K Number
K243961
Device Name
Electrically Powered Wheelchair
Date Cleared
2025-02-12

(51 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 product consists of frame, wheels, seat, armrest, lithium battery, motor and controller with a lightweight and compact design. The whole wheelchair can be folded and it can be easily carried or rolled after folding. The seat cushion is detachable. The armrest can be flipped upside down, which is convenient for the elderly to move. Users can drive the wheelchair by themselves through the control device. The wheelchair uses lithium batteries as its power source. The controls the drive leftright motor to realize the wheelchair forward, backward and turn functions. The frame of the device is aluminum alloy. The front wheels suitable for rotation, acceleration, retrograde and other actions of the wheelchair. The front wheels movement will be achieved by thrust generated from the rear wheels are driving wheels to control the speed and direction. The wheels are Solid PU tires. When in use, the operator drives the motor of the rear wheel by operating the controller joystick to achieve the rear wheels movement. The DC brushless motor and brake system are fixed on the rear wheels. The max loading of the device is 120KG. Only for one person sit.
More Information

Not Found

No
The device description and performance studies focus on standard wheelchair components, motor control, and safety testing, with no mention of AI or ML technologies.

No.
The device is a mobility aid for transportation, not a device intended to treat or cure a disease or condition.

No
The device is described as a motor-driven mobility aid for transportation, not for diagnosing medical conditions.

No

The device description clearly outlines numerous hardware components including a frame, wheels, seat, armrest, battery, motor, and controller. While it mentions software validation, the core functionality and physical form are hardware-based.

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 a disabled or elderly person. This is a physical function, not a diagnostic one.
  • Device Description: The description details a mechanical and electrical device for transportation. 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 biological samples
    • Providing information for diagnosis, monitoring, or screening of diseases or conditions
  • Performance Studies: The performance studies focus on safety, software validation, and compliance with standards related to wheelchairs and medical electrical equipment, not diagnostic accuracy or analytical performance.

In summary, the device is a mobility aid, not a diagnostic tool.

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

ITI

Device Description

This product consists of frame, wheels, seat, armrest, lithium battery, motor and controller with a lightweight and compact design. The whole wheelchair can be folded and it can be easily carried or rolled after folding. The seat cushion is detachable. The armrest can be flipped upside down, which is convenient for the elderly to move. Users can drive the wheelchair by themselves through the control device.

The wheelchair uses lithium batteries as its power source. The controls the drive leftright motor to realize the wheelchair forward, backward and turn functions.

The frame of the device is aluminum alloy. The front wheels suitable for rotation, acceleration, retrograde and other actions of the wheelchair. The front wheels movement will be achieved by thrust generated from the rear wheels are driving wheels to control the speed and direction. The wheels are Solid PU tires.

When in use, the operator drives the motor of the rear wheel by operating the controller joystick to achieve the rear wheels movement.

The DC brushless motor and brake system are fixed on the rear wheels.

The max loading of the device is 120KG. Only for one person sit.

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

disabled or elderly person

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)

Product Material Safety: biocompatibility testing according to ISO 10993-5, ISO 10993-10, and ISO 10993-23 requirements. Results showed materials are safe and meet requirements.

Performance of the products:

  • Risk Analysis developed in accordance with ISO 14971: 2019.
  • Software validation
  • ISO 7176-1:2014 Wheelchairs - Part 1: Determination of static stability
  • ISO 7176-2:2017 Wheelchairs - Part 2: Determination of dynamic stability of electric wheelchairs
  • ISO 7176-3:2012 Wheelchairs - Part 3: Determination of effectiveness of brakes
  • ISO 7176-4:2008 Wheelchairs - Part 4: Energy consumption of electric wheelchairs and scooters for determination of theoretical distance range
  • ISO 7176-5:2008 Wheelchairs - Part 5: Determination of dimensions, mass and maneuvering space
  • ISO 7176-6:2018 Wheelchairs - Part 6: Determination of maximum speed, acceleration of electric wheelchairs
  • ISO 7176-7:1998 Wheelchairs - Part 7: Measurement of seating and wheel dimensions
  • ISO 7176-8:2014 Wheelchairs - Part 8: Requirements and test methods for static, impact and fatigue strength
  • ISO 7176-9:2009 Wheelchairs - Part 9: Climatic tests for electric wheelchairs
  • 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 7176-13:1989 Wheelchairs - Part 13: Determination of coefficient of friction of test surfaces.
  • ISO 7176-14:2022 Wheelchairs -- Part 14: Power and control systems for electrically powered wheelchairs and scooters --Requirements and test methods
  • ISO 7176-15:1996 Wheelchairs - Part 15: Requirements for information 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 compatibility of electrically powered wheelchairs and scooters
  • ISO 7176-22: 2014 Wheelchairs-Part 22: Set-up procedures
  • ISO 7176-25: 2013 Wheelchairs - Part 25: Batteries and chargers for powered wheelchairs.
  • Electromagnetic Compatibility Testing in accordance with IEC 60601-1-2:2020 8.11.

All tests indicate a positive conclusion and support substantial equivalence.

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

Not Found

Predicate Device(s)

K211647

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

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 shows the logo of the U.S. Food and Drug Administration (FDA). The logo consists of two parts: the Department of Health and Human Services logo on the left and the FDA acronym and name on the right. The Department of Health and Human Services logo is a stylized depiction of a human figure, while the FDA acronym and name are written in blue, with the acronym in a square.

February 12, 2025

Kunshan Hi-Fortune Health Products Co., Ltd % Ariel Xiang Consultant Shanghai Sungo Management Consulting Co. Ltd. 14th Floor, 1500# Century Avenue Shanghai, Shanghai 200122 China

Re: K243961

Trade/Device Name: Electrically Powered Wheelchair (HP206) Regulation Number: 21 CFR 890.3860 Regulation Name: Powered Wheelchair Regulatory Class: Class II Product Code: ITI Dated: December 23, 2024 Received: December 23, 2024

Dear Ariel Xiang:

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

Page

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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 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,

Tushar Bansal -S

for 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

3

Indications for Use

Submission Number (if known)

K243961

Device Name

Electrically Powered Wheelchair (HP206)

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)

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4

Kunshan Hi-Fortune Health Products Co., Ltd. No.625 Juxiang Road zhangpu town , Kunshan City Jiangsu Province, China

510(K) Summary K243961

Document Prepared Date: 2025/2/11

A. Applicant

Kunshan Hi-Fortune Health Products Co.. Ltd Address:NO.625 Juxiang Road, Zhangpu Town,Kunshan City, Jiangsu, 215321, CHINA Contact Person: zhanli.Tian Email:zhanli.tian@hi-fortune.net

Submission Correspondent: Primary contact: Ms.Ariel Xiang Title: Senior Consultant Shanghai SUNGO Management Consulting Co., Ltd. 14th Floor, Dongfang Building, 1500# Century Ave., Shanghai 200122, China Tel: +86-21-58817802 Email: shouqiu.xiang@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: Electrically powered wheelchair Common Name: Powered wheelchair Models: HP206

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

C. Predicate device

510Knumber: K211647 Device Name:Electrically Powered Wheelchair Modesl:HP358EA Kunshan Hi-Fortune Health Products 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.

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ய் Device Description:

This product consists of frame, wheels, seat, armrest, lithium battery, motor and controller with a lightweight and compact design. The whole wheelchair can be folded and it can be easily carried or rolled after folding. The seat cushion is detachable. The armrest can be flipped upside down, which is convenient for the elderly to move. Users can drive the wheelchair by themselves through the control device.

The wheelchair uses lithium batteries as its power source. The controls the drive leftright motor to realize the wheelchair forward, backward and turn functions.

The frame of the device is aluminum alloy. The front wheels suitable for rotation, acceleration, retrograde and other actions of the wheelchair. The front wheels movement will be achieved by thrust generated from the rear wheels are driving wheels to control the speed and direction. The wheels are Solid PU tires.

When in use, the operator drives the motor of the rear wheel by operating the controller joystick to achieve the rear wheels movement.

The DC brushless motor and brake system are fixed on the rear wheels.

The max loading of the device is 120KG. Only for one person sit.

F. Comparison with predicate Device

Compared to the predicate devices, the subject device has the same intended use, similar product design, similar performance, same safety as the predicate device, the summarized comparison information is listed in the following table:

changesProposed DevicePredicate Device (K211647)
1.Change Motor typeDC Brushless Motor,
24Vdc 170W;2pcsDC Brush Motor,
24Vdc 250W;2pcs
2. Change controller modelM7084PG D51492

a) There are two changes to the proposed device:

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Kunshan Hi-Fortune Health Products Co., Ltd. No.625 Juxiang Road zhangpu town , Kunshan City Jiangsu Province, China

b) Technical comparison

Table 1 General Comparison

| Elements of

ComparisonProposed DevicePredicate Device (K211647)Remark
ManufacturerKunshan Hi-Fortune Health
Products Co., LtdKunshan Hi-Fortune Health
Products Co., Ltd--
Common or Usual nameElectrically powered
wheelchairElectrically Powered Wheelchair--
Model(s)HP206HP358EA--
ClassificationClass IIClass IIS.E.
Classification regulation21 CFR890.386021 CFR890.3860S.E.
Product codeITIITIS.E.
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 wheels6, including two front wheels and two rear wheels, two anti-tip wheels6, including two front wheels and two rear wheels, two anti-tip wheelsS.E.
Function of wheelsFront wheels: driven
wheels suitable for
rotation, accelerati
on, retrograde
Rear wheels: driving wheels
to control the speed and
direction
Anti-tip wheels: preventing
the wheelchair from
tipping turning over when
driving on the slope. Non-
adjustableFront wheels: driven wheels
suitable for
rotation, acceleration,
retrograde
Rear wheels: driving wheels
to control the speed and
direction
Anti-tip wheels: preventing the
wheelchair from tipping turning
over when driving on the slope.
Non-adjustableS.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.
ArmrestPUPUS.E.
Back cushionTeryleneTeryleneS.E.
Seat cushionTeryleneTeryleneS.E.
Main frame materialAluminum alloyAluminum alloyS.E.
Max loading weight120KG120KGS.E.
Maximum obstacle
climbing35mm30mmSimilar,
Minor difference will not cause different
performance.
Total mass22KG22KGS.E.
Overall Dimension
(lengthwidthheight)950mmX660mmX940mm990mmX620mmX940mmSimilar,
Minor difference on wheelchair dimension
will not cause different performance.
All safety and performance have been
validated with the maximum rated weight
dummy.
Folded Dimension
(lengthwidthheight)660mmX420mmX720mm620mmX550mmX850mmS.E.
Front wheel size/type8" PU tire8" PU tireS.E.
Rear wheel size/type12" PU tires12" Pneumatic tiresSimilar,Minor difference will not cause
different performance.
Max speed forward1.5 m/s1.4 m/sSimilar
Max Speed backward0.9m/s0.8m/sS.E.
Maximum safe
operational incline
Degree10°10°S.E.
Maximum Braking
distanceForwards 1.2m;Reverse 0.6mForwards 0.8m;Reverse 0.6mSimilar
Maximum distance of
travel on the fully
charged battery10.6km10kmMinor difference will not cause different
performance.
Turning Radius750mm500mmMinor difference will not cause different
performance.
Batteryli-ion battery pack;
rechargeable,
25.2VDC,10.4Ahli-ion battery;
rechargeable, 25.2VDC, 10.4AhS.E
Battery chargerOff-board charger,
Input :100-240VAC,Off-board charger,
Input : 100-240VAC, 50-
60Hz, 1.2-0.5AS.E
50-60Hz, 1.2-0.5A
DC output: 24Vdc 2ADC output: 24Vdc2A
MotorDC Brushless Motor,
24Vdc 170W;2pcsDC Brush Motor,
24Vdc 250W;2pcsAnalysis, The design principles of the
controller and Driving system are the
controllerM7084,
24V 35APG D51492,
24V 35Asame, and both meet the requirements of
the ISO 7176-14:2008. Software validation
is carried out on both control systems.

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8

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Table 2 safety comparison

ItemProposed DevicePredicate DeviceResults
BiocompatibilityAll user directly contacting materials are
compliance with ISO10993-5、
ISO10993-10 and ISO10993-23
requirements.All user directly contacting materials are
compliance with ISO10993-5 and
ISO10993-10 requirements.SE
EMCIEC 60601-1-2&ISO7176-21IEC 60601-1-2&ISO7176-21SE
PerformanceISO7176 seriesISO7176 seriesSE
Label and labelingConforms to FDA RegulatoryConforms to FDA RegulatorySE

G. Substantial Equivalence Discussion

The proposed device and predicate device are complying to the same ISO standards, ISO 7176-2, ISO 7176-3, ISO 7176-4, ISO 7176-5, ISO 7176-6, ISO 7176-7, ISO 7176-9, ISO 7176-10, ISO 7176-11, ISO 7176-13, ISO 7176-14, ISO 7176-15, ISO 16840-10, ISO 7176-22,ISO 7176-25, IEC 60601-1-2 and FDA guidance Submission for Power Wheelchair.

The indications for use, design, structure, composition and energy source of proposed device and predicate device are identical.The dimensions and performance parameters are similar.The main differences are motor and controller.

The design principles of the controller and Driving system are the requirements of the ISO 7176-

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  1. Software validation is carried out on both control systems. Brake system and speed control are same way as well, and both meet the ISO 7176-3. Turning radius, Maximum obstacle climbing and Maximum safe operational incline are slightly different while such differences will not impact the safety and effectiveness of the subject device or raise new safety and effectiveness concerns as well as both meet the ISO 7176-2 and ISO 7176-10.

The materials in contact with human tissue are identical for both proposed device and predicate device. The biocompatibility of the proposed device and predicate device meet the ISO 10993-5:2009 & ISO 10993-10:2021 & ISO 10993-23: 2021.

The flame-retardant test of the seat cyshion/ backrest of both subject device is carried out acording to the ISO 16840-10 test. Therefore, both devices are assured to be under the same safety level.

In conclusion, the technological characteristics, features, specifications, materials, mode of operation, and intended use of the device substantially equivalent to the predicate devices quoted above. The differences between the subject device and predicate devices do not raise new issues of safety or effectiveness.

H. Product Performance

  • c) Product Material Safety
    To ensure the safety of the wheelchair material, the bio-compatibility testing was done to the testing was conducted according to the following standards:

ISO 10993-5 Biological evaluations of medical devices -- Part 5: Tests for In Vitro cytotoxicity

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

ISO 10993-23 Biological evaluation of medical devices - Part 23: Tests for irritation

From the test result, we can find the material are safety and can meet the requirements.

  • d) Performance of the products
    The following performance data were provided to verify that the subject device met all design specifications and provided support of the substantial equivalence determination.

Risk Analysis developed in accordance with ISO 14971: 2019.

Software validation

ISO 7176-1:2014 Wheelchairs - Part 1: Determination of static stability

ISO 7176-2:2017 Wheelchairs - Part 2: Determination of dynamic stability of electric wheelchairs

ISO 7176-3:2012 Wheelchairs - Part 3: Determination of effectiveness of brakes

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ISO 7176-4:2008 Wheelchairs - Part 4: Energy consumption of electric wheelchairs and scooters for determination of theoretical distance range

ISO 7176-5:2008 Wheelchairs - Part 5: Determination of dimensions, mass and maneuvering space

ISO 7176-6:2018 Wheelchairs - Part 6: Determination of maximum speed, acceleration of electric wheelchairs

ISO 7176-7:1998 Wheelchairs - Part 7: Measurement of seating and wheel dimensions

ISO 7176-8:2014 Wheelchairs - Part 8: Requirements and test methods for static, impact and fatigue strength

ISO 7176-9:2009 Wheelchairs - Part 9: Climatic tests for electric wheelchairs

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 7176-13:1989 Wheelchairs - Part 13: Determination of coefficient of friction of test surfaces.

ISO 7176-14:2022 Wheelchairs -- Part 14: Power and control systems for electrically powered wheelchairs and scooters --Requirements and test methods

ISO 7176-15:1996 Wheelchairs - Part 15: Requirements for information 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 compatibility of electrically powered wheelchairs and scooters

ISO 7176-22: 2014 Wheelchairs-Part 22: Set-up procedures

ISO 7176-25: 2013 Wheelchairs - Part 25: Batteries and chargers for powered wheelchairs.

Electromagnetic Compatibility Testing in accordance with IEC 60601-1-2:2020 8.11.

1. Conclusion

The proposed device and predicate have the same technological characteristics, features, specifications, materials, mode of operation, and intended use of the device. To ensure all the key characteristic of the products can meet the requirements, the testing was done and all the results indicate the positive conclusion.

Based on the analysis above, we confirm these two products are essentially equivalent.