K153514 · Premium Plus International Limited · EBZ · Aug 22, 2016 · Dental
Device Facts
Record ID
K153514
Device Name
Premium Plus C01/C02 LED Curing Light
Applicant
Premium Plus International Limited
Product Code
EBZ · Dental
Decision Date
Aug 22, 2016
Decision
SESE
Submission Type
Abbreviated
Regulation
21 CFR 872.6070
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
Premium Plus C01/C02 Dental Curing Light is intended for use by trained dental professionals for the purpose of curing dental composites by light.
Device Story
Handheld dental curing light; utilizes blue LED technology to polymerize light-cured dental materials. Device comprises handpiece, charging station, plug-in transformer, and protective light shield. C01 model uses fiber optic light guide; C02 model uses direct light source head. Operated by dental professionals in clinical settings. Three curing modes (Full, Ramp, Pulse) provide flexibility for various composites/sealants. Protective shield filters blue light for eye safety; barrier sleeves required between patients. Output is high-intensity blue light (440-480nm). Clinical benefit is efficient, reliable polymerization of dental resins.
Clinical Evidence
Bench testing only. Performance evaluated via electrical safety, electromagnetic compatibility, LED lamp testing, and depth of cure. Results confirm conformance to IEC 60601-1, IEC 60601-1-2, and ISO 10650-2 / ANSI/ADA Specification No. 48-2.
Technological Characteristics
Blue LED light source; 440-480nm wavelength (peak 460nm). Three operational modes: Full, Ramp, Pulse. Power: 3.7V 1100mAh Li-ion battery. Charging via AC 100-240V transformer. C01 features fiber optic light guide; C02 features direct light head. Standards: IEC 60601-1:2005, IEC 60601-1-2:2007, ISO 10650-2:2007. Handpiece dimensions: Ø2.7cm x 24cm; weight 160g.
Indications for Use
Indicated for trained dental professionals to polymerize dental light-cured materials (composites, bonding agents, sealants).
Regulatory Classification
Identification
An ultraviolet activator for polymerization is a device that produces ultraviolet radiation intended to polymerize (set) resinous dental pit and fissure sealants or restorative materials by transmission of light through a rod.
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Food and Drug Administration 10903 New Hampshire Avenue Document Control Center - WO66-G609 Silver Spring, MD 20993-0002
August 22, 2016
Premium Plus International Limited Jessica Mao QA Engineer Flat 1001 Yuen Long Trading Centre, 33 Wang Yip Street West, Yuen Long, N.T. Hong Kong CHINA
Re: K153514
Trade/Device Name: Premium Plus C01/C02 LED Curing Light Regulation Number: 21 CFR 872.6070 Regulation Name: Ultraviolet activator for polymerization Regulatory Class: Class II Product Code: EBZ Dated: July 7, 2016 Received: July 14, 2016
Dear Ms. Jessica Mao:
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. 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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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 803); good manufacturing practice requirements as set forth in the quality systems (QS) regulation (21 CFR Part 820); and if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR 1000-1050.
If you desire specific advice for your device on our labeling regulation (21 CFR Part 801), please contact the Division of Industry and Consumer Education at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address
http://www.fda.gov/MedicalDevices/Resourcesfor You/Industry/default.htm. Also, please note the regulation entitled. "Misbranding by reference to premarket notification" (21CFR Part 807.97). For questions regarding the reporting of adverse events under the MDR regulation (21 CFR Part 803), please go to
http://www.fda.gov/MedicalDevices/Safety/ReportaProblem/default.htm for the CDRH's Office of Surveillance and Biometrics/Division of Postmarket Surveillance.
You may obtain other general information on your responsibilities under the Act from the Division of Industry and Consumer Education at its toll-free number (800) 638-2041 or (301) 796-7100 or at its Internet address
http://www.fda.gov/MedicalDevices/ResourcesforYou/Industry/default.htm.
Sincerely,
Michael J. Ryan -S
for Tina Kiang, Ph.D. Acting Director Division of Anesthesiology, General Hospital, Respiratory, Infection Control and Dental Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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Flat 1001 Yuen Long Trading Centre, No. 33 Wang Yip Street West, Yuen Long, HONG KONG Phone: (852) 2761 3211, Facsimile: (852) 2761 3210, Email: jessicamao@premiumplushk.com
#### Section 4 Indications for Use Statement
510(k) Number (if known): K153514
Trade Name: Premium Plus C01/C02 LED Curing Light
Indications for Use: Premium Plus C01/C02 Dental Curing Light is intended for use by trained dental professionals for the purpose of curing dental composites by light.
AND/OR
Prescription Use (Part 21 CFR 801 Subpart D) Over-The-Counter Use (21 CFR 801 Subpart C)
(PLEASE DO NOT WRITE BELOW THIS LINE - CONTINUE ON ANOTHER PAGE IF NEEDED)
Concurrence of CDRH, Office of Device Evaluation (ODE)
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Flat 1001 Yven Long Trading Centre, No. 33 Wang Yip Street West, Yven Long, HONG KONG Phone: (852) 2761 3211, Facsimile: (852) 2761 3210, Email: jessicamao@premiumplushk.com
### Section 5 510(k) Summary [As Required by 21 CFR 807.92]
510(k) Number: K153514
Submitter: Premium Plus International Limited Flat 1001 Yuen Long Trading Centre, No. 33 Wang Yip Street West, Yuen Long, N.T. Hong Kong, China (Establishment registration number: 3006847937)
Contact Person: Jessica Mao QA Engineer Tel: 852-27613211 Fax: 852-27613210 Email: jessicamao@premiumplushk.com
Device Name: Activator, Ultraviolet, For Polymerization Trade Name: Premium Plus C01/C02 LED Curing Light Common Name: Dental Curing Light
Model Type: C01 & C02 (As they have same design requirements, performance specifications, technology, intended use and similar indications, they are summarized into one 510(k) submission, adherence to Section 4 of the guidance document for Bundling Multiple Device or Multiple Indications in a Single Submission )
Device Panel: Dental
Basis for Submission: New Device Regulation Name: Ultraviolet Activator for Polymerization
Device Classification: Class II
Regulation Number: 21 CFR 872.6070
Regulation Description: Ultraviolet activator for polymerization Product Code: EBZ
#### (A)Primary Predicate Device to Premium Plus C01 LED Curing Light:
Trade Name: Ledex WL-070 510(k) Number: K082408 Manufactured by: Dentmate Technology Company, Limited
#### (B) Primary Predicate Device to Premium Plus C02 LED Curing Light:
Trade Name: Coltolux® LED Curing Light 510(k) Number: K040551 Manufactured by: Coltene/Whaledent Incorporated
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Flat 1001 Yven Long Trading Centre, No. 33 Wang Yip Street West, Yven Long, HONG KONG Phone: (852) 2761 3211, Facsimile: (852) 2761 3210, Email: jessicamao@premiumplushk.com
#### (C) Reference Device for Performance Testing to Premium Plus C02 LED Curing Light:
Trade Name: VALO® Cordless 510(k) Number: K110582 Manufactured by: Ultradent Products, Inc.
#### Device Description:
Premium Plus C01/C02 LED Curing Light is classified as an Ultraviolet Activator for Polymerization (21 CFR 872.6070) because it is used for polymerization of dental light cured materials by dental professionals. The device is based on blue LED (light emitting diode) technology. It has three curing modes. Using different modes gives dental professionals the flexibility to polymerize virtually almost all types of composites, boding agents and sealants available in the market.
Premium Plus C01/C02 LED Curing Light consists of a handpiece and a charging station, which is connected via a plug-in transformer to an AC outlet for charging. The handpiece contains high intensity dental blue LED light source and a fibre optic light guide(C01-1) that conduct light to the treatment area on the patients or direct light source head(C02-1). A protective light shield and transformer are accessories provided with Premium Plus C01/C02 LED Curing Light, which support the operation of the device. The protective light shield filters blue light to protect eyes of dental professionals and patients. An FDA cleared barrier sleeves must be used between each patient such as the Pac-Dent Barrier Sleeve.
#### Indications for Use:
Premium Plus C01/C02 LED Curing Light is intended for use by trained dental professionals for the purpose of curing dental composites by light.
#### Technological Characteristics and Substantial Equivalence:
| Device | Ledex WL-070<br>510(k) Number:K082408 | Premium Plus C01 LED<br>Curing Light |
|----------------------|---------------------------------------------------------------------------------------|---------------------------------------|
| Intended Use | Used by trained dental<br>professionals to polymerize dental<br>light cured materials | Same |
| Target Users | Professional Dentists and<br>Hygienists | Same |
| Light Source | LED light | Same |
| Operational<br>Modes | 3 modes: Full, Ramp, Pulse | Same |
| Power Source | 3.7V, 800mAh, Lithium-ion type | 3.7V, 1100 mAh, Lithium -<br>ion type |
| Power Supply | Input: AC100~240V, 50/60Hz<br>Output: DC 5V/2A | Input: AC 100-240V,<br>50/60Hz |
### Table 1: Comparison of the Proposed Device Premium Plus C01 LED Curing Light against the Predicate Device Ledex WL-070
An electronic copy of the submission is being provided which is an exact duplicate of the paper copy. Page 2 of 4 Section 5
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Flat 1001 Yuen Long Trading Centre, No. 33 Wang Yip Street West, Yuen Long, HONG KONG Phone: (852) 2761 3211, Facsimile: (852) 2761 3210, Email: jessicamao@premiumplushk.com
| | | Output: DC 5V/1A<br>(with charging station) |
|---------------------------------------|------------------------------------------------------------------------------|------------------------------------------------------------|
| The Range of<br>Wavelength | 440nm~480nm, peak:460nm | Same |
| Radiant Intensity | 1100 mw/cm²- 1200 mw/cm² | 750 mw/cm²- 1200 mw/cm² |
| Light Guide Rod | Ø8mm Optical fiber sterilization in<br>autoclave | Same |
| Operating<br>Environmental<br>Factors | 10°C~40°C/30%~75%relative<br>humidity/500hPa~1060hPa<br>atmospheric pressure | Same |
| Handpiece Size | Ø2.6cm x 15.6cm | Ø2.7cm x 24cm |
| Weight | 120g | 160g |
| FDA- Recognized<br>Standards | EN60601-1 | IEC 60601-1:2005<br>IEC 60601-1-2:2007<br>ISO 10650-2:2007 |
Premium Plus C01 LED Curing Light and its predicate device Ledex WL-070 have identical intended use, operational principles and performance specifications. They also both transmit visible blue LED light at wavelength known to polymerize the dental resins. The devices are substantially equivalent in intended use, operation, wavelength range, light intensity, and light source.
Table 2: Comparison of the Proposed Device Premium Plus C02 LED Curing Light against the Predicate Device Coltolux® LED Curing Light
| Device | Coltolux® LED Curing Light<br>510(k) Number:K040551 | Premium Plus C02 LED Curing Light |
|---------------------------------|------------------------------------------------------------------------------------|-----------------------------------------------------------------------------|
| Intended Use | Used by trained dental professionals to polymerize dental light cured materials | Same |
| Light Source | LED Light | Same |
| Operational Modes | 1mode: Ready mode | 3 modes: Full, Ramp, Pulse |
| Power Source | Rechargeable battery | 3.7V, 1100 mAh, Lithium - ion type |
| Radiant Intensity | 300 mw/cm² or higher | 750 mw/cm²- 1200 mw/cm² |
| Accessories | Snap on light shields, barrier sleeves, light lenses, goggles, test block, adapter | Protective light shield, caps, head protective rings, adapter |
| Operating Environmental Factors | 10°C~40°C / relative humidity 80% at 25°C | 10°C~40°C / 30%~75% relative humidity / 500hPa~1060hPa atmospheric pressure |
| FDA- Recognized Standards | IEC60601-1-2 | IEC 60601-1<br>IEC 60601-1-2<br>ISO 10650-2:2007 |
An electronic copy of the submission is being provided which is an exact duplicate of the paper copy. Page 3 of 4 Section 5
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Flat 1001 Yuen Long Trading Centre, No. 33 Wang Yip Street West, Yuen Long, HONG KONG Phone: (852) 2761 3211, Facsimile: (852) 2761 3210, Email: jessicamao@premiumplushk.com
Premium Plus C02 LED Curing Light and its primary predicate device Coltolux® LED Curing Light have the same intended use and light source. They both have the similar product appearance and power source, and require the similar operating environmental factors. Furthermore, they both are electrical safety and electromagnetic compatibility in accordance with IEC 60601-1-2.
#### Performance Test:
The following tests were conducted to evaluate the functional performance and safety of Premium Plus C01/C02 LED Curing Light:
- Electrical Safety
- Electromagnetic Compatibility
- Light-emitting diode(LED) lamps
- Depth of Cure ●
The test results confirm that Premium Plus C01/C02 LED Curing Light conforms to the requirements in ISO 60601-1, ISO 60601-1-2 and ISO 10650-2 / ANSI/ADA Specification No. 48-2, LED Curing Lights, and is substantially equivalent for use as a dental curing light.
Two short videos show you everything — or skip straight to the written tutorial if you'd rather read. You can reopen this any time from the Tutorial button in the top bar.
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.
Where do you find a device's intended use without opening the PDF?
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.
4. Device detail page: chat and citations
Click a device name to open its detail page: device facts on the left, a chat window on the right. Ask something like "Describe the training data". The answer carries little citation bubbles — click one to jump to the highlighted passage in the source PDF, so you can verify every AI answer against the document. There's also a Download PDF button for sharing.
How do you verify an AI chat answer on the device detail page?
Click the citation bubbles to jump to the relevant highlight in the source document.
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.
6. Collections
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.
How do you save a set of selected devices for later use?
Select the rows, go to the Collections tab, and create a labeled collection (e.g., "Cobb Angle Project"). You can reload the selection anytime and carry it into the PDF viewer and other tabs that support selections.
7. Product codes and the regulations tree
Click a product code in the results to jump to it in the regulations tree — identification text, sibling product codes, and devices you can open in a PDF viewer on the right. Click a regulation number to see its identification, special controls, and related product codes. You can also search by product code or regulation number at the top of the tree. Always read the special controls if any exist for your device — it broadens your search and sharpens pre-kickoff research.
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.
8. Chart view
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.