LED Therapy Device (Planar LED/Planar LED mini)

{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 & Human Services logo on the left and the FDA text logo on the right. The FDA text logo is in blue and includes the letters "FDA" followed by "U.S. FOOD & DRUG ADMINISTRATION" in a smaller font size. April 12, 2022 Shenzhen Leaflife Technology Co., Ltd Cheng Qiang Regulatory registration supervisor 4F,Bldg. C, JMD Industrial Park, No.39 Qingfeng Blvd., Baolong Industrial Area, Longgang Dist., Shenzhen, Guangdong 518116 China Re: K220103 Trade/Device Name: LED Therapy Device (Planar LED/Planar LED mini) Regulation Number: 21 CFR 878.4810 Regulation Name: Laser Surgical Instrument For Use In General And Plastic Surgery And In Dermatology Regulatory Class: Class II Product Code: OHT Dated: January 6, 2022 Received: January 12, 2022 Dear Cheng Qiang: 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 (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 located 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}------------------------------------------------ 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 803) for devices or postmarketing safety reporting (21 CFR 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 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR Part 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). Sincerely. Purva Pandya Assistant Director DHT4A: Division of General Surgery Devices OHT4: Office of Surgical and Infection Control Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health Enclosure {2}------------------------------------------------ # Indications for Use 510(k) Number (if known) K220103 Device Name LED Therapy Device (Planar LED/ Planar LED mini) Indications for Use (Describe) The LED Therapy Device is intended for hair removal, permanent hair reduction on all skin type I-VI), including tanned skin. Permanent hair reduction is defined as the long-term, stable reduction in the number of hairs regrowing when measured at 6, 9, and 12 months after the completion of a treatment regime. | Type of Use (Select one or both, as applicable) | | |---------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------| | <div> <span> Prescription Use (Part 21 CFR 801 Subpart D) </span> </div> | <div> <span> Over-The-Counter Use (21 CFR 801 Subpart C) </span> </div> | ### CONTINUE ON A SEPARATE PAGE IF NEEDED. 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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." {3}------------------------------------------------ # 510(k) Summary In accordance with 21 CFR 807.92 the following summary of information is provided: #### SUBMITTER l. Shenzhen Leaflife Technology Co., Ltd 4F, Bldg. C, JMD Industrial Park, No.39 Qingfeng Blvd., Baolong Industrial Area, Longgang Dist., Shenzhen, RP China Phone: 086-(0)17875910506 Fax: 086-0755-27215592 | Primary Contact Person: | Cheng Qiang | |-------------------------|---------------------------------------| | | Regulatory Affairs Manager | | | Shenzhen Leaflife Technology Co., Ltd | | Tel: | 086-0755-27216609 | | Fax: | 086-0755-27215592 | | Phone: | 086-(0)17875910506 | | Email: | cq@leaflife.cn | Date Prepared: 01/06/2022 {4}------------------------------------------------ Image /page/4/Picture/0 description: The image shows the logo for LEAFLIFE. The logo is in blue and green, with the word "LEAFLIFE" in blue, with a green line above the "F" and "E". Above the word is a green arc with a leaf at the top. Below the word is the Chinese translation of the word in gray. #### II. PROPOSED DEVICE | Trade Name: | LED Therapy Device | |----------------------|-----------------------------------------------------| | Common Name: | Powered Laser Surgical Instrument | | Classification Name: | Powered Laser Surgical Instrument (21 CFR 878.4810) | | Regulation Class: | II | | Product Code: | OHT | | Review Panel: | General & Plastic Surgery | # III. PREDICATE DEVICE | Predicate device (Primary) | Laser Therapy Device, Model LM-L808A: K202980 | |----------------------------|----------------------------------------------------------| | Predicate device | TRIA Laser Hair Removal System, Model TRIA: K120737 | | Predicate device | IPL Salon Hair Reduction System, Model F60001<br>K181568 | The predicates have not been subject to a design-related recall. # IV. DEVICE DESCRIPTION The LED Therapy Device is a surgical device intended for use in dermatologic and general surgical procedure. It utilizes a diode LED as a light source (780-850 nm). The LED light power is delivered to the treatment area via a LED hand piece. The emission LED is activated by a foot switch and a hand piece. The proposed LED Therapy Device is equipped with a light depilation function that is based on the theory of selective photo thermolysis. There is abundant melanin in the hair follicle and hair stem. The melanin is distributed amidst the cells between the hair ball substrate and it can be transferred to the structure of hair stems (such as medulla, cortex, and hair cuticle). The Near infrared light can precisely target the melanin and apply the depilation treatment selectively. After the melanin absorbs Near infrared light energy, the temperature rises, in this way, the surrounding hair follicle tissues are damaged, and the hairs are removed. {5}------------------------------------------------ Image /page/5/Picture/1 description: The image shows the logo for LEAFLIFE. The logo has the word "LEAFLIFE" in blue, with a green arc above the word. There is a green leaf on the right side of the arc. Below the word "LEAFLIFE" are two Chinese characters in gray. ### V. INTENDED USE The LED Therapy Device is intended for hair removal, permanent hair reduction on all skin types (Fitzpatrick skin type I-VI), including tanned skin. Permanent hair reduction is defined as the long-term, stable reduction in the number of hairs regrowing when measured at 6, 9, and 12 months after the completion of a treatment regime. # vi. COMPARISON OF TECHNOLOGICAL CHARACTERISTICS WITH THE PREDICATE DEVICE The LED Therapy Device (LM-LNIRA, LM-LNIRB) is substantially equivalent to the cleared predicate device. The LED Therapy Device (LM-LNIRA, LM-LNIRB) has the same intended use, and similar technological characteristics such as fluence, wavelength, spot size, and pulse duration, etc. with the predicates. Please refer to the following table for details: {6}------------------------------------------------ Image /page/6/Figure/0 description: The image shows the logo for LEAFLIFE. The logo is a combination of text and a graphic element. The text "LEAFLIFE" is written in a stylized font, with the top half of the letters in green and the bottom half in blue. Above the text is a green leaf, and to the right of the leaf are some green bubbles. Below the text are some Chinese characters. | Item | Proposed Device | Predicate Device<br>K202980 (Primary) | Predicate Device<br>K120737 | Predicate Device<br>K181568 | Remark | |------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------| | Device name | LED Therapy Device<br>(Planar LED/ Planar LED mini) | Laser Therapy Device | TRIA Laser Hair Removal<br>System (TRIA) | IPL Salon Hair Reduction<br>System | / | | Product model | LM-LNIRA, LM-LNIRB | LM-L808A | TRIA | F60001 | / | | K number | On pending | K202980 | K120737 | K181568 | / | | Product code | OHT | GEX | GEX | OHT | Same | | Classification<br>regulation | 21 CFR 878.4810 | 21 CFR 878.4810 | 21 CFR 878.4810 | 21 CFR 878.4810 | Same | | Item | Proposed Device | Predicate Device<br>K202980 (Primary) | Predicate Device<br>K120737 | Predicate Device<br>K181568 | Remark | | Intended Use | The LED Therapy Device is<br>intended for hair removal,<br>permanent hair reduction on all<br>skin types (Fitzpatrick skin type<br>I-VI), including tanned skin.<br>Permanent hair reduction is<br>defined as the long-term, stable<br>reduction in the number of<br>hairs regrowing when measured<br>at 6, 9, and 12 months after the<br>completion of a treatment<br>regime. | The Laser Therapy Device is<br>intended for hair removal,<br>permanent hair reduction<br>on all skin types (Fitzpatrick<br>skin type I-VI), including<br>tanned skin.<br>Permanent hair reduction is<br>defined as the long-term,<br>stable reduction in the<br>number of hairs regrowing<br>when measured at 6, 9, and<br>12 months after the<br>completion of a treatment<br>regime. | TRIA is an<br>over-the-counter device<br>intended for adjunctive<br>use with shaving for hair<br>removal sustained with<br>periodic treatments. TRIA<br>is also intended for<br>permanent reduction in<br>hair regrowth defined as a<br>long-term, stable<br>reduction in hair counts<br>following a treatment<br>regime. Permanent hair<br>reduction is defined as<br>long term, stable<br>reduction in the number<br>of hairs regrowing when<br>measured out to 6, 9, and<br>12 months after the<br>completion of the<br>treatment regimen. | The IPL Salon Hair<br>Reduction System (Model:<br>F60001) is an over the<br>Counter device intended<br>for the removal of<br>unwanted body and/or<br>facial hair in adults. It is<br>also intended for<br>permanent reduction in<br>unwanted hair.<br>Permanent hair reduction<br>is defined as the long-term<br>stable reduction in the<br>number of hairs<br>re-growing when<br>measured at 6. 9. and 12<br>months after the<br>completion of a treatment<br>regimen. | Same | | Prescription<br>use or not | Prescription use | Prescription use | Over-The-Counter Use | Over-The-Counter Use | Same | | Configuration | Main Unit | Main Unit | Main Unit | Main Unit | Same | | | Hand piece | Handpiece | / | Finger switch | Same | | Item | Proposed Device | Predicate Device<br>K202980 (Primary) | Predicate Device<br>K120737 | Predicate Device<br>K181568 | Remark | | | Foot Control | Foot Control | / | / | Same | | Laser Type | Diode LED | Diode laser | Diode laser | Xenon Arc Flashlamp | Discussion<br>1 | | Laser<br>Classification | Risk Group 3 | Class IV | Class IV | Exempt group | Discussion<br>1 | | Laser<br>Wavelength | 780-850 nm | 808 nm | 800nm +/-20%<br>(640nm-960nm) | 475nm~1200nm | Discussion<br>1 | | Spot size | (17mm*22mm)<br>(LM-LNIRA)<br>(17mm*17mm)<br>(LM-LNIRB) | (12mm*12mm) 1.44cm² | $Φ$ 10mm (Round) | Treatment Area (regular<br>window): 3.025 [cm²]<br>Treatment area (facial<br>adapter): 1.72 [cm²] | Discussion<br>2 | | Fluence | 1-100J/cm² | 1-100J/cm² | 6J/cm², 10J/cm², 14J/cm²,<br>18J/cm², 22J/cm² | Level 1: 8.62J<br>Level 2: 9.45J<br>Level 3: 10.64J<br>Level 4: 11.48J<br>Level 5: 12.70J | Same | | Frequency | 1-10Hz | 1-10Hz | / | / | Same | | Pulse Duration | 3-400ms | 5-400ms | / | 11-12ms | Similar | | Item | Proposed Device | Predicate Device<br>K202980 (Primary) | Predicate Device<br>K120737 | Predicate Device<br>K181568 | Remark | | Power Supply | AC 220~240V 50/60 Hz<br>or<br>AC 100~120V 50/60 Hz | AC 220~240V 50/60 Hz<br>or<br>AC 100~120V 50/60 Hz | 100~240V,50/60Hz | 100-240 VAC, 50/60Hz | Discussion<br>3 | | Dimension | 430mm x 500mm x 870mm<br>(LM-LNIRA)<br>408mm x 460mm x 593mm<br>(LM-LNIRB) | 650mm x 430mm x 315mm | / | 143*69.5*43mm(H*W*D) | Discussion<br>3 | | Weight | 30kg (LM-LNIRA)<br>24kg (LM-LNIRB) | 22kg | / | 650g | Discussion<br>3 | {7}------------------------------------------------ Image /page/7/Figure/0 description: The image shows the logo for LEAFLIFE. The logo is in blue and green, with a stylized leaf above the "L". The text "LEAFLIFE" is in blue, with a green line running through the middle of each letter. Below the text is a blue curved line. There is also some text in another language below the English text. {8}------------------------------------------------ Image /page/8/Figure/0 description: The image shows the logo for LEAFLIFE. The logo features the word "LEAFLIFE" in blue and green, with a green leaf above the "F". There are also some Chinese characters below the word "LEAFLIFE". {9}------------------------------------------------ Image /page/9/Figure/1 description: The image shows the logo for LEAFLIFE. The logo is blue and green, and it features a stylized leaf and the word "LEAFLIFE" in a modern font. There is also some text in another language below the word LEAFLIFE. The logo is clean and simple, and it conveys a sense of nature and life. #### Discussion 1 The proposed device is different in Laser Classification, Laser Wavelength, and Laser Safety test standard from the predicate device. Mainly because of these differences caused by the inconsistency of Laser Type, this difference can be proved by non-clinical test There is no security impact. The difference that mainly affects performance may exist in the difference in Laser Wavelength can be verified by the Predicate device (K120737), Predicate device (K181568) and the wavelength range of light absorbed by melanin to prove that there is no effect on performance. Therefore, this difference will not affect the substantial equivalency. #### Discussion 2 The proposed device is different in Spot Size only affects the area of treatment, not affecting the therapeutic effect, Therefore, this difference will not affect the substantial equivalency. #### Discussion 3 {10}------------------------------------------------ Image /page/10/Picture/1 description: The image shows the logo for LEAFLIFE. The logo is a combination of text and a graphic. The text "LEAFLIFE" is written in a stylized font, with the top half of the letters in green and the bottom half in blue. Above the text is a green leaf graphic. Below the text is the Chinese translation of the name. The proposed device is different in dimension and weight from the predicate device. By complying with ANS/AAMI ES60601-1, the Electrical Safety of the proposed device is determined to be accepted, this difference will not affect the substantial equivalency. | Item | Proposed Device | Predicate Device<br>K202980 (Primary) | Predicate Device<br>K120737 | Predicate Device<br>K181568 | Remark | |------------------------------|------------------------------------------|------------------------------------------|------------------------------------------|------------------------------------------|---------| | Patient Contact<br>Materials | Sapphire in handpiece | Sapphire in handpiece | / | / | Same | | Cytotoxicity | No Cytotoxicity | No Cytotoxicity | / | / | Same | | Sensitization | No evidence of sensitization | No evidence of<br>sensitization | / | / | Same | | Irritation | No evidence of irritation | No evidence of irritation | / | / | Same | | Electrical Safety | Comply with ANSI/AAMI<br>ES60601-1 | Comply with ANSI/AAMI<br>ES60601-1 | Comply with IEC 60601-1. | Comply with IEC<br>60601-1. | Same | | EMC | Comply with IEC 60601-1-2 | Comply with IEC<br>60601-1-2 | Comply with IEC<br>60601-1-2 | Comply with IEC<br>60601-1-2 | Same | | Laser Safety | Comply with IEC<br>60601-2-57, IEC 62471 | Comply with IEC<br>60601-2-22, IEC 60825 | Comply with IEC<br>60601-2-22, IEC 60825 | Comply with IEC<br>60601-2-57, IEC 62471 | Similar | {11}------------------------------------------------ Image /page/11/Picture/0 description: The image shows the logo for LEAFLIFE. The logo is composed of the word "LEAFLIFE" in blue and green, with a green leaf above the "L". There is also some text in another language below the word "LEAFLIFE". The logo is simple and modern, and it conveys a sense of nature and health. ## VII. Non-Clinical Test Conclusion Non-clinical tests were conducted to verify that the proposed device met all design specifications as was Substantially Equivalent (SE) to the predicate device. The test results demonstrated that the proposed device complies with the following standards: ES60601-1:2005/(R) 2012 and A1:2012, C1:2009/(R)2012 and ANSI/AAMI A2:2010/(R)2012, Medical electrical equipment — Part 1: General requirements for basic safety and essential performance IEC 60601-1-2:2014, Medical electrical equipment - Part 1-2: General requirements for basic safety and essential performance - Collateral Standard: Electromagnetic disturbances - Requirements and tests. IEC 60601-2-57:2011, Medical Electrical Equipment - Part 2-57: Particular requirements for the basic safety and essential performance of non-laser light source equipment intended for therapeutic, diagnostic, monitoring and cosmetic/aesthetic use. IEC 62471:2006, Photobiological safety of lamps and lamp systems. ISO 10993-5 Third Edition 2009-06-01, Biological Evaluation of Medical Devices - Part 5: Tests For In Vitro Cytotoxicity. (Biocompatibility) ISO 10993-10 Third Edition 2010-08-01, Biological Evaluation of Medical Devices -Part 10: Tests for Irritation and Skin Sensitization. (Biocompatibility) Performance Testing for Spot Size Accuracy and Energy Output Accuracy. VIII. CLINICAL TEST CONCLUSION No clinical study is included in this submission. # IX. SUBSTANTIALLY EQUIVALENT (SE) CONCLUSION Based on the comparison and analysis above, the proposed device is determined to be Substantially Equivalent (SE) to the predicate device.