | |
| Regulation Number | 882.5890 | |
| Product Code(s) | NFO | |
| Legally Marketed Predicate Devices21 CFR 807.92(a)(3) | ||
| Predicate # | Predicate Trade Name (Primary Predicate is listed first) | Product Code |
| K221443 | PureLift Pro Plus | NFO |
| K223482 | reVive Light Therapy® Wrinkle and Acne LED Device | OHS |
| K201782 | NuFace Trinity Plus Device | NFO |
| Device Description Summary21 CFR 807.92(a)(4) |
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PureLift GLOW is a hand-held device intended to apply electrical impulses to strategic locations on the face and Light Emitting Diode (LED) technology that is intended for the treatment of wrinkles and mild to moderate inflammatory acne.
The PureLift GLOW probes are designed for optimal contact with the LED technology is not intended to come into contact with the user. The device continually alternates between the positive probes and allows the user to adjust the settings for personalized comfort level by pressing the intensity starts at (1) and continues to (10). The LED treatment area is approximately 36.3cm2 and available five levels of blue (465nm) and red (634nm) wavelengths.
The device housing is injection molded of biocompatible thermoplastic resin and the probes consist of chrome-plated spheres. The device, powered by a 3.7-volt rechargeable battery, produces low-level current that is transmitted through the two fixed, smooth spherical probes. To turn the device on, the power button is pressed, and a green light illuminates to indicate that the unit is ready for use. Users then follow the instructions for use. The two probes qently qlide over the skin to deliver low-level to strategic locations on the face and neck with the use of a conductive gel and the LED light is directed to the treatment area.
Intended Use/Indications for Use
PureLift GLOW is intended for facial and neck stimulation, treatment of mild to moderate inflammatory acne, and indicated for over-the-counter cosmetic use.
Indications for Use Comparison
The subject device is intended for facial and neck stimulation, treatment of mild to moderate inflammatory acne, and indicated for over-the-counter cosmetic use. The same indication for use in comparison to the following predicate/reference devices:
- K223482 Predicate Device: intended for the treatment of wrinkles and mild to moderate inflammatory acne
- K210782 Reference Device:intended for facial and neck stimulation and over-the-counter cosmetic use
Technological Comparison
The subject has similar technological characteristics as comparison to the predicate/reference device.
Non-Clinical and/or Clinical Tests Summary & Conclusions 21 CFR 807.92(b)
21 CFR 807.92(a)(5)
21 CFR 807.92(a)(5)
21 CFR 807.92(a)(6)
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The following bench performance testing has been performed for the PureLift GLOW device:
- Power input
- Limitation of voltage, current or energy
- Accuracy of controls and instructions and protection against hazardous outputs
- Leakage currents and patient auxiliary currents
- Dielectric strength
- Accessible parts
- Acoustic energy
- Ball pressure
- Drop test
- Environment
- Marking
- Mold stress relief
- Push test
- Temperature
- Vibration
Clinical testing was not required to support a substantial equivalence determination.
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Substantial Comparison Table
| Item | PureLift GLOW | PureLift Pro Plus | NuFace Trinity Plus | reVive Light Therapy Wrinkleand Acne LED |
|---|---|---|---|---|
| 510(k) Number | K243587 | K221443 | K201782 | K223482 |
| Regulation | 21 CFR 882.5890 | 21 CFR 882.5890 | 21 CFR 882.5890 | 21 CFR 878.4810 |
| Product Code(s) | NFO/OLP | NFO | NFO | OHS/OLP |
| Class | Class II | Class II | Class II | Class II |
| Use Type | Over-the-Counter (OTC) | Over-the-Counter (OTC) | Over-the-Counter (OTC) | Over-the-Counter (OTC) |
| Device Name | Intended for facial and neckstimulation, treatment ofwrinkles, treatment of mild tomoderate inflammatory acne,and indicated for over-the-counter cosmetic use. | Intended for facial stimulationand indicated for over-the-counter cosmetic use. | The NuFace Trinity Plus Deviceis intended for facial and neckstimulation and indicated forover-the-counter cosmeticuse. | The reVive Light Wrinkle andLED Device is intended fortreatment of wrinkles and mildto moderate inflammatoryacne. |
| Irradiance Source | LED | N/A | N/A | LED |
| Anatomic Site | Face and Neck | Face | Face and Neck | Face |
| Treatment Area | 36.3cm2 | N/A | N/A | 7 cm2 |
| Type of Energy Output | Microcurrent | Microcurrent | Microcurrent | N/A |
| Treatment Method | Place directly on the skin | Place directly on the skin | N/A | Place directly on the skin |
| Treatment Time | 10 minutes | 10 minutes only | N/A | 3 minutes |
| Materials | Thermoplastic resinenclosures, chrome-platedspheres | Thermoplastic resinenclosures, chrome-platedspheres | N/A | N/A |
| Wavelengths (WrinkleTreatment) | 634nm | N/A | N/A | 605nm, 630nm, 660nm,880nm |
| Wavelengths (AcneTreatment) | 465nm | N/A | N/A | 415nm, 630nm |
| Item | PureLift GLOW | PureLift Pro Plus | NuFace Trinity Plus | reVive Light Therapy Wrinkleand Acne LED |
| Dimensions (H x W x D) | 14.6cm x 6.1cm x 4.4cm | 20.7cm x 4.8cm x 4.5cm | 5.2in x 2.6in x 1.6in | N/A |
| Power Source | One 3.7V battery | One 3.7V battery | Internal rechargeableLithium Ion battery | Battery or universal USB powersource |
| Number of output modes | 2 | 2 | N/A | N/A |
| Number of output channels | 1 | 1 | 1 | N/A |
| Regulated current orregulated voltage | Regulated current | Regulated current | Both | N/A |
| Software / Firmware /Microprocessor Control | Yes | Yes | Yes | N/A |
| Automatic Shut Off | Yes | Yes | Yes | N/A |
| Patient Override Control | No | No | Yes | N/A |
| Indicator Display | Yes | Yes | N/A | N/A |
| Timer Range | 10 minutes only | 10 minutes only | N/A | N/A |
| Type of Protection | Type BF | Type BF | Type BF | N/A |
| On / Off Status | Yes | Yes | Yes | N/A |
| Standards Compliance | ANSI/AAMI ES60601-1IEC 60601-1-2 | ANSI/ AAMI ES 60601-1IEC 60601-1-2IEC 60601-2-10IEC 60601-1-11 | N/A | ANSI/ AAMI ES 60601-1IEC 60601-1-2 |
| Biocompatibility | ISO 10993-5ISO 10993-10 | ISO 10993-5ISO 10993-10 | N/A | ISO 10993-5ISO 10993-10 |
| ltem | PureLift GLOW | PureLift Pro Plus | NuFace Trinity Plus | reVive Light Therapy Wrinkleand Acne LED |
| Waveform | Pulses monophasic,alternating polarity | Pulses monophasic,alternating polarity | N/A | N/A |
| Shape | Rectangular pulses | Rectangular pulses | N/A | N/A |
| Maximum Output Voltage | 9mA (@500Ω)4.4mA (@2kΩ)1.2mA (@10kΩ) | 9mA (@500Ω)4.4mA (@2kΩ)1.2mA (@10kΩ) | N/A | N/A |
| Maximum Output Current | 20Vpp (@500Ω)32Vpp (@2kΩ)44Vpp (@10kΩ) | 20Vpp (@500Ω)32Vpp (@2kΩ)44Vpp (@10kΩ) | N/A | N/A |
| Output Tolerance | ± 1mA | ± 1mA | N/A | N/A |
| Pulse Width | 4 µs | 4 µs | N/A | N/A |
| Frequency (Hz) | 1.37kHz ~ 1.73kHz | 1.37kHz ~ 1.73kHz | N/A | N/A |
| Symmetrical Phases | Non multiphasic | Non multiphasic | N/A | N/A |
| Phase Duration | 4 µs | 4 µs | N/A | N/A |
| Net Charge (µC per pulsetrain) | 0 us per pulse train | 0 µs per pulse train | N/A | N/A |
| MaximumPhase Charge(μC) | 5.81 µC @500Ω | 5.81 µC @500Ω | N/A | N/A |
| Maximum Current Density(mA/cm2) | 8.8 mA/cm² @500Ω | 8.8 mA/cm- @500Ω | N/A | N/A |
| Maximum Density Power | 39600 µW/cm² | 39600 µW/cm² | N/A | N/A |
| Pulse Per Burst | 30 pulses | 30 pulses | 20 (10 positive and 10negative) | N/A |
| Burst Per Second | 2740 ~ 3400 | 2740 ~ 3400 | 8.3 (@ 8.3 Hz) | N/A |
| Burst Duration | 230 us | 230 มร | 2.4s (@8.3 Hz) | N/A |
| Duty Cycle | 0.63 ~ 0.80 | 0.63 ~ 0.80 | Duty cyle: 50%Ontime per burst: 20.2s | N/A |
| ON Time (seconds) | Constant | Constant | 60 ms (@8.3 Hz) | N/A |
| ltem | PureLift GLOW | PureLift Pro Plus | NuFace Trinity Plus | reVive Light Therapy Wrinkleand Acne LED |
| Indicator Displays | On/off status, low battery,voltage current level | On/off status, low battery,voltage current level | On/off status, low battery,voltage current level | N/A |
| Accessory to Device | PureLift Activator Serum(biocompatible, 510(k) clearedper K221443) or othercosmetic conductive gel orserum | PureLift Activator Serum(biocompatible, 510(k) clearedper K221443) | NuFACE Gel Primer(biocompatible, 510(k) clearedper K161654) | N/A |
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§ 882.5890 Transcutaneous electrical nerve stimulator for pain relief.
(a)
Identification. A transcutaneous electrical nerve stimulator for pain relief is a device used to apply an electrical current to electrodes on a patient's skin to treat pain.(b)
Classification. Class II (performance standards).