The SE-1200 Pro&SE-1201 Pro 12-lead electrocardiographs are intended to acquire ECG signals from adult and pediatric patients through body surface ECG electrodes. The electrocardiographs are only intended to be used in hospitals or healthcare facilities by doctors and trained healthcare professionals. The cardiogram recorded by the electrocardiograph can help users to analyze and diagnose heart disease. However, the interpreted ECG with measurements and interpretive statements is offered to clinicians on an advisory basis only.
Device Story
12-lead electrocardiograph (SE-1200 Pro/SE-1201 Pro) acquires ECG signals via body surface electrodes; processes signals to generate measurements, graphical presentations, and interpretive statements; displays data on LCD touch screen; prints reports via thermal dot-matrix recorder; saves records to flash memory or transmits to PC. Used in hospitals/healthcare facilities by physicians and trained professionals. Provides advisory interpretive statements to assist clinicians in heart disease diagnosis. Features battery or AC power operation; supports wireless connectivity (WIFI, 4G, Bluetooth).
Clinical Evidence
No clinical data. Bench testing only. Functional and system-level testing validated performance against accuracy specifications and consensus standards (IEC 60601-1, IEC 60601-1-2, IEC 60601-2-25). Software verification and validation conducted per FDA guidance.
Technological Characteristics
12-lead ECG; 24-bit A/D conversion; 64,000 Hz sampling frequency; 0.01-350 Hz frequency response; ≥100 MΩ input impedance; thermal dot-matrix recorder (210mm width). Powered by AC (100-240V) or internal lithium battery. Connectivity: WIFI, 4G, Bluetooth. Safety: Class I, Type CF. Software algorithms: SEMIP or Glasgow.
Indications for Use
Indicated for adult and pediatric patients requiring ECG signal acquisition via body surface electrodes. Intended for use in hospitals or healthcare facilities by doctors and trained healthcare professionals to assist in the analysis and diagnosis of heart disease.
Regulatory Classification
Identification
An electrocardiograph is a device used to process the electrical signal transmitted through two or more electrocardiograph electrodes and to produce a visual display of the electrical signal produced by the heart.
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July 28, 2023
Edan Instruments, Inc. Milin Wu Regulatory Engineer #15 Jinhui Road, Jinsha Community, Kengzi Sub-District Pingshan District Shenzhen, Guangdong 518122, China
Re: K222902
Trade/Device Name: Electrocardiograph, model: SE-1200 Pro and SE-1201 Pro Regulation Number: 21 CFR 870.2340 Regulation Name: Electrocardiograph Regulatory Class: Class II Product Code: DPS Dated: June 28, 2023 Received: July 5, 2023
Dear Milin Wu:
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.
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.
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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-regulatoryinformation/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 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,
Shruti N. Mistry -S
for
Jennifer Shih Kozen Assistant Director Division of Cardiac Electrophysiology, Diagnostics and Monitoring Devices Office of Cardiovascular Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health
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# Indications for Use
510(k) Number (if known) K222902
Device Name Electrocardiograph(SE-1200 Pro. SE-1201 Pro)
#### Indications for Use (Describe)
The SE-1200 Pro&SE-1201 Pro 12-lead electrocardiographs are intended to acquire ECG signals from adult and pediatric patients through body surface ECG electrocardiographs are only intended to be used in hospitals or healthcare facilities by doctors and trained healthcare professionals. The cardiogram recordiograph can help users to analyze and diagnose heart disease. However, the interpreted ECG with measurements and interpretive statements is offered to clinicians on an advisory basis only.
| Type of Use (Select one or both, as applicable) | |
|-------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------|
| <div> <span> <span style="text-decoration: overline;">X</span> Prescription Use (Part 21 CFR 801 Subpart D) </span> </div> | <div> <span> Over-The-Counter Use (21 CFR 801 Subpart C) </span> </div> |
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# 510(K) Summary
# Prepared in accordance with the content and format regulatory requirements of 21 CFR Part 807.92
| 1. Submitter: | Edan Instruments, Inc.<br>#15 Jinhui Road, Jinsha Community, Kengzi Sub-District, Pingshan<br>District, Shenzhen, 518122 P.R.China.<br>Tel: +86(0755) 84513592<br>Fax: +86(0755) 26882223 | |
|---------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------|
| | Liu Yongying | |
| Contact person:<br>Preparing date: | September 19, 2022 | |
| | Trade Name: Electrocardiograph, model: SE-1200 Pro, SE-1201 Pro | |
| 2. Device name and<br>classification: | Common/Usual Name: Electrocardiograph | |
| | Classification Name | Product code |
| | 21 CFR 870.2340 Electrocardiograph | DPS |
| | Regulatory Class: Class II | |
| 3. Predicate Device(s): | 1) Edan Instruments, iSE-1210 Electrocardiograph, cleared under K212278<br>(Primary)<br>2) Edan Instruments, SE-1202 Electrocardiograph, cleared under K210140<br>(Reference) | |
| 4. Device Description: | SE-1201 Pro&SE-1200 Pro (2 models: SE-1201 Pro and SE-1200 Pro) features<br>a LCD touch screen, an operation panel, user-programmable reports, and the<br>ability to operate on either battery or AC power. It is capable of simultaneous<br>acquisition, display, and print of 12-lead ECG. It uses algorithm to generate<br>measurements, data presentations, graphical presentations and interpretative<br>statements. The record can be saved in flash memory or send to PC. | |
| 5. Indication for Use | The SE-1200 Pro&SE-1201 Pro 12-lead electrocardiographs are intended to<br>acquire ECG signals from adult and pediatric patients through body surface<br>ECG electrodes. The electrocardiographs are only intended to be used in<br>hospitals or healthcare facilities by doctors and trained healthcare professionals.<br>The cardiogram recorded by the electrocardiograph can help users to analyze<br>and diagnose heart disease. However, the interpreted ECG with measurements | |
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# 6. Predicate Device Comparison
Comparison to the predicate devices, the subject device has the same intended use, similar product design, same performance effectiveness, performance safety as the predicate device as summarized in the following tables:
| Item | Primary predicate device<br>(iSE-1210) | Proposed device<br>(SE-1201 Pro&SE-1200 Pro) | Comparison Result |
|----------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------|
| K# | K212278 | K222902 | — |
| Intended Use | The iSE Series electrocardiograph is<br>intended to acquire ECG signals from adult<br>and pediatric patients through body surface<br>ECG electrodes. The electrocardiograph is<br>only intended to be used in hospitals or<br>healthcare facilities by doctors and trained<br>healthcare professionals. The cardiogram<br>recorded by the electrocardiograph can<br>help users to analyze and diagnose heart<br>disease. However, the interpreted ECG<br>with measurements and interpretive<br>statements is offered to clinicians on an<br>advisory basis only. The electrocardiograph<br>is capable of network communications and<br>supports the informatized management of<br>workflows in hospital and healthcare<br>facilities. | The SE-1200 Pro&SE-1201 Pro 12-lead<br>electrocardiographs are intended to acquire<br>ECG signals from adult and pediatric<br>patients through body surface ECG<br>electrodes. The electrocardiographs are only<br>intended to be used in hospitals or<br>healthcare facilities by doctors and trained<br>healthcare professionals. The cardiogram<br>recorded by the electrocardiograph can help<br>users to analyze and diagnose heart disease.<br>However, the interpreted ECG with<br>measurements and interpretive statements is<br>offered to clinicians on an advisory basis<br>only. | Different |
| Algorithm | SEMIP | SEMIP or Glasgow | Different |
| Number of electrodes | 10 | 10 | Same |
| Safety Specifications | | | |
| Safety Standards | IEC 60601-1:2005/A1:2012<br>IEC 60601-1-2:2014<br>IEC 60601-2-25:2011 | IEC 60601-1:2005/A1:2012<br>IEC 60601-1-2:2014<br>IEC 60601-2-25:2011 | Same |
| Anti-electric-shock type | Class I with internal power supply | Class I with internal power supply | Same |
| Anti-electric-shock<br>degree | Type CF | Type CF | Same |
| Power Supply Specifications | | | |
| Mains Supply | Operating Voltage = 100V-240V~ | Operating Voltage = 100V-240V~ | Same |
| | Operating frequency = 50 Hz / 60 Hz | Operating frequency = 50 Hz / 60 Hz | |
| | Output Power: 19V, 2.53A | Output Power: 19V, 2.53A | |
| | Rated voltage = 15.2V | Rated voltage = 14.8 V | Different |
| | Rated capacity = 3550mAh | Rated capacity = 2500mAh | |
| Built-in Lithium Battery<br>Pack | When the battery is fully charged, iSE can<br>work (without printing) continuously at<br>least 8 hours.<br>100% recharge time: ≤ 5 hours<br>90% recharge time: < 4 hours | When the battery is fully charged, the<br>SE-1200 Pro&SE-1201 Pro<br>electrocardiograph can work for ≥4 H in<br>auto mode (printing a report once every 2<br>minutes), the SE-1200 Pro&SE-1201 Pro<br>electrocardiograph can work for≥2 H in<br>manual mode, and print 3*4+1R copies of<br>reports automatically ≥ 250 copies.<br>The battery takes just under 2 hours to<br>charge from empty to 90%. | |
| Recording | | | |
| Recorder | Thermal dot-matrix recorder | Thermal dot-matrix recorder | Same |
| Effective Width | 210mm | 210mm | Same |
| ECG Unit | | | |
| HR Range | 30 BPM ~ 300 BPM<br>±1 BPM | 30 BPM ~ 300 BPM<br>±1 BPM | Same |
| A/D | 24 bits | 24 bits | Same |
| Sampling Frequency | 64,000 Hz | 64,000 Hz | Same |
| Frequency<br>Response | 0.01 Hz ~ 350 Hz (-3 dB) | 0.01 Hz ~ 350 Hz (-3 dB) | Same |
| Input Impedance | ≥100 MΩ(10 Hz) | ≥100 MΩ(10 Hz) | Same |
| DC Offset Voltage | ±900 mV | ±960mV, ±5% | Different |
| Noise | ≤12.5 μVp-p | ≤12.5 μVp-p | Same |
| Filter | AC Filter:<br>50 Hz / 60 Hz / Off<br>DFT Filter:<br>0.01 Hz / 0.05 Hz / 0.32 Hz / 0.67 Hz<br>EMG Filter: | AC Filter:<br>50 Hz / 60 Hz / Off<br>DFT Filter:<br>0.01 Hz / 0.05 Hz / 0.32 Hz / 0.67 Hz<br>EMG Filter: | Same |
| | LOWPASS Filter:<br>350 Hz / 300 Hz / 270 Hz / 150 Hz / 100 Hz / 75 Hz | LOWPASS Filter:<br>350 Hz / 300 Hz / 270 Hz / 150 Hz / 100 Hz / 75 Hz | |
| CMRR | ≥140 dB (AC filter on)<br>≥123 dB (AC filter off) | ≥140 dB (AC filter on)<br>≥123 dB (AC filter off) | Same |
| Pacemaker Detection | | | |
| Amplitude | ±500μV to ±700mV | ±500μV to ±700mV | |
| Width | 30μs to 2.0ms | 30μs to 2.0ms | Same |
| Sampling Frequency | 80,000 /sec/channel, Rhythm Lead | 80,000 /sec/channel, Rhythm Lead | |
| Connection | | | |
| Wireless connection | WIFI, 4G, Bluetooth, NFC | WIFI, 4G, Bluetooth, | Different |
Table 2-1: Comparison between SE-1201 Pro&SE-1200 Pro and iSE-1210 (primary predicate device)
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#### Table 2-2: Comparison between SE-1201 Pro&SE-1200 Pro and SE-1202 (reference predicate device)
| Item | Reference predicate device<br>(SE-1202) | Proposed device<br>(SE-1201 Pro&SE-1200 Pro) | Comparison Result |
|--------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------|
| K# | K210140 | Current Submission | — |
| Intended Use | The SE-1202 12-lead electrocardiograph is intended to acquire ECG signals from adult and pediatric patients through body surface ECG electrodes. The electrocardiograph is only intended to be used in hospitals or healthcare facilities by doctors and trained healthcare professionals. The cardiogram recorded by the electrocardiograph can help users to analyze and diagnose heart disease. However, the interpreted ECG with measurements and interpretive statements is offered to clinicians on an advisory basis only. | The SE-1200 Pro&SE-1201 Pro 12-lead electrocardiographs are intended to acquire ECG signals from adult and pediatric patients through body surface ECG electrodes. The electrocardiographs are only intended to be used in hospitals or healthcare facilities by doctors and trained healthcare professionals. The cardiogram recorded by the electrocardiograph can help users to analyze and diagnose heart disease. However, the interpreted ECG with measurements and interpretive statements is offered to clinicians on an advisory basis only. | Same |
| Algorithm | SEMIP or Glasgow | SEMIP or Glasgow | Same |
As seen in the comparison tables, the subject and predicate devices have similar design features and performance specifications. The technological differences between the subject and predicate devices do not raise different questions of safety or effectiveness.
# 7. Performance Data:
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# Non-clinical data:
# Electrical safety and electromagnetic compatibility (EMC)
The SE-1201 Pro&SE-1200 Pro electrocardiograph were assessed for conformity with the relevant requirements of the following standards and found to comply:
- ANSI AAMI ES 60601-1:2005/(R) 2012 and A1:2012, C1:2009(R) 2012 and A2:2010(R) 2012 Medical electrical equipment - Part 1: General requirements for basic safety and essential performance.
- IEC 60601-1-2:2014 (Fourth Edition) Medical electrical equipment – Part 1-2: General requirements for basic safety and essential performance - Collateral Standard: electromagnetic disturbances - Requirements and tests.
## Performance testing-Bench
Edan has conducted functional and system level testing to validate the performance of the results of the bench testing show that the subject device meets its accuracy specification and meet relevant consensus standards.
- IEC 60601-2-25 Edition 2.0 2011-10 Medical electrical equipment - Part 2-25: Particular requirements for the basic safety and essential performance of electrocardiographs
## Software Verification and Validation Testing
Software verification and validation testing were conducted and documentation was provided as recommended by FDA's Guidance for Industry and FDA Staff, "Guidance for the Content of Premarket Submissions for Software Contained in Medical Devices".
## Clinical data: Not applicable.
## Summary
The non-clinical performance testing showed that the subject devices are as safe and as effective as the predicate device.
## 8. Conclusion
The bench testing data and software verification and validation demonstrate that Electrocardiograph SE-1201 Pro&SE-1200 Pro is substantially equivalent to the predicate devices.
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Part 1 — Search, results, and everyday workflows 16 min
Part 2 — Embeddings: the galaxy map 3 min
1. Search: exact and fuzzy
Type a phrase like "coronary artery calcification" into the search box. You get two kinds of results. Exact results match the literal phrase — prefix searches work ("coronary artery calcificati") but suffix searches do not. Fuzzy results match on the meaning and intent of your phrase rather than the exact words, and are sorted by relevance score. Hover over the Exact or Fuzzy badge on any row to see exactly why it matched.
Use the checkboxes above the results to narrow: SaMD keeps only software-only devices, AI / ML keeps only devices with AI.
Exact vs. fuzzy search: what's the difference?
Exact matches on the literal phrase (prefix search works, suffix does not). Fuzzy matches on the meaning and intent of the phrase rather than the exact words. Hover over the badge on any row to see why it matched.
You search "coronary artery calcification" and want only software devices with AI. What two filters do you apply?
Narrow by SaMD (software-only devices), then narrow by AI/ML (devices with AI).
2. The results table
Scroll right in the results table. The intended use is extracted for you — no need to open the PDF. The device story gives a high-level snapshot of what the device does and how it's used. The AI Performance sub-table shows each output name, acceptance criteria, observed values, and development/test dataset descriptions — the same format Innolitics uses for regulatory strategy outputs, and the fastest high-level fingerprint of an AI device. It is AI-generated but has been very reliable in practice.
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Scroll right in the search results table. The intended use column is extracted for you; no need to dig into the 510(k) summary PDF.
What does the AI Performance sub-table show, and why is it useful?
Output name, acceptance criteria, observed values, development dataset description, and test dataset description. It's the same format we use for regulatory strategy output and Fast 510(k) input, and the fastest high-level fingerprint of an AI device. AI-generated but reliable in practice.
3. Judging fuzzy relevance
Fuzzy results trail off in relevance as you scroll. Use three signals to decide how far down to go: the fuzzy badge explanations, the intended use column, and whether your target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, you're past the relevant zone. A top hit with a low score (~0.4) and a stretched explanation is a hint the closest predicates are far away — the project may be headed for De Novo. Note the fuzzy search is a pattern match: it doesn't handle negation ("not") well, and hardware devices can appear — filter by SaMD/AI ML to cut them.
How do you judge how far down fuzzy search results to go?
Use the relevancy signals: the fuzzy badge explanations, the intended use column, and whether the target output (e.g., Cobb angle) still appears in the AI Performance sub-table. Once it stops appearing, results are trailing off in relevancy.
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Reading rule for every project: how many summaries do you read in full?
At least the three most relevant 510(k) or De Novo summaries, in full. After that, use targeted chat questions to confirm your memory quickly. The tool supports this professional habit — it doesn't replace it.
5. Side-by-side comparison
Select multiple rows in the results table (aim for under ~10), then open the PDF Viewer tab. Ask one question — it goes to all selected devices in parallel, each with citations. This is the fastest way to compare and contrast devices: training data, PCCP scope, how they handled adding new scanners, and so on.
What does the side-by-side PDF viewer mode do?
Select multiple devices, open the PDF viewer tab, and ask one question (e.g., "Describe the training data"). It queries all selected devices simultaneously with citations, so you can compare and contrast quickly.
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With rows selected, go to the Collections tab and create a labeled collection (e.g., "Cobb Angle Project"). Reload that selection any time — before a client call, pull up the collection and ask questions across all of its devices at once.
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What can you do from the regulations tree view?
Browse product codes and regulation numbers, read the identification text and special controls, browse sibling product codes, open device PDFs on the right, and search by product code or regulation number at the top of the tree.
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Click Show Chart and segment by regulation number (or product code) to see which regulations dominate your result set. Clicking a regulation takes you into the regulations tree. Great for spotting that most matches are, say, hardware laparoscopic devices — a cue to go back and filter.
How do you see which regulations dominate a search result set?
Click "Show Chart" and segment by Regulation Number. Clicking a regulation takes you to the regulations tree.
9. The predicate graph
Open the Predicates tab for a family-tree view of predicate relationships. Click a node to trace its parents and children; selections from search carry over pre-selected. Commonly predicated devices are worth reading — a lot of people predicated them for a reason. The visual lineage is also handy on client calls, e.g. to show how a predicate family evolved and justify why your predicate still holds.
In the predicate graph, why are commonly predicated devices worth reading?
A lot of people predicated them for a reason. Clicking a node traces parents and children, and selections from search carry over pre-selected.
10. Embeddings: the galaxy map
The Embeddings tab plots every matching document in a 2-D "galaxy map" where semantically similar devices cluster together. Hover or click clusters to explore, and let AI label the clusters for you. Embeddings beat product codes for grouping: two devices can carry different product codes (LLZ vs. QIH) yet do the same thing — the embedding captures the meaning of the intended use and device story. This is also exactly how retrieval-augmented generation (RAG) works under the hood, and it makes a great visual on client calls.
Try it yourself
Head to the search page and work through a few of these AI/ML fuzzy searches to build intuition: perivascular fat on CT · aortic valve calcification opportunistic screening on noncontrast CT · breast cancer prediction on digital pathology slides · autism detection · gestational age prediction · a hearing aid that can also detect a pulse · foundation model based analysis of ECG · large language models · penetration test. Watch how the relevance scores, intended use, and AI Performance tables tell you when results stop being meaningful.