K172118 · Kimberly-Clark Corporation · HEB · Oct 11, 2017 · Obstetrics/Gynecology
Device Facts
Record ID
K172118
Device Name
U by Kotex Click Unscented Menstrual Tampons
Applicant
Kimberly-Clark Corporation
Product Code
HEB · Obstetrics/Gynecology
Decision Date
Oct 11, 2017
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 884.5470
Device Class
Class 2
Indications for Use
The U by Kotex® Click® Unscented Menstrual Tampons are inserted into the vagina to absorb menstrual fluid.
Device Story
Device is a conventional unscented menstrual tampon; consists of absorbent rayon fiber pledget, rayon-polyester withdrawal string, and non-woven polyester/polyethylene cover. Features a three-piece plastic applicator (plunger, telescope, barrel) with rounded tip. Used by patients for menstrual fluid absorption. Device is manually inserted into the vagina; functions via physical absorption of fluid. Benefits include effective menstrual hygiene management. No electronic or software components.
Clinical Evidence
Bench testing only. Biocompatibility testing per ISO 10993-1:2009 (cytotoxicity, sensitization, irritation, acute systemic toxicity). Performance testing per FDA guidance for menstrual tampons: Syngyna absorbency testing (21 CFR 801.430), chemical residue analysis (TCDD/TCDF/pesticides), mechanical testing (string strength, fiber shedding, integrity), and microbiology testing (bioburden, vaginal microflora impact, TSST-1 production, S. aureus growth).
Technological Characteristics
Materials: rayon fibers, rayon-polyester string, non-woven polyester/polyethylene cover. Design: eight-groove bullet-shaped pledget, three-piece plastic applicator. Standards: ISO 10993-1:2009 (biocompatibility), USP <61>/<62> (microbiology), 21 CFR 801.430 (absorbency). No energy source, software, or connectivity.
Indications for Use
Indicated for use by individuals requiring vaginal absorption of menstrual fluid.
Regulatory Classification
Identification
An unscented menstrual tampon is a device that is a plug made of cellulosic or synthetic material that is inserted into the vagina and used to absorb menstrual or other vaginal discharge. This generic type of device does not include menstrual tampons treated with scent (i.e., fragrance materials) or those with added antimicrobial agents or other drugs.
Predicate Devices
U by Kotex® Click® Unscented Menstrual Tampons (K113036)
Submission Summary (Full Text)
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Image /page/0/Picture/0 description: The image contains the logo of the U.S. Food and Drug Administration (FDA). On the left is the Department of Health & Human Services logo. To the right of that is the FDA logo, which is a blue square with the letters "FDA" in white. To the right of the blue square is the text "U.S. FOOD & DRUG ADMINISTRATION" in blue.
October 11, 2017
Kimberly-Clark Corporation Lori J. Barr Kimberly-Clark Corp. 2001 Marathon Ave. Neenah, WI 54956
Re: K172118
Trade/Device Name: U by Kotex® Click® Unscented Menstrual Tampons Regulation Number: 21 CFR§ 884.5470 Regulation Name: Unscented Menstrual Tampon Regulatory Class: II Product Code: HEB Dated: July 10, 2017 Received: July 13, 2017
Dear Lori J. Barr:
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.
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); 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 (DICE) 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. 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 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 (DICE) 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,
Benjamin R. Fisher, Ph.D. Director Division of Reproductive, Gastro-Renal, and Urological Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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Image /page/2/Picture/0 description: The image contains the logo of the U.S. Food and Drug Administration (FDA). On the left is the Department of Health & Human Services logo. To the right of that is the FDA logo, which is a blue square with the letters "FDA" in white. To the right of the blue square is the text "U.S. FOOD & DRUG ADMINISTRATION" in blue.
October 11, 2017
Kimberly-Clark Corporation Lori J. Barr Kimberly-Clark Corp. 2001 Marathon Ave. Neenah, WI 54956
Re: K172118
Trade/Device Name: U by Kotex® Click® Unscented Menstrual Tampons Regulation Number: 21 CFR§ 884.5470 Regulation Name: Unscented Menstrual Tampon Regulatory Class: II Product Code: HEB Dated: July 10, 2017 Received: July 13, 2017
Dear Lori J. Barr:
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.
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.
{3}------------------------------------------------
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); 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 (DICE) 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. 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 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 (DICE) 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,
Benjamin R. Fisher, Ph.D. Director Division of Reproductive, Gastro-Renal, and Urological Devices Office of Device Evaluation Center for Devices and Radiological Health
Enclosure
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Image /page/4/Picture/0 description: The image shows the logo for Kimberly-Clark Corporation. The logo consists of a stylized "K" symbol on the left, followed by the text "Kimberly-Clark Corporation" in a bold, sans-serif font. The text is black, and the logo is simple and modern.
# 510(k) Summary (K172118)
#### l. Submitter
| Submitter/Address: | Kimberly-Clark Corporation<br>2100 Winchester Road<br>Neenah, WI 54956 |
|---------------------------------------------|------------------------------------------------------------------------|
| Contact Person:<br>Phone:<br>Fax:<br>Email: | Lori J. Barr<br>920-721-4570<br>920.380.6467<br>lori.barr@kcc.com |
- II. Date Prepared:
#### .............................................................................................................................................................................. General Information
| Device Name: | U by Kotex® Click® Unscented Menstrual Tampons |
|----------------------|------------------------------------------------|
| Common Name: | Unscented Menstrual Tampon |
| Classification Name: | Unscented Menstrual Tampon (21 CFR 884.5470) |
| Product Code: | HEB (tampon, menstrual, unscented) |
| Regulatory Class: | II |
October 10, 2017
#### IV. Predicate Device:
U by Kotex® Click® Unscented Menstrual Tampons (K113036) manufactured by Kimberly-Clark Corporation. This predicate device has not been subject to any design related recalls.
#### V. Description of the Device:
The subject devices are conventional unscented menstrual tampons consisting of an absorbent pledget, an overwrap, a withdrawal string, and a plastic applicator. The absorbent pledget consists of a ribbon of rayon fibers. A rayon-polyester blend withdrawal string is placed on the ribbon and the ribbon is radially wound, then compressed into a traditional eight-groove bulletshaped pledget, overwrapped with a non-woven cover material. The tampon component is inserted into a three-piece plastic applicator consisting of an inner tube (plunger), a clear middle telescopic tube (telescope), and an outer insertion tube (barrel) formed with a closed, rounded tip. Each tampon component with applicator is wrapped in an individual plastic film wrapper, and packaged in a sealed multi-unit container for retail sale. Tampons are available in Regular, Super and Super Plus absorbencies in various counts.
#### VI. Indications for Use
The U by Kotex® Click® Unscented Menstrual Tampons are inserted into the vagina to absorb menstrual fluid.
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Image /page/5/Picture/1 description: The image shows the logo for Kimberly-Clark Corporation. The logo consists of a stylized "KC" symbol on the left, followed by the company name in a combination of bold and regular fonts. The word "Kimberly-Clark" is in bold, while "Corporation" is in a lighter, regular font.
### Comparison of Intended Use and Technological Characteristics with the Predicate Device VII.
| Criteria | K172118 (subject device) | K113036 (predicate device) |
|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Indications for Use | Same as predicate | Kimberly-Clark U by Kotex Click is an unscented<br>menstrual tampon inserted into the vagina to absorb<br>menstrual fluid. |
| Design - absorbent<br>pledget | Same as predicate | The absorbent pledget consists of a ribbon of rayon<br>fibers. A rayon-polyester blend withdrawal string is<br>placed on the ribbon and the ribbon is radially<br>wound, then compressed into a traditional eight-<br>groove bullet-shaped pledget, overwrapped with a<br>non-woven cover material.<br><br>The pledget provides three absorbencies: regular,<br>super, and super plus. |
| Design - Applicator | Same as predicate | The three-piece plastic applicator consisting of an<br>inner tube (plunger), a clear middle telescopic tube<br>(telescope), and an outer insertion tube (barrel)<br>formed with a closed, rounded tip. |
| Material | The non-woven polyester/polyethylene covering the pledget used in the subject<br>devices are from different suppliers. There are no other changes in materials<br>used in the subject and predicate devices. | |
| The subject and predicate devices have the same indication – an unscented menstrual tampon inserted<br>into the vagina to absorb menstrual fluid. | | |
| The subject and predicate devices have the same design. The non-woven polyester/polyethylene<br>covering the pledget used in the subject devices are from different suppliers. This difference in | | |
technological characteristics does not raise different questions for safety and effectiveness.
## VIII. Summary of Non-Clinical Performance Testing:
The following studies have been performed to support substantial equivalence to the predicate device:
- . Biocompatibility testing in accordance with the ISO 10993-1:2009. The testing demonstrated that the pledget is non-cytotoxic, non-sensitizing, non-irritating, and non-toxic.
- * Cytotoxicity testing per 10993-5:2009
- * Guinea Pig Maximization Sensitization testing per ISO 10993-10:2010
- * Vaginal Irritation testing per ISO 10993-10:2010
- Acute Systemic Toxicity testing per ISO 10993-11:2006 *
- Performance testing in accordance with the FDA Guidance, "Menstrual Tampons and Pads: Information for Premarket Notification Submissions" issued July 27, 2005. The testing confirmed that the design output meets the design inputs and specifications for the device. The testing criteria are as follows:
- * Syngyna (absorbency range) – The subject tampons met the requirements of 21 CFR §801.430(f)(2) for each absorbency level.
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Image /page/6/Picture/0 description: The image shows the logo for Kimberly-Clark Corporation. The logo consists of a stylized "KC" symbol enclosed in a circle, followed by the company name "Kimberly-Clark" in bold, and "Corporation" in a lighter font. The logo is simple and professional, and it is easily recognizable.
- * Chemical residues - There were no detectable 2,3,7,8- tetrachlorodibenzo-p-dioxin (TCDD); 2,3,7,8-tetrachlorofuran dioxin (TCDF); or any pesticide and herbicide residues
- Mechanical performance The subject tampons met the following design * specifications:
- String strength: ≥ 10 lb force
- Fiber shedding: ≤2 mg/tampon
- Tampon integrity: ≥20 daN dry and ≥15 daN wet
- * Microbiology testing - The subject tampons passed the following tests:
- Bioburden: Total Aerobic Microbial Count (TAMC) ≤200 cfu/g and Total Yeast/Mold Count (TYMC) ≤20 cfu/q per USP <61>; Absence of pathogenic orqanisms (S. aureus; E. coli; P. aeruginosa; Salmonella species; C. albicans; and C. sakazakii) per USP <62>
- Vaginal microflora: The subject tampons did not alter growth of normal vaginal microflora, increase the production of Toxic Shock Syndrome Toxin-1 (TSST-1), or enhance the growth of S. aureus.
#### XI. Conclusion:
The subject and predicate devices have the same intended use. There is a difference in the supplier for the material used in the subject device. However, this difference in technological characteristics does not raise different questions of safety or effectiveness. The performance data demonstrate that the subject device is substantially equivalent to the predicate device.
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.