K Number
K244030
Date Cleared
2025-03-28

(88 days)

Product Code
Regulation Number
N/A
Reference & Predicate Devices
Predicate For
N/A
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP AuthorizedThirdpartyExpeditedreview
Intended Use

Needle Stimulator is an electro-acupuncture stimulator device, which is indicated for use in the practice of acupuncture by qualified practitioners of acupuncture as determined by the states.

Device Description

Needle Stimulator is an electro-acupuncture device for acupuncture therapy, powered by 6 pieces of 1.5V batteries or AC 100-240V. It is composed of a console and 6 channels of electrode cables with alligator type connectors. The console has the operating controls including function knobs or buttons. Needle Stimulator does not equip with acupuncture needles. The practitioners should select legally marketed needles.

AI/ML Overview

The provided text is an FDA 510(k) summary for a medical device called "Needle Stimulator." It details the device, its intended use, and a comparison to a predicate device to establish substantial equivalence.

However, the provided text does not contain any information about a study that proves the device meets specific performance acceptance criteria for an AI/ML-based device. The information is primarily focused on electrical safety, essential performance, and electromagnetic compatibility tests as per general medical device standards, and not on the performance metrics of an AI system detecting or classifying something.

The recurring phrases like "Similar Note 1," "Similar Note 2," etc., refer to explanations for minor differences between the subject device and the predicate device in terms of hardware specifications and compliance with voluntary standards. They are not related to an AI/ML performance study.

Specifically, the section "6. Clinical Test" states, "Clinical data were not included in this submission." This strongly indicates that no clinical study was performed for this 510(k) submission, and therefore, no AI/ML performance data against ground truth or human readers would be available within this document.

Therefore, I cannot fulfill your request to describe the acceptance criteria and the study that proves the device meets the acceptance criteria for an AI/ML-based device based on the information provided. The document describes a standard medical device (an electro-acupuncture stimulator), not an AI/ML product requiring the detailed performance study you've outlined.

If this was a misunderstanding and you expected a generic answer for an AI/ML device based on typical FDA requirements, please clarify. But based solely on the provided text, the requested information is absent.

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March 28, 2025

Wuxi Jiajian Medical Instrument Co., Ltd. % Doris Dong Official Correspondent Shanghai CV Technology Co., Ltd. Room 805, No.19 Dongbao Road, Songjiang Area Shanghai, Shanghai 201613 China

Re: K244030

Trade/Device Name: Needle Stimulator (CMNS6-1 PLUS, CMNS6-3) Regulatory Class: Unclassified Product Code: BWK Dated: December 2, 2024 Received: December 30, 2024

Dear Doris Dong:

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" (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).

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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 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-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,

Amber T. Ballard -S

Amber Ballard, PhD Assistant Director 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

510(k) Number (if known) K244030

Device Name Needle Stimulator (CMNS6-1 PLUS, CMNS6-3)

Indications for Use (Describe)

Needle Stimulator is an electro-acupuncture stimulator device, which is indicated for use in the practice of acupuncture by qualified practitioners of acupuncture as determined by the states.

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 [As required by 21 CFR 807.92]

1. Submission Information:

510(k) Number:K244030
Date:March 24, 2025
Type of 510(k) Submission:Traditional
Basis for 510(k) Submission:New device
Submitter/Manufacturer:Wuxi Jiajian Medical Instrument Co., LtdNo. 35 Baiqiao Rd., Ehu Town, Xishan District, Wuxi,Jiangsu, China 214116
Contact:Doris Dong[Consultant, from Shanghai CV Technology Co., Ltd.]Add: Room 805, No. 19 Dongbao Road, Songjiang Area, Shanghai, 201613ChinaE-mail: doris.d@ceve.org.cnTel: 86 21-31261348 / Fax: 86 21-57712250

2. Device Description:

Proprietary Name:Needle Stimulator
Model:CMNS6-1 PLUS, CMNS6-3
Common Name:Electro-Acupuncture
Classification Name:Stimulator, Electro-Acupuncture
Product Code:BWK
Device Class:Unclassified
Review Panel:Neurology
Device Description:Needle Stimulator is an electro-acupuncture device for acupuncture therapy, powered by 6 pieces of 1.5V batteries or AC 100-240V. It is composed of a console and 6 channels of electrode cables with alligator type connectors. The console has the operating controls including function knobs or buttons. Needle Stimulator does not equip with acupuncture needles. The practitioners should select legally marketed needles.
Indications for use:Needle Stimulator is an electro-acupuncture stimulator device, which is indicated for use in the practice of acupuncture by qualified practitioners of acupuncture as determined by the states.

3. Predicate Device Identification

Predicate 510(k) Number:K202861
Marketing Clearance Date:08/27/2021
Product Name:Needle Stimulator
Manufacturer:Wuxi Jiajian Medical Instrument Co., Ltd.

4. Substantial Equivalence to Predicate device:

Detailed comparison data is included in "Substantial Equivalence Discussion - CMNS6-1 PLUS" of this 510(k) submission.

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Table 1-

ParametersSubject DevicePredicate DeviceRemark
1510(k) Number:K244030K202861--
2Marketing clearance date:--08/27/2021--
3Device NameNeedle StimulatorNeedle Stimulator--
4ModelCMNS6-1 PLUSCMNS6-1--
5ManufacturerWuxi Jiajian Medical Instrument Co.,LtdWuxi Jiajian Medical Instrument Co.,LtdSame
6Indications for UseNeedle Stimulator is an electro-acupuncture stimulator device, which is indicated for use in the practice of acupuncture by qualified practitioners of acupuncture as determined by the states.Needle Stimulator is an electro-acupuncture stimulator device, which is indicated for use in the practice of acupuncture by qualified practitioners of acupuncture as determined by the states.Same
7Type of usePrescription usePrescription useSame
8Power Source(s)DC 1.5Vx6 Type R14 or AC 100-240VDC 1.5Vx6 Type R14 or AC 100-240VSame
Method of Line Current IsolationType BFType BFSame
Patient Leakage Current----Same
Normal Condition (μΑ)2μΑ2μΑ
Single Fault Condition (μΑ)≤50μΑ≤50μΑ
9Average DC current through electrodes when device is on but no pulses are being applied (µA)N/AN/ASame
10Number of Output Modes3 (continuous wave/ interrupted wave/ Dense-disperse wave)3 (continuous wave/ interrupted wave/ Dense-disperse wave)Same
Number of Output channels:6 (3 channels at most work together on single patient)6 (3 channels at most work together on single patient)Same
11Synchronous or Alternating?SynchronousSynchronousSame
Method of Channel IsolationTransformerTransformerSame
12Regulated Current or Regulated Voltage?Voltage ControlVoltage ControlSame
13Software/Firmware/MicroprocessorYesYesSame
14Automatic OverloadTrip?NoNoSame
15Automatic No-LoadTrip?YesNoSimilarNote 1
16Automatic Shut Off?YesYesSame
17UserOverrideControl?YesYesSame
IndicatorDisplay:On/OffStatus?YesYesSame
18LowBattery?NoYesSimilarNote 1
Voltage/CurrentLevel?NoYes
19Timer(minutes)Range1-60min0-60minSimilarNote 3
20Compliance withVoluntary Standards?IEC 60601-1,IEC 60601-1-2IEC 60601-1, IEC 60601-2-10,IEC 60601-1-2SimilarNote 2
21Compliance with 21CFR 898?YesYesSame
22Weight (grams)740g740gSame
23Dimensions [W x Hx D]23416076mm23015555mmSimilarNote 3
24Housing Materials &ConstructionABS;Injection moldedABS; Injection moldedSame
25WaveformBiphasicBiphasicSame
26ShapeAsymmetric biphasic squarewaveAsymmetric biphasic squarewaveSame
MaximumOutputVoltage (volts)35V±20%@500Ω27V±10% @500ΩSimilar
2760.4V±20%@2kΩ60.4V±10% @2kΩNote 4
75V±20%@10kΩ75V±10%@10kΩ
MaximumOutputCurrent(specifyunits)70mA±20%@500Ω54mA±10% @500Ω
2830.2mA±20%@2kΩ30.2mA±10% @2kΩ
7.5mA±20%@10kΩ7.5mA±10% @10kΩ
PulsePositive175 $\mu$ s±20%200 $\mu$ s±10%
29width( $\mu$ sec)Negative1051 $\mu$ s (6 x (+Phase) )1030 $\mu$ s (5.15 x (+Phase) )
30Pulse(msec)Period10~1000ms10~1000msSame
31Max.frequencypulse(Hz)1~100Hz±20%1~100Hz±10%SimilarNote 4
Rate (pps)]
32Net Charge (µC per pulse)0µC@500Ω, + and – pulses cancel0µC@500Ω, + and – pulses cancelSame
33Maximum Phase Charge, (µC)8.6µC @500Ω9.4µC @500ΩSimilar Note 5
34Maximum Average Current, (mA)1.17mA @500Ω1.08mA @500Ω
35Maximum Current Density, (mA/cm², r.m.s.)8.6mA/cm² @500Ω9.4mA/cm² @500Ω
36Maximum Average Power Density, (W/cm²)0.135W/cm²@500Ω0.141W/cm²@500Ω
37BiocompatibilityISO10993-5, ISO 10993-10ISO10993-5, ISO 10993-10Same
38AccessoriesLead wires, Alligator type connectorsLead wires, Alligator type connectorsSame
ParametersModified DevicePredicate DeviceRemark
1510(k) Number:K244030K202861--
2Marketing clearance date:--08/27/2021--
3Device NameNeedle StimulatorNeedle Stimulator--
4ModelCMNS6-3CMNS6-2--
5ManufacturerWuxi Jiajian MedicalInstrument Co.,LtdWuxi Jiajian MedicalInstrument Co.,LtdSame
6Indications for UseNeedle Stimulator is anelectro-acupuncture stimulatordevice, which is indicated foruse in the practice ofacupuncture by qualifiedpractitioners of acupuncture asdetermined by the states.Needle Stimulator is anelectro-acupuncture stimulatordevice, which is indicated foruse in the practice ofacupuncture by qualifiedpractitioners of acupuncture asdetermined by the states.Same
7Type of usePrescription usePrescription useSame
Power Source(s)DC 1.5Vx6 Type R14 or AC100-240VDC 1.5Vx6 Type R14 or AC100-240VSame
8Method of LineCurrent IsolationType BFType BFSame
Patient LeakageCurrent----Same
NormalCondition (μΑ)2μΑ2μΑ
Single FaultCondition (μΑ)≤50μΑ≤50μΑ
9Average DC currentthrough electrodeswhen device is onbut no pulses arebeing applied (µA)N/AN/ASame
10Number of OutputModes3 (continuous wave/ interruptedwave/ Dense-disperse wave)3 (continuous wave/ interruptedwave/ Dense-disperse wave)Same
Number of Outputchannels:6 (3 channels at most worktogether on single patient)6 (3 channels at most worktogether on single patient)Same
11Synchronousor Alternating?SynchronousSynchronousSame
Method ofChannel IsolationTransformerTransformerSame
Regulated Current orRegulated Voltage?Voltage ControlVoltage ControlSame
13Software/Firmware/MicroprocessorControl?YesYesSame
14Automatic OverloadTrip?NoNoSame
15Automatic No-LoadTrip?YesNoSimilarNote 1
16Automatic Shut Off?YesYesSame
17UserOverrideControl?YesYesSame
18IndicatorDisplay:On/OffStatus?YesYesSame
LowBattery?NoYesSimilarNote 1
Voltage/CurrentLevel?YesYesSame
19Timer(minutes)Range1-100min1-99minSimilarNote 3
20CompliancewithVoluntary Standards?IEC 60601-1, IEC 60601-1-2IEC 60601-1, IEC 60601-2-10,IEC 60601-1-2SimilarNote 2
21Compliance with 21CFR 898?YesYesSame
22Weight (grams)740gapprox. 657gSimilar
23Dimensions [W x Hx D]23416076mm23818475mmNote 3
24Housing Materials &ConstructionABS; Injection moldedABS; Injection moldedSame
25WaveformBiphasicBiphasicSame
26ShapeAsymmetric, square waveAsymmetric, square waveSame
27MaximumOutputVoltage (volts)35V±20%@500Ω27V±10% @500ΩSimilarNote 4
60.4V±20%@2kΩ60.4V±10% @2kΩ
75V±20%@10kΩ75V±10%@10kΩ
MaximumCurrentOutput(specify70mA±20%@500Ω54mA±10% @500Ω
2830.2mA±20%@2kΩ30.2mA±10% @2kΩ
units)7.5mA±20%@10kΩ7.5mA±10% @10kΩ
PulsePositive175µs±20%175µs±10%
29width(µsec)Negative1051µs (6 x (+Phase) )1051µs (6 x (+Phase) )
30PulsePeriod(msec)
30PulsePeriod(msec)10~1000ms10~1000msSame
31Max.pulsefrequency (Hz) [orRate (pps)]1~100Hz±20%1~100Hz±10%SimilarNote 4
32Net Charge (µC perpulse)0μC@500Ω, + and – pulsescancel0μC@500Ω, + and – pulsescancelSame
33Maximum PhaseCharge, (µC)8.6μC @500Ω8.225μC @500ΩSimilarNote 5
34Maximum AverageCurrent, (mA)1.17mA @500Ω0.945mA @500Ω
35Maximum CurrentDensity, (mA/cm²,r.m.s.)8.6mA/cm² @500Ω8.225mA/cm² @500Ω
36Maximum AveragePower Density,(W/cm²)0.135W/cm²@500Ω0.1234W/cm²@500Ω
37BiocompatibilityISO10993-5, ISO 10993-10ISO10993-5, ISO 10993-10Same
38AccessoriesLead wires, Alligator typeconnectorsLead wires, Alligator typeconnectorsSame

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Note 1:

The proposed device's average DC current at overload, low battery and voltage/current level are different from those of the primary predicate device. As the proposed device and the predicate device adopt the same fundamental output technology and similar treatment effect, therefore, the proposed device is considered to be substantially equivalent. Also, the proposed device had passed AAMI / ANSI ES60601-1 and IEC 60601-1-2 tests, so these differences will not raise any new safety and effectiveness issues.

Note 2:

The IEC 60601-2-10 for testing of predicate device is specific to neuromuscular stimulation, and the BWK product code does not appear in the FDA's testing standards, so we do not believe that this test is required for the proposed device.

Note 3:

The dimensions and appearance of the proposed device are a little different from those of the predicate device, depending on the design and sales requirements of the product. But these differences are insignificant in terms of safety or effectiveness.

Note 4:

There are some differences in the maximum output voltage, maximum output current, pulse width, pulse period and frequency between the proposed device and the predicate device. Based on the calculation of maximum current density, maximum average power density, these parameters don't exceed the safety limit. Also, the worst cases have been considered in risk analysis report. Therefore, these differences do not raise new questions of safety and effectiveness.

Note 5:

The net charge, maximum phase charge, maximum average current, maximum current density, maximum average power density have some differences between the proposed device and the predicate device. The differences are minor and do not raise new questions of safety and effectiveness.

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Detailed comparison data is included in "Substantial Equivalence Discussion - CMNS6-3" of this 510(k) submission.

Table 2-

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Note 1:

The proposed device's average DC current at no load and voltage/current level are different from those of the primary predicate device. As the proposed device and the predicate device adopt the same fundamental output technology and similar treatment effect, therefore, the proposed device is considered to be substantially equivalent. Also, the proposed device had passed AAMI / ANSI ES60601-1 and IEC 60601-1-2 tests, so these differences will not raise any new safety and effectiveness issues.

Note 2:

The IEC 60601-2-10 for testing of predicate device is specific to neuromuscular stimulation, and the BWK product code does not appear in the FDA's testing standards, so we do not believe that this test is required for the proposed device.

Note 3:

The time range, weight, dimensions and appearance of the proposed device are a little different from those of the predicate device, depending on the design and sales requirements of the product. But thesed ifferences are insignificant in terms of safety or effectiveness.

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Note 4:

There are some differences in the maximum output voltage, maximum output current, pulse width, pulse period, and frequency between the proposed device and the predicate device. Based on the calculation of maximum current density, maximum average power density, these parameters don't exceed the safety limit. Also, the worst cases have been considered in risk analysis report. Therefore, these differences do not raise new questions of safety and effectiveness.

Note 5:

The net charge, maximum phase charge, maximum average current, maximum current density, maximum average power density have some differences between the proposed device and the predicate device. The differences are minor and do not raise new questions of safety and effectiveness.

5. Test summary:

Needle Stimulator is safe and effective as the predicate device cited above. The new devices have passed testings according to the following standards:

  1. 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) [Including Amendment 2 (2021)];

  2. IEC 60601-1-2 Edition 4.1 2020-09 CONSOLIDATED VERSION Medical electrical equipment - Part

1-2: General requirements for basic safety and essential performance - Collateral Standard:

Electromagnetic disturbances - Requirements and tests;

  1. IEC TS 60601-4-2 Edition 1.0 2024-03 Medical electrical equipment - Part 4-2: Guidance and interpretation - Electromagnetic immunity: performance of medical electrical equipment and medical electrical systems

6. Clinical Test

Clinical data were not included in this submission.

7. Conclusion

The conclusion drawn from the non-clinical tests demonstrates that the device performs as intended and is as safe, and effective as the legally marketed device identified in the submission. Thus, the subject device is substantially equivalent to the predicate device.

N/A