K Number
K250487
Device Name
SparkTM Clear Aligner System
Manufacturer
Date Cleared
2025-02-20

(1 days)

Product Code
Regulation Number
872.5470
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
Intended Use
The Spark™ Clear Aligner System is indicated for the alignment of teeth during orthodontic treatment of malocclusion.
Device Description
The Spark™ Clear Aligner System consists of a series of doctor-prescribed, custom manufactured, thin, clear plastic removable orthodontic appliances (aligners) that gently move the participant's teeth in small increments from their original state to a more optimal, treated state. Treatment planning, aligner manufacture are supported by a proprietary software system. The clinician receives the aligners and provides them in sequential "stages" to the patient, confirming fit and monitoring treatment from the placement of the first aligner to the removal of the final aligners are held in place by presure and can be removed by the patient at any time. Several treatment options may be integrated into the Spark Clear Aligners, such as cutouts, hooks, and/or other attachment shapes, bite ramps, etc. to aid the aligners with teeth movement. The integrated occlusion guides on the upper and lower aligners allow the option of incrementally repositioning the mandible (lower jaw) forward to address in patients who have not reached full skeletal maturity.
More Information

Not Found

No
The document does not mention AI, ML, or related terms, and the description of the proprietary software system does not provide details suggesting the use of such technologies.

Yes
The device is indicated for "alignment of teeth during orthodontic treatment of malocclusion," which clearly describes a therapeutic intervention to correct a medical condition.

No
The device is described as an orthodontic appliance for aligning teeth, which is a treatment modality, not a diagnostic one. Its purpose is to physically move teeth, not to identify or characterize a disease or condition.

No

The device description explicitly states that the system consists of "thin, clear plastic removable orthodontic appliances (aligners)" which are physical hardware components. While software is used for treatment planning and manufacturing, the core medical device is the physical aligner.

Based on the provided information, the Spark™ Clear Aligner System is not an In Vitro Diagnostic (IVD) device.

Here's why:

  • IVD devices are used to examine specimens derived from the human body (like blood, urine, tissue) to provide information for diagnosis, monitoring, or screening.
  • The Spark™ Clear Aligner System is a physical appliance used to mechanically move teeth. It directly interacts with the patient's teeth and jaw, rather than analyzing biological samples.
  • The intended use is for the alignment of teeth during orthodontic treatment of malocclusion. This is a mechanical and structural treatment, not a diagnostic test based on biological samples.

The description clearly outlines a physical device used for orthodontic treatment, which falls outside the scope of IVD devices.

N/A

Intended Use / Indications for Use

The Spark™ Clear Aligner System is indicated for the alignment of teeth during orthodontic treatment of malocclusion.

Product codes

NXC

Device Description

The Spark™ Clear Aligner System consists of a series of doctor-prescribed, custom manufactured, thin, clear plastic removable orthodontic appliances (aligners) that gently move the participant's teeth in small increments from their original state to a more optimal, treated state. Treatment planning, aligner manufacture are supported by a proprietary software system. The clinician receives the aligners and provides them in sequential "stages" to the patient, confirming fit and monitoring treatment from the placement of the first aligner to the removal of the final aligners are held in place by presure and can be removed by the patient at any time. Several treatment options may be integrated into the Spark Clear Aligners, such as cutouts, hooks, and/or other attachment shapes, bite ramps, etc. to aid the aligners with teeth movement. The integrated occlusion guides on the upper and lower aligners allow the option of incrementally repositioning the mandible (lower jaw) forward to address in patients who have not reached full skeletal maturity.

Mentions image processing

Not Found

Mentions AI, DNN, or ML

Not Found

Input Imaging Modality

Not Found

Anatomical Site

teeth, mandible (lower jaw)

Indicated Patient Age Range

Not Found

Intended User / Care Setting

doctor-prescribed, clinician

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)

Not Found

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

Not Found

Predicate Device(s)

K223517, K240501

Reference Device(s)

Not Found

Predetermined Change Control Plan (PCCP) - All Relevant Information

Not Found

§ 872.5470 Orthodontic plastic bracket.

(a)
Identification. An orthodontic plastic bracket is a plastic device intended to be bonded to a tooth to apply pressure to a tooth from a flexible orthodontic wire to alter its position.(b)
Classification. Class II.

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February 20, 2025

Ormco Corporation % Prithul Bom Most Responsible Person Regulatory Technology Services, LLC 1000 Westgate Drive, Suite 510k Saint Paul, Minnesota 55114

Re: K250487

Trade/Device Name: SparkTM Clear Aligner System Regulation Number: 21 CFR 872.5470 Regulation Name: Orthodontic plastic bracket Regulatory Class: Class II Product Code: NXC Dated: February 19, 2025 Received: February 19, 2025

Dear Prithul Bom:

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 (OS) 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,

MICHAEL E. ADJODHA -S

Michael E. Adjodha, MChE, RAC, CQIA Assistant Director DHT1B: Division of Dental and ENT Devices OHT1: Office of Ophthalmic, Anesthesia, Respiratory, ENT, and Dental 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)

K250487

Device Name

Spark TM Clear Aligner System

Indications for Use (Describe)

The Spark™ Clear Aligner System is indicated for the alignment of teeth during orthodontic treatment of malocclusion.

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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Declaration of Conformity
Application #K250487
Company NameOrmco Corporation
Company Address200 S. Kraemer Blvd. Brea CA 92821 United States
Device Trade NameSpark™ Clear Aligner System
The subject device(s) is in conformity with the requirements of the following documents:
OrganizationDesignation Number and Edition/DateRecognition #
ANSI AAMI ISO10993-1: 20182-258
ANSI AAMI ISO10993-5:2009/(R)20142-245
ANSI AAMI ISO10993-10:2010/(R)20142-174
ANSI AAMI ISO10993-11: 20172-255
ISO7405 Third edition 2018-10 Corrected version 2018-124-261
ASTMF1980-2114-575
ANSI ADAStandard No. 41-20204-295
ANSI AAMI ISO14971: 20195-125
ANSI AAMI ISO02-228

Additional Information (e.g., limitations on the validity of the Declaration of Conformity)

Signed for and on behalf of the applicant company:

Place and Issuance Date:Brea, CA
------------------------------------

2/06/2025

Full Name and Title:

Jessica Pomares; Regulatory Affairs Specialist

Signature

Image /page/4/Picture/9 description: The image shows the name "Jessica Pomares" written in a cursive font. The text is black and the background is white. The font is elegant and decorative.

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510(k) Summary

Prepared on: 2025-02-06

Contact Details

Applicant NameOrmco Corporation
Applicant Address200 S. Kraemer Blvd. Brea CA 92821 United States
Applicant Contact Telephone714-628-8575
Applicant ContactMs. Jessica Pomares
Applicant Contact Emailjessica.pomares@envistaco.com

21 CFR 807.92(a)(1)
Device Name

Device Trade NameSpark™ Clear Aligner System
Common NameOrthodontic plastic bracket
Classification NameAligner, Sequential
Regulation Number21 CFR part 872.5470
Product Code(s)NXC

21 CFR 807.92(a)(2)
Legally Marketed Predicate Devices

Predicate #Predicate Trade Name (Primary Predicate is listed first)Product Code
K223517Clear AlignerNXC
K240501Spark™ Clear Aligner SystemNXC

21 CFR 807.92(a)(3)
Device Description Summary
21 CFR 807.92(a)(4)
The Spark™ Clear Aligner System consists of a series of doctor-prescribed, custom manufactured, thin, clear plastic removable orthodontic appliances (aligners) that gently move the participant's teeth in small increments from their original state to a more optimal,
treated state. Treatment planning, aligner manufacture are supported by a proprietary software system. The clinician receives the aligners and provides them in sequential "stages" to the patient, confirming fit and monitoring treatment from the placement of the first aligner to the removal of the final aligners are held in place by presure and can be removed by the patient at any time. Several treatment options may be integrated into the Spark Clear Aligners, such as cutouts, hooks, and/or other attachment shapes, bite ramps, etc. to aid the aligners with teeth movement. The integrated occlusion guides on the upper and lower aligners allow the option of incrementally repositioning the mandible (lower jaw) forward to address in patients who have not reached full skeletal maturity.

Intended Use/Indications for Use

The Spark™ Clear Aligner System is indicated for the alignment of teeth during orthodontic treatment of malocclusion.

Indications for Use Comparison

The Subject Device and Predicate Device share a similar Indications for Use

21 CFR 807.92(a)(5)

21 CFR 807.92(a)(5)