K Number
K251248
Device Name
ELECTRIC WHEELCHAIR (QDWP-A01,QDWP-B02)
Date Cleared
2025-06-20

(58 days)

Product Code
Regulation Number
890.3860
AI/MLSaMDIVD (In Vitro Diagnostic)TherapeuticDiagnosticis PCCP Authorized
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 wheelchair can easily fold and unfold for transportation or storage.The armrest can be flipped backward, which is convenient for the elderly to move. Users can drive the wheelchair by themselves through the control device. The QDWP-A01 uses lithium batteries as its power source, The QDWP-B02 uses lead acid batteries as its power source.The controller controls the drive left/right motor to realize the wheelchair forward, backward and turn functions. The frame of QDWP-A01 is aluminum,the frame of QDWP-B02 is steel. The front wheels are driven 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. The rear wheels are driving wheels to control the speed and direction. When in use, the operator drives the motor of the rear wheel by operating the joystick to achieve the rear wheels movement. The 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

No.
The device description and performance studies do not mention any AI, DNN, or ML components. The control system for the wheelchair appears to be entirely based on user input via a joystick and basic motor control.

No.
Justification: The device is a mobility aid for transportation, not designed to diagnose, cure, mitigate, treat, or prevent disease.

No
The device is described as a motor-driven transportation vehicle for mobility, with no mention of diagnosing conditions.

No

This device is a physical medical device (a motor-driven wheelchair) with hardware components such as a frame, wheels, battery, motor, and controller. While it mentions "Software validation" as part of its performance studies, this refers to the validation of the embedded software within the physical device's control system, not that the device itself is purely software.

No.
An IVD is a medical device that is used to perform tests on specimens taken from the human body, such as blood, urine, or tissue, to provide information for diagnosis, monitoring, or screening purposes. This device is a mobility aid for transportation and does not perform any in vitro diagnostic tests.

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 wheelchair can easily fold and unfold for transportation or storage.The armrest can be flipped backward, which is convenient for the elderly to move. Users can drive the wheelchair by themselves through the control device.

The QDWP-A01 uses lithium batteries as its power source, The QDWP-B02 uses lead acid batteries as its power source.The controller controls the drive left/right motor to realize the wheelchair forward, backward and turn functions.

The frame of QDWP-A01 is aluminum,the frame of QDWP-B02 is steel. The front wheels are driven 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. The rear wheels are driving wheels to control the speed and direction. When in use, the operator drives the motor of the rear wheel by operating the joystick to achieve the rear wheels movement.

The 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

Not Found

Intended User / Care Setting

disabled or elderly person limited to a seated position. / indoor and outdoor

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

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 and deceleration 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 disclosure, documentation 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 proceduresd
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.

Key Metrics

Not Found

Predicate Device(s)

K113463

Reference Device(s)

K211647

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).

FDA 510(k) Clearance Letter - Electric Wheelchair

Page 1

U.S. Food & Drug Administration
10903 New Hampshire Avenue
Silver Spring, MD 20993
www.fda.gov

Doc ID # 04017.07.05

June 20, 2025

Jinhua Qidian Vehicle Co. Ltd
℅ Ariel Xiang
Consultant
Shanghai Sungo Management Consulting Co. Ltd.
14th Floor, 1500# Century Avenue
Shanghai, Shanghai 200122
China

Re: K251248
Trade/Device Name: Electric Wheelchair (qdwp-a01,qdwp-b02)
Regulation Number: 21 CFR 890.3860
Regulation Name: Powered Wheelchair
Regulatory Class: Class II
Product Code: ITI
Dated: April 23, 2025
Received: April 23, 2025

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.

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"

Page 2

K251248 - Ariel Xiang Page 2

(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 (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-reporting-combination-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-devices/device-advice-comprehensive-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-devices/medical-device-safety/medical-device-reporting-mdr-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/medical-devices/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-devices/device-advice-comprehensive-regulatory-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).

Page 3

K251248 - Ariel Xiang Page 3

Sincerely,

Julia E. Slocomb 2025.06.20
-S 11:44:26 -04'00'

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

Page 4

DEPARTMENT OF HEALTH AND HUMAN SERVICES
Food and Drug Administration

Indications for Use
Form Approved: OMB No. 0910-0120
Expiration Date: 07/31/2026
See PRA Statement below.

Submission Number (if known)
K251248

Device Name
ELECTRIC WHEELCHAIR (QDWP-A01,QDWP-B02)

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) ☒ Over-The-Counter Use (21 CFR 801 Subpart C)

CONTINUE ON A SEPARATE PAGE IF NEEDED.

This section applies only to requirements of the Paperwork Reduction Act of 1995.
DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.

The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to:

Department of Health and Human Services
Food and Drug Administration
Office of Chief Information Officer
Paperwork Reduction Act (PRA) Staff
PRAStaff@fda.hhs.gov

"An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB number."

Page 5

JINHUA QIDIAN VEHICLE CO.LTD
#8.NO308. WeiyeRoad, Jiangtang, Wucheng,Jinhua, Zhejiang, China

510(K) Summary

Document Prepared Date: 2025/4/21

A. Applicant

Name: JINHUA QIDIAN VEHICLE CO.LTD
Address: #8.NO308. WeiyeRoad, Jiangtang, Wucheng,Jinhua, Zhejiang, China
Contact Person: Qunbao Yang
Email: 568438678@qq.com

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: Electric wheelchair
Common Name: Powered wheelchair
Model(s): QDWP-A01,QDWP-B02

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

C. Predicate device

510K number: K113463
power wheelchair, PL00l
SUZHOU KD Medical Appliance Co. Ltd.

Page 6

Reference Device
K211647
Electrically Powered Wheelchair,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.

E. Device Description:

This product consists of frame, wheels, seat, armrest, lithium battery, motor and controller with a lightweight and compact design.The wheelchair can easily fold and unfold for transportation or storage.The armrest can be flipped backward, which is convenient for the elderly to move. Users can drive the wheelchair by themselves through the control device.

The QDWP-A01 uses lithium batteries as its power source, The QDWP-B02 uses lead acid batteries as its power source.The controller controls the drive left/right motor to realize the wheelchair forward, backward and turn functions.

The frame of QDWP-A01 is aluminum,the frame of QDWP-B02 is steel. The front wheels are driven 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. The rear wheels are driving wheels to control the speed and direction. When in use, the operator drives the motor of the rear wheel by operating the joystick to achieve the rear wheels movement.

The 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

Table 1 General Comparison

Elements of ComparisonSubject Device (K251248)Predicate Device (K113463)Reference Device (K211647)Remark
ManufacturerJINHUA QIDIAN VEHICLE CO.LTDSUZHOU KD Medical Appliance Co. Ltd.Kunshan Hi-Fortune Health Products Co., Ltd--
Common orElectric wheelchairPower WheelchairElectrically Powered--

Page 7

Usual nameirWheelchair
Model(s)QDWP-A01 QDWP-B02PL00l
ClassificationClass IIClass II
Classification regulation21 CFR890.386021 CFR890.3860
Product codeITIITI
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.
Intended userdisabled or elderly person limited to a seated position.disabled or elderly person limited to a seated position.

Page 8

Use conditionindoor and outdoor useindoor and outdoor useindoor and outdoor useS.E
Number of wheels4,including two front wheels and two rear Wheels4,including two front wheels and two rear Wheels6, including two front wheels and two rear wheels, two anti-tip wheelsS.E
Function of wheelsFront wheels:driven wheels suitable for rotation, acceleration, retrograde Rear wheels: driving wheels to control the speed and directionFront wheels:driven wheels suitable for rotation, acceleration, retrograde Rear wheels: driving wheels to control the speed and directionFront 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 controlBy Joystick controlBy Joystick controlBy Joystick controlS.E

Page 9

Driving systemDirect drive on the rear wheelsDirect drive on the rear wheelsDirect drive on the rear wheelsS.E
Brake systemAutomatic electromagnetic brake systemAutomatic electromagnetic brake systemAutomatic electromagnetic brake systemS.E
Braking distance1.2m1.5 m0.8mAnalysis: Minor difference on braking distance will not cause different performance. Shorter distance for braking will be more safety.
Maximum safe operational incline degree10 °9 °10°S.E
ArmrestPPPUPUAnalysis: Different material used for parts in contact with user, which such differences will not impact the safety and effectiveness of the subject device as biocompatibility tests are carried out according to ISO 10993 series.

Page 10

| Main frame material | Aluminum alloy | Steel | Aluminum alloy | Aluminum alloy QDWP-A01 is Same as Predicate Device; QDWP-B02 is different. Analysis: Different material used for frame, that such difference will not impact the safety and effectiveness of the subject device as the performance tests are conducted according to ISO 7176 |

Page 11

series.
Back cushionNylonPU foam covered by nylon fabric clothTeryleneS.E Same as Predicate Device.
Seat cushionNylonPU foam covered by nylon fabric clothTerylene
Overall length1120mm970mm880mm990mm Analysis: Minor difference on wheelchair dimension will not cause different performance. All safety and performance have been validated with the maximum rated weight dummy.
Overall width600mm660mm570mm620mm
Folded Dimension (lengthwidthheight)710600450mm680460770mm750570400mm620mmX550mmX850mm

Page 12

Front wheel size/type200mm×50mm PU Solid tire (8 inch)200mm×45mm (8 inch) PU Solid tire6" x 2"/PU Solid tire8" PU tireS.E Same as Reference Device.
Rear wheel size/type10inch×2.0inch Rubber Filler305mm×43mm (12 inch) PU Solid tire8″x 2.4″/ PU Solid tire12" Pneumatic tiresDWPB02 is same as reference device. Analysis: Minor difference on dimension of wheels will not cause different performance.
Max speed forward1.8 m/s (6.5km/h)Up to 6 km/h (1.6 m/s), adjustable1.4 m/sAnalysis: Minor difference on Max speed forward of

Page 13

wheels will not cause different performance.
Max loading weight120kg114kg (251lbs)120kgS.E
Maximum distance of travel on the fully charged battery20.3km10.0km20 km10km S.E
BatteryLithium-ion Battery 24V, 10Ah,2PCSLead Acid Battery, 12V, 12Ah,2PCSli-ion battery pack; rechargeable, 24 VDC 20Ahli-ion battery; rechargeable, 25.2VDC, 10.4Ah Analysis: QDWP-A01 is same , QDWP-B02 is different. The performance of batteries and charger of device meet the Requirements of ISO
Battery chargerOff-board charger, Input: 100-240V~1.8A, 50/60Hz Output: 24V, 3.0AOff-board charger, Input:100/240V,50/60Hz/55W Output:24V-29.6V,1.8AOff-board charger Input: 110-240V, 50- 60Hz, Output: 24 Vdc, 2A;Off-board charger, Input :100-240VAC, 50-60Hz, 1.2-0.5A DC output: 24Vdc2A

Page 14

7176-25.
MotorBrushless Motor, 24VDC, 250WBrushed motor, 24VDC, 250WBrushless DC motor; 24VDC; 180W; 2pcsDC Brushed Motor, 24Vdc 250W;2pcs QDWP-B02 is same as reference device. The type of QDWP-A01 is predicate device. Analysis: Minor difference on motor power. Both meet the require of ISO 7176-14 standard. It will not cause new safety and effectiveness concerns.
Electronic controller24V 40A24V35ABrushless dual-drive rocker controller24V 35A QDWP-B02 is same as reference device. Analysis:

Page 15

Both of the control systems are evaluated according to standard ISO 7176-14:2008 and software validation requirement and there are no new safety and effectiveness concerns due to the difference.
Turning Radius900mm950mm800 mm500mm Analysis: Minor difference on turning radius will not cause new safety and effectiveness concerns due to the difference.

Page 16

Maximum obstacle climbing25mm30 mm30mmAnalysis: Minor difference on obstacle climbing will not cause new safety and effectiveness concerns.

Table 2 safety comparison

ItemProposed DevicePredicate DeviceResults
BiocompatibilityAll user directly contacting materials are compliance with ISO10993-5 ,ISO10993-10 ,ISO10993-23 requirements.All user directly contacting materials are compliance with ISO10993-5 and ISO10993-10 requirements.S.E.
EMCISO7176-21 and IEC 60601-1-2ISO7176-21 and IEC 60601-1-2S.E.
PerformanceISO7176 seriesISO7176 seriesS.E.
Label and labelingConforms to FDA RegulatoryConforms to FDA RegulatoryS.E.

G. Substantial Equivalence Discussion

The proposed device and predicate device are complying to the same ISO standards, ISO 7176-1, ISO 7176-2, ISO 7176-3, ISO 7176-4, ISO 7176-5, ISO 7176-6, ISO 7176-7, ISO 7176-8, ISO 7176-9, ISO 7176-10, ISO 7176-11, ISO 7176-13, ISO 7176-14, ISO 7176-15, ISO 16840-10, ISO 7176-21, ISO7176-22,ISO 7176-25, IEC 60601-1-2 and FDA guidance Submission for Power Wheelchair.

The indications for use, design, structure, composition, principle of operation 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 same, and both meet the requirements of the ISO 7176-14. Software validation is carried out on both control systems. Brake system and speed control are designed in the same way as well, and both meet the requirements of 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 requirements of 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 requirements of the ISO 10993-5:2009 & ISO 10993-10:2021 & ISO 10993-23: 2021.

Page 17

The flame-retardant test of the seat cushion/ backrest of both subject device and predicate device is carried out according 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

a) Product Material Safety

To ensure the safety of the wheelchair material, the bio-compatibility testing was done to the products. The testing was conducted according to the following standards:

  • ISO10993-5 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.

b) 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
  • 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 and deceleration 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

Page 18

  • 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 disclosure, documentation 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 proceduresd
  • 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.

I. Conclusion

The proposed device and predicate device 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 substantially equivalent.