K221643 · Shenzhen Desida Technology Co., Ltd. · OHT · Oct 21, 2022 · General, Plastic Surgery
Device Facts
Record ID
K221643
Device Name
Hair Removal Device (Model: IPL-D26, IPL-D19)
Applicant
Shenzhen Desida Technology Co., Ltd.
Product Code
OHT · General, Plastic Surgery
Decision Date
Oct 21, 2022
Decision
SESE
Submission Type
Traditional
Regulation
21 CFR 878.4810
Device Class
Class 2
Attributes
Therapeutic
Indications for Use
The Hair Removal Devices (models IPL-D26 and IPL-D19) are over the counter devices intended for the removal of unwanted hair. The devices are intended for permanent reduction in hair regrowth, defined as a long-term, stable reduction in the number of hairs re-growing when measured at 6, 9, and 12 months after the completion of treatment regimen.
Device Story
Pulsed light hair removal device (models IPL-D26, IPL-D19) utilizing selective photothermolysis to disable hair growth. Device consists of handheld applicator and external power supply. Input: optical energy from xenon arc flashlamp. Safety features: integrated skin color sensor (prevents emission on inappropriate skin tones) and skin proximity sensor (prevents emission unless in full contact with skin). Operated by user in home environment. Output: pulsed light flashes (3 cm² spot size). Effect: long-term, stable reduction in hair regrowth. Benefit: permanent hair reduction.
Clinical Evidence
Bench testing only. No clinical data provided. Testing included biocompatibility (ISO 10993-1: cytotoxicity, sensitization, irritation), electrical safety (IEC 60601-1, IEC 60601-1-11, IEC 60601-2-57, IEC 60601-2-83, IEC 62471), EMC (IEC 60601-1-2), and usability (IEC 60601-1-6).
Technological Characteristics
Xenon arc flashlamp energy source; 500-1200nm wavelength; 2-4ms pulse duration; 1.8-4.9 J/cm² energy density; 3 cm² treatment window. Features skin color and proximity sensors. Handheld form factor. Compliance with IEC 60601 series and IEC 62471. Software level of concern: Moderate.
Indications for Use
Indicated for removal of unwanted hair and permanent reduction in hair regrowth in adults. Intended for over-the-counter use.
Regulatory Classification
Identification
(1) A carbon dioxide laser for use in general surgery and in dermatology is a laser device intended to cut, destroy, or remove tissue by light energy emitted by carbon dioxide.(2) An argon laser for use in dermatology is a laser device intended to destroy or coagulate tissue by light energy emitted by argon.
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October 21, 2022
Shenzhen Desida Technology Co., Ltd. % Amos Zou RA Engineer Shenzhen CT Bio-Tech Co., Ltd. Room 408, Comprehensive Building, Building 6, Xusheng Building, Xixiang Street, Baoan District Shenzhen, Guangdong 518102 China
Re: K221643
Trade/Device Name: Hair Removal Device (Model: IPL-D26, IPL-D19) Regulation Number: 21 CFR 878.4810 Regulation Name: Laser Surgical Instrument For Use In General And Plastic Surgery And In Dermatology Regulatory Class: Class II Product Code: OHT Dated: May 30, 2022 Received: June 6, 2022
Dear Amos Zou:
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,
Jianting Wang Acting Assistant Director DHT4A: Division of General Surgery Devices OHT4: Office of Surgical and Infection Control Devices Office of Product Evaluation and Quality Center for Devices and Radiological Health
Enclosure
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# Indications for Use
510(k) Number (if known) K221643
Device Name Hair Removal Device (Model:IPL-D26,IPL-D19)
## Indications for Use (Describe)
The Hair Removal Devices (models IPL-D26 and IPL-D19) are over the counter devices intended for the removal of unwanted hair. The devices are intended for permanent reduction in hair regrowth, defined as a long-term, stable reduction in the number of hairs re-growing when measured at 6, 9, and 12 months after the completion of treatment regimen.
| Type of Use (Select one or both, as applicable) | |
|-------------------------------------------------|--|
|-------------------------------------------------|--|
Prescription Use (Part 21 CFR 801 Subpart D)
X Over-The-Counter Use (21 CFR 801 Subpart C)
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Department of Health and Human Services Centre of Device and Radiological Health Office of Device Evaluation Traditional 510(k) section
# 510(K) SUMMARY OF SAFETY AND EFFECTIVENESS INFORMATION
# as required by section 21 CFR 807.92
#### 1. Submitter of 510(K):
# Sponsor:
| Company Name: | Shenzhen Desida Technology Co., Ltd. |
|-------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------|
| Address: | 5F, Building A, Sanmin Industrial Zone, Shilongzai, Shuitian Community, Shiyan<br>Street, Baoan District, Shenzhen City, Guangdong Province, China. |
| Contact person: | Mr.Gong Yong |
| TEL: | +86-755-28227189/13689585641 |
| FAX: | +86 -755-28227189 |
| E-mail: | 184056776@qq.com<br>40888122@qq.com |
| Date of Prepared: | May 30,2022 |
# Application Correspondent:
| Company Name: | Shenzhen CT Bio-Tech co., Ltd |
|-------------------|-------------------------------------------------------------------------------------------------------------------------------|
| Address: | Room 408,Comprehensive Building,Building 6,Xusheng Building,Xixiang<br>street,Baoan District,Shenzhen,,Guangdong.518126,China |
| Contact person: | Amos Zou |
| TEL: | +86-15015249549 |
| E-mail: | amos.zou@139.com |
| Date of Prepared: | May 30, 2022 |
#### 2. Proposed Device and code:
| Device Trade Name: | Hair Removal Device(Model:IPL-D26,IPL-D19) |
|-------------------------------|--------------------------------------------|
| Regulation Medical Specialty: | General & Plastic Surgery |
| Product Code: | OHT |
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| Device classification Name: | Light Based Over-The-Counter Hair Removal |
|-----------------------------|-----------------------------------------------------------------------------------------|
| Regulation number | 21 CFR 878.4810 |
| Regulation Description | Laser surgical instrument for use in general and plastic surgery and in<br>dermatology. |
| Device Class | II |
| Sterilization facility | Not applicable |
| Type: | Traditional |
#### 3. Predicate Device:
| 510(K) | Trade or Proprietary or Model Name | Manufacturer |
|---------|--------------------------------------------|---------------|
| K160968 | Ipulse Smoothskin Gold Hair Removal Device | Cyden Limited |
#### Description of Proposed Device: 4.
The Hair Removal Devices (Model:IPL-D26,IPL-D19) are pulsed light hair removal devices. The IPL-D26 and IPL-D19 models use the same components and have the same features except for their color. The IPL-D26 is white and IPLD19 is red. The device uses light pulses to produce hair removal, and the effect of the device is based on the theory of selective photothermolysis in which optical energy is used to disable hair growth. The IPL-D26 and IPL-D19 devices are each composed of a hand held applicator and an external power supply. Each applicator contains a xenon lamp, a skin color sensor and a skin proximity sensor. The xenon lamp emits the pulsed light flashes to produce hair removal. The skin color sensor is to ensure that the light will be emitted only to skin color appropriate for the device. The contact sensor is to ensure that the light pulses will not be emitted unless the applicator in full contact with the skin. The spot size (treatment area) in the Hair Removal Device devices is 3 cm²
#### 5. Indications for Use
The Hair Removal Devices (models IPL-D26 and IPL-D19) are over the counter devices intended for the removal of unwanted hair. The devices are intended for permanent reduction in hair regrowth, defined as a long -term, stable reduction in the number of hairs re-growing when measured at 6, 9, and 12 months after the completion of treatment regimen.
#### 6. Device Comparison Table
The following table compares the device to the predicate device with basic technological characteristics.
| | Subject Device 1 | Predicate Device | Remark |
|--------------------------|------------------------------------------------|-----------------------------------------------|---------|
| 510(k) Number | K221643 | K160968 | -- |
| Device Name and<br>Model | Hair Removal Device<br>(Model:IPL-D26,IPL-D19) | Ipulse Smoothskin Gold Hair<br>Removal Device | -- |
| Manufacturer | Shenzhen Desida Technology Co., Ltd. | Cyden Limited | -- |
| Enerty Medium | Xenon Arc Flashlamp | Xenon Arc Flashlamp | same |
| Wavelength<br>Range | 500nm-1200nm | 510-1100nm | Similar |
| Pulse Duration | 2-4 milliseconds | 2ms to 10ms | Similar |
| Energy Density | 1.8-4.9 J/cm² | 3-6J/cm² | Similar |
| Treatment<br>window | 3cm² (3cm by 1cm) | 3cm² (3cm by 1cm) | Same |
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| Delivery Device<br>Pulsing Control | Direct Illumination to Tissue<br>Finger switch | Direct Illumination to Tissue<br>Finger switch | Same<br>Same |
|------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|--------------|
| Skin Tone Sensor | Optical Measurement<br>Integral to device.<br>Continuous measurement. | Optical Measurement<br>Integral to device.<br>Continuous measurement. | Same |
| Indications for<br>Use | The Hair Removal Devices (models<br>IPL-D26 and IPL-D19) are over the<br>counter devices intended for the<br>removal of unwanted hair. The devices<br>are intended for permanent reduction in<br>hair regrowth, defined as a long-term,<br>stable reduction in the number of hairs<br>re-growing when measured at 6, 9, and<br>12 months after the completion of<br>treatment regimen. | The iPulse SmoothSkin Gold Hair<br>Removal System is indicated for the<br>removal of unwanted hair. The iPulse<br>SmoothSkin Gold is also indicated for<br>the permanent reduction in hair<br>regrowth, defined as the long-term,<br>stable reduction in the number of<br>hairs regrowing when measured at 6,<br>9 and 12 months after the completion<br>of a treatment regime. | Same |
| Use Environment | Over-the-counter | Over-the-counter | Same |
# 7. PERFORMANCE DATA
The testing for Hair Removal Device included performance, software, electrical safety, EMC, biocompatibility and bench. Hair Removal Device passed all testing in support of the substantial equivalence determination:
# 7.1. Biocompatibility testing
The biocompatibility evaluation for the Hair Removal Devicewas conducted in accordance with International Standard ISO 10993-1 "Biological Evaluation of Medical Devices – Part 1: Evaluation and Testing Within a Risk Management Process." As dictated by the application of contact with the intact skin, the enclosure of testing included the following tests:
- Cytotoxicity
- Sensitization
- Irritation
#### 7.2. Electrical safety and electromagnetic compatibility
Electrical safety, performance and EMC testing were conducted on the Hair Removal Device. The device with compliance with the IEC 60601-1, IEC 60601-1-11, IEC 60601-2-57,IEC 60601-2-83 and IEC 62471 standards for safety and the IEC 60601-1-2 standard for EMC.
#### 7.3. 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." The software for this device was considered as a "Moderate" level of concern.
# 7.4 Usability
Usability testing has been performed to, and passed, the following standards:
● IEC 60601-1-6 Medical electrical equipment –Part 1-6: General requirements for safety – Collateral standard: Usability
#### 8. Conclusions:
The proposed IPL Hair Removal Device models IPL-D26 and IPL-D19 in this 510(k) use the same IPL technology that is used in the K160968 predicate device and the proposed device models are for the same intended use as the predicate device. Differences between the proposed device models and predicate device do not raise new types of questions regarding safety and effectiveness, and performance testing supports that
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the proposed device can be used safely and effectively for the proposed indications for use. The proposed IPL Hair Removal Device models IPL-D26 and IPL-D19 are considered to be substantially equivalent to the K160968 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.