K193260 · Vericom Co., Ltd. · EMA · Aug 21, 2020 · Dental
Device Facts
Record ID
K193260
Device Name
U-Cem Premium & MAZIC Cem
Applicant
Vericom Co., Ltd.
Product Code
EMA · Dental
Decision Date
Aug 21, 2020
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 872.3275
Device Class
Class 2
Indications for Use
1. Luting metal crowns, bridge, inlay and including porcelain-fused-to-metal and composite-to-metal varieties 2. Luting resin crowns, bridges, inlays, onlays and veneers 3. Luting metal or non-metal/fiber posts 4. Luting orthodontic appliances 5. Luting porcelain inlays, onlays, crowns and veneers (includes alumina and zirconia)
Device Story
U-Cem Premium and MAZIC Cem are dual-cured, self-adhesive, fluoride-releasing, radiopaque resin cements. Used by dental professionals in clinical settings for cementation of various dental restorations including crowns, bridges, inlays, onlays, veneers, posts, and orthodontic appliances. Available in automix and double dispenser delivery systems; offered in three shades (Clear, Universal, Opaque). Device functions by chemically bonding to tooth structure and restorative materials without requiring a separate bonding agent. Healthcare providers apply the paste to the restoration, which then sets to secure the prosthesis. Faster setting time compared to predicate; provides mechanical retention and esthetic options for dental procedures.
Clinical Evidence
Bench testing only. Performance evaluated per ISO 4049 (polymer-based restorative materials), ISO 9917-1 (water-based cements), and ISO/TS 11405 (adhesion to tooth structure). Biocompatibility testing conducted per ISO 10993 series (parts 1, 3, 5, 10, 11). Results demonstrate physical properties (compressive strength 236.35 MPa, flexural strength 135.87 MPa, film thickness 11 μm) and shear bond strengths comparable or superior to the predicate device. No clinical data provided.
Technological Characteristics
Dual-cured, methacrylate-based resin cement with amorphous silica filler. Radiopaque. Available in automix and double dispenser delivery systems. Conforms to ISO 4049. Biocompatible per ISO 10993. Storage at 2-8°C.
Indications for Use
Indicated for luting metal, resin, or porcelain crowns, bridges, inlays, onlays, veneers, metal/non-metal/fiber posts, and orthodontic appliances in patients requiring dental cementation.
Regulatory Classification
Identification
Zinc oxide-eugenol is a device composed of zinc oxide-eugenol intended to serve as a temporary tooth filling or as a base cement to affix a temporary tooth filling, to affix dental devices such as crowns or bridges, or to be applied to a tooth to protect the tooth pulp. Dental cement other than zinc oxide-eugenol is a device composed of various materials other than zinc oxide-eugenol intended to serve as a temporary tooth filling or as a base cement to affix a temporary tooth filling, to affix dental devices such as crowns or bridges, or to be applied to a tooth to protect the tooth pulp.
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August 21, 2020
Vericom Co., Ltd. % Priscilla Chung Regulatory Affairs Consultant LK Consulting Group USA, Inc 1150 Roosevelt, STE 200 Irvine, California 92620
Re: K193260
Trade/Device Name: U-Cem Premium & MAZIC Cem Regulation Number: 21 CFR 872.3275 Regulation Name: Dental Cement Regulatory Class: Class II Product Code: EMA Dated: July 21, 2020 Received: July 24, 2020
Dear Priscilla Chung:
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.
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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 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 medical devices and radiation-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.
for Srinivas "Nandu" Nandkumar, Ph.D. Director DHT1B: Division of Dental Devices OHT1: Office of Ophthalmic. Anesthesia. Respiratory, ENT and Dental Devices Office of Product Evaluation and Ouality Center for Devices and Radiological Health
Enclosure
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# Indications for Use
510(k) Number (if known) K193260
Device Name
U-Cem™ Premium & MAZIC® Cem
#### Indications for Use (Describe)
- 1. Luting metal crowns, bridge, inlay and including porcelain-fused-to-metal and composite-to-metal varieties
- 2. Luting resin crowns, bridges, inlays, onlays and veneers
- 3. Luting metal or non-metal/fiber posts
- 4. Luting orthodontic appliances
- 5. Luting porcelain inlays, onlays, crowns and veneers (includes alumina and zirconia)
| Type of Use (Select one or both, as applicable) | |
|------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------|
| <span style="text-decoration: overline;">☑</span> Prescription Use (Part 21 CFR 801 Subpart D) | <span style="text-decoration: overline;">☐</span> Over-The-Counter Use (21 CFR 801 Subpart C) |
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# 510(k) Summary (K193260)
This summary of 510(k) is being submitted in accordance with requirements of 21 CFR Part 807.92.
Date: July 16, 2020
# 1. 510K Applicant / Submitter:
Vericom Co., Ltd. 48.Toegyegongdan 1-Gil, Chuncheon-Si, Gangwon-Do, 200-944, Republic of Korea Tel: +82-31-441-2881 Fax: +82-31-441-2883
## 2. Submission Contact Person
LK Consulting Group USA, Inc. 1150 Roosevelt, STE 200, Irvine CA 92620 Priscilla Juhee Chung Phone: 714.202.5789 Fax: 714-409-3357 Email: juhee.c(@lkconsultinggroup.com
## 3. Device
- Proprietary Name: U-Cem™ Premium & MAZIC® Cem .
- Common Name: Luting Cement .
- Classification: Dental Cement, Class II (21 CFR 872.3275) .
- . Product Code: EMA
# 4. Predicate Device
BisCem (K082449) by Bisco, Inc.
# 5. Description:
The U-Cem™ Premium and the MAZIC® Cem are dual-cured self-adhesive resin cement. The U-Cem™ Premium and the MAZIC® Cem are the same product yet with different label design for different volume packages as shown below. The brand name, MAZIC® Cem, is specifically for 8.5g.
It is fluoride-releasing paste type, and has radiopaque. U-Cem™ Premium is available in both Automix and Double Dispenser types, and offers three different shades: Clear, Universal, and Opaque for esthetics.
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It is used for cementation of ceramics, metals or composite inlays, onlays, crowns, bridges, posts and screws.
# 8. Indications for Use
1. Luting metal crowns, bridge, inlay and including porcelain-fused-to-metal and compositeto-metal varieties
- 2. Luting resin crowns, bridges, inlays, onlays and veneers
- 3. Luting metal or non-metal/fiber posts
- 4. Luting orthodontic appliances
- 5. Luting porcelain inlays, onlays, crowns and veneers (includes alumina and zirconia)
# 9. Substantial Equivalence Discussion:
The U-Cem™ Premium/ the MAZIC® Cem has the same intended use and the principle of operation, and also has similar physical properties demonstrating comparable performance specifications to the predicate device: BisCem (K082449) by Bisco, Inc.
The Indications for Use statement of the subject device is similar to that of the predicate device, but it is described in a slightly different way. However, fundamentally the predicate device's indications cover the subject device's claims.
One of the differences is the subject device has an additional delivery system which is the Double Dispenser type. This Double Dispenser has the same mixing ration as the auto mix type so this difference does not raise a question in substantial equivalence.
Another difference is that the subject device has three shades, whereas, the BisCem has two shades, and some raw materials used might be different. However, bench performance and biocompatibility testing performed demonstrates that these differences would not raise a new question in substantial equivalence. For the tests that were performed according to the standards, both devices satisfied the standards' requirements. For the testing that does not have an international standard, the test results of the subject device were substantially equivalent to the predicate device.
The Physical and Performance properties are also very similar except setting time. The subject device shows faster setting time which is 2 minutes and 12 seconds. Both devices meet the ISO 4049 requirement for the setting time, and it does not a raise an issue to support substantial equivalence.
Based on the information provided herein, it is concluded that the U-Cem™ Premium/ the MAZIC® Cem is substantially equivalent to the predicate device.
| | Subject Device | Predicate Device |
|--------------|-------------------|------------------|
| Device Name | U-Cem™ Premium | BisCem |
| 510k # | K193260 | K082449 |
| Manufacturer | VERICOM CO., LTD. | Bisco, Inc. |
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| Indications for use | | 1. Luting metal crowns, bridge, inlay and including porcelain-fused-to-metal and composite-to-metal varieties<br>2. Luting resin crowns, bridges, inlays, onlays and veneers<br>3. Luting metal or non-metal/fiber posts<br>4. Luting orthodontic appliances<br>5. Luting porcelain inlays, onlays, crowns and veneers (includes alumina and zirconia) | 1. Luting metal crowns, bridge, inlay and including porcelain-fused-to-metal and composite-to-metal varieties<br>2. Luting resin crowns, bridges, inlays, onlays and veneers<br>3. Luting metal or non-metal/fiber posts<br>4. Luting orthodontic appliances<br>5. Luting porcelain inlays, onlays, crowns and veneers (includes alumina and zirconia) | |
|-----------------------------------------|--------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------|
| Principle of operation | | Dual cured | Dual cured | |
| Physical &<br>Performance<br>properties | Working Time<br>(at 60sec. after<br>completion of<br>mixing) | Physically homogeneous and forming the thin layer | Physically homogeneous and forming the thin layer | |
| | Setting time | 2 m 12s | 9 m 08 s | |
| | Compressive strength | $236.35MPa$ | $189.15MPa$ | |
| | Flexural strength | $135.87MPa$ | $101.93 MPa$ | |
| | Film thickness | $11 μm$ | $23 μm$ | |
| | Shear<br>bond<br>strength | Composite -Dentin | $12.85MPa$ | $7.68MPa$ |
| | | Composite -Enamel | $19.16MPa$ | $16.32MPa$ |
| | | Glass Ceramic -Litium disilicate | $6.21MPa$ | $5.49MPa$ |
| | | Ceramic Aluminum oxide | $7.28MPa$ | $4.27MPa$ |
| | | Metal | $12.70MPa$ | $4.38MPa$ |
| | | Zirconia | $9.05MPa$ | $5.12MPa$ |
| | Fluoride release | | $2.42 ppm$ | $10.02 ppm$ |
| | Radio-opacity | | 1.45 | None |
| | Solubility | | $0.87 µg/mm²$ | $1.53µg/mm²$ |
| | Polymerization shrinkage | | 4.38% | 4.18% |
| Chemical<br>Composition | Filler | | Amorphous silica | Amorphous silica |
| | Resin composition | | Methacrylate based | Methacrylate based |
| | Method of application<br>Ions released | | Bonding agent not required<br>Fluoride | Bonding agent not required<br>Fluoride |
| Standard Conformed | | ISO 4049 | ISO 4049 | |
| Biocompatibility | | Yes | Yes | |
| Use | | Prescription / Hospital | Prescription / Hospital | |
| Delivery system | | Dual syringe(Base:Catalyst=1:1), Automix and Double Dispenser type | Dual-syringe(Base:Catalyst=1:1), Automix type | |
| Storage condition | | 2~8°C<br>(at refrigerator temperature) | 2~8°C<br>(at refrigerator temperature) | |
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| Physical<br>properties | Shade | - Clear<br>- Universal<br>- Opaque | - Translucent<br>- Opaque |
|------------------------|-------|------------------------------------|---------------------------|
|------------------------|-------|------------------------------------|---------------------------|
#### 10. Performance Tests (Non-clinical)
- . Performance Test:
- ISO 4049 Fourth edition 2009-10-01 Dentistry Polymer-based restorative materials
- ISO 9917-1 Second edition 2007-10-01 Dentistry - Water-based cements - Part 1: Powder/liquid acid-base cements, Annex D.
ISO /TS 11405 Third edition 2015-02-01 Dentistry - Testing of adhesion to tooth i structure
- Biocompatibility Tests ●
- ISO 10993-1 Fourth edition 2009-10-15, biological evaluation of medical devices part 1: evaluation and testing within a risk management process [including: technical corrigendum 1 (2010)]. (Biocompatibility)
- ISO 10993-3 Third edition 2014-10-1 Biological evaluation of medical devices Part 3: Tests for genotoxicity, carcinogenicity and reproductive toxicity
- ISO 10993-5 Third edition 2009-06-01 Biological evaluation of medical devices Part 5: Tests for in vitro cytotoxicity
- ISO 10993-10 Third Edition 2010-08-01 Biological evaluation of medical devices -Part 10: Tests for irritation and skin sensitization
- ISO 10993-11 Second edition 2006-08-15 Biological evaluation of medical devices -Part 11: Tests for systemic toxicity
- Shelf Life Test Performance Tests in accordance with ISO 4049 and ISO 9917-1 .
The test results of non-clinical tests performed on the subject device supported that it is substantially equivalent to the predicate devices despite the differences.
## 11. Conclusions:
Based on the information provided in this premarket notification, Vericom Co., Ltd. concludes that the U-Cem™ Premium & MAZIC® Cem is substantially equivalent to the predicate device as described herein in.
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.