Infrared Heat (Model: E0221)

K223893 · Light Tree Ventures Europe B.V. · OHS · May 16, 2023 · General, Plastic Surgery

Device Facts

• Record ID: K223893
• Device Name: Infrared Heat (Model: E0221)
• Applicant: Light Tree Ventures Europe B.V.
• Product Code: OHS · General, Plastic Surgery
• Decision Date: May 16, 2023
• Decision: SESE
• Submission Type: Traditional
• Regulation: 21 CFR 878.4810
• Device Class: Class 2
• Attributes: Therapeutic

Intended Use

The Infrared Heat (Model: E0221) is intended to emit energy in the red and infrared spectrum for use in the treatment of full face wrinkles.

Device Story

Infrared Heat (Model: E0221) is an over-the-counter LED device for treating full face wrinkles. Device consists of a pad, adjustable strap, USB charging cord, and goggles. Emits red (630nm) and infrared (830nm) light via 60 total LEDs (30 per wavelength). User wears pad on face; device operates via timer-controlled software with automatic 10-minute shut-off. Powered by 3.7V lithium battery. Intended for home use by patients. Output energy (30 mW/cm²) and dose (18J/cm²) are designed to stimulate skin; safety is managed by adherence to photobiological and electrical safety standards.

Clinical Evidence

No clinical data. Substantial equivalence supported by bench testing, including electrical safety (IEC 60601-1), electromagnetic compatibility (IEC 60601-1-2), photobiological safety (IEC 62471), and biocompatibility (ISO 10993-5, -10, -23).

Technological Characteristics

LED-based light therapy device. Wavelengths: 630nm and 830nm (+/- 20nm). Power: 3.7V 1800mAh lithium battery. Output: 30 mW/cm², 18J/cm². Standards: IEC 60601-1, IEC 60601-2-57, IEC 60601-1-11, IEC 62471, IEC 62133-2. Biocompatibility: ISO 10993-5, -10, -23. Software: Moderate level of concern.

Indications for Use

Indicated for the treatment of full face wrinkles in adult patients. 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.

Predicate Devices

• BioPhotas Celluma3 (K171323)
• Opera Lebody (K201107)

Submission Summary (Full Text)

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May 16, 2023

Light Tree Ventures Europe B.V. Alain Dijkstra Manager Laan van Ypenburg 108, 2497 GC, The Hague, The Netherlands Hague, Netherlands

Re: K223893

Trade/Device Name: Infrared Heat (Model: E0221) 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: OHS Dated: February 15, 2023 Received: February 15, 2023

Dear Alain Dijkstra:

We have reviewed your Section 510(k) premarket notification of intent to market the device referenced above and have determined the device is substantially equivalent (for the indications for use stated in the enclosure) to legally marketed predicate devices marketed in interstate commerce prior to May 28, 1976, the enactment date of the Medical Device Amendments, or to devices that have been reclassified in accordance with the provisions of the Federal Food, Drug, and Cosmetic Act (Act) that do not require approval of a premarket approval application (PMA). You may, therefore, market the device, subject to the general controls provisions of the Act. Although this letter refers to your product as a device, please be aware that some cleared products may instead be combination products. The 510(k) Premarket Notification Database located at https://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfpmn/pmn.cfm identifies combination product submissions. The general controls provisions of the Act include requirements for annual registration, listing of devices, good manufacturing practice, labeling, and prohibitions against misbranding and adulteration. Please note: CDRH does not evaluate information related to contract liability warranties. We remind you, however, that device labeling must be truthful and not misleading.

If your device is classified (see above) into either class II (Special Controls) or class III (PMA), it may be subject to additional controls. Existing major regulations affecting your device can be found in the Code of Federal Regulations, Title 21, Parts 800 to 898. In addition, FDA may publish further announcements concerning your device in the Federal Register.

Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal

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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 ([e-mail]) or phone [phone] or 301-796-7100).

Sincerely,

# Jianting Wang -S

Jianting Wang Acting Assistant Director DHT4A: Division of General Surgery Devices OHT4: Office of Surgical and Infection Control 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) K223893

Device Name Infrared Heat, model: E0221

#### Indications for Use (Describe)

The Infrared Heat (Model: E0221) is intended to emit energy in the red and infrared spectrum for use in the treatment of full face wrinkles.

| Type of Use (Select one or both, as applicable) |
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| <div style="display:flex; align-items:center;"><input type="checkbox"/> Prescription Use (Part 21 CFR 801 Subpart D)</div> | <div style="display:flex; align-items:center;"><input checked="" type="checkbox"/> Over-The-Counter Use (21 CFR 801 Subpart C)</div> |
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#### 510(k) Summary of K223893

This summary of 510(k) safety and effectiveness information is being submitted in accordance with the requirement of 21 CFR 807.92.

#### 1. Submitter's Information

Sponsor Name: Light Tree Ventures Europe B.V. Establishment Registration Number: 3017422691 Address: Laan van Ypenburg 108, 2497 GC, The Hague, The Netherlands Contact Person (including title): Alain Dijkstra (Manager) Tel: [phone] Fax: [phone] E-mail: [e-mail]

#### Application Correspondent:

Contact Person: Alain Dijkstra Company: Light Tree Ventures Europe B.V. Address: Laan van Ypenburg 108, 2497 GC, The Hague, The Netherlands Tel: [phone] Fax: [phone] Email: [e-mail]

#### Manufacturer

Shenzhen Kaiyan Medical Equipment Co., Ltd Add: Building#3 and Building#5, 40th of Fuxin Street, Huaide Community Fuyong Town, Baoan District, Shenzhen, Guangdong 518103, China

#### Distributor

Company: Smart Recovery Technologies LLC Add: 132A Veterans Lane-451, Doylestown, PA 18901, USA

#### 2. Subiect Device Information

Trade Name: Infrared Heat, model: E0221 Classification Name: Laser surgical instrument for use in general and plastic surgery and in dermatology Review Panel: General & Plastic Surgerv Product Code: OHS Regulation Number: 21 CFR 890.5500, 21 CFR 878.4810 Regulation Class: II

#### 3. Predicate Device Information

Predicate Device (K171323) Sponsor: BioPhotas, Inc. Trade Name: BioPhotas Celluma3 Classification Name: Laser surgical instrument for use in general and plastic surgery and in dermatology Review Panel: General & Plastic Surgery Product Code: OHS Regulation Number: 21 CFR 878.4810

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Regulation Class: II

#### Predicate Device (K201107)

Sponsor: GTG Wellness Co., Ltd. Trade Name: Opera Lebody Classification Name: Laser surgical instrument for use in general and plastic surgery and in dermatology Review Panel: General & Plastic Surgery Product Code: OHS Regulation Number: 21 CFR 878.4810 Regulation Class: II

### 4. Device Description

The Infrared Heat, model: E0221, is an over-the-counter light emitting diode (LED) device that emits 630nm and 830nm light to treat wrinkles. The device uses three types of LEDs and has two modes to reach those two functions. The user can control the treatment time or automatically shut it off within a set time.

The Infrared Heat components include the main unit device (a pad), an adjustable strap, a USB charging cord, goggles and a user manual.

The user wears the device in the area which needs to treat, and the device will shut down automatically a 10-minute after finishing treatment.

#### 5. Intended Use / Indications for Use

The Infrared Heat (Model: E0221) is intended to emit energy in the red and infrared spectrum for use in the treatment of full face wrinkles.

#### 6. Comparison to predicate devices

Compare with the predicate device, the subject device is very similar in design principle, intended use, indications for use, functions, material and the applicable standards. The differences between the subject device and predicate devices do not raise new questions of safety or effectiveness.

| Elements of<br>Comparison | Subject Device | Predicate Device<br>(K171323) | Predicate Device<br>(K201107) | Remark |
|----------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------|----------------------|
| Company | Light Tree Ventures<br>Europe B.V. | BioPhotas, Inc. | GTG Wellness<br>Co., Ltd. | -- |
| Trade Name | Infrared Heat | Biophotas Celluma3 | Opera Lebody | -- |
| Model | E0221 | / | / | -- |
| Classification<br>Name | Laser surgical instrument<br>for use in general and<br>plastic surgery and in<br>dermatology | Laser surgical<br>instrument for use in<br>general and plastic<br>surgery and in<br>dermatology | Laser surgical<br>instrument for use<br>in general and<br>plastic surgery and<br>in dermatology | Same |
| 510(k) Number | K223893 | K171323 | K201107 | -- |
| Product Code | OHS | OHS | OHS | -- |
| Indications<br>for<br>Use | The Infrared Heat (Model:<br>E0221) is intended to emit<br>energy in the red and<br>infrared spectrum for use<br>in the treatment of full face<br>wrinkles. | The<br>BioPhotas<br>Celluma3 is intended to<br>emit energy in the<br>visible and infrared<br>region of the spectrum<br>for use in the treatment<br>of full face wrinkles. | OPERA LEBODY<br>is an over the<br>counter device<br>that is intended for<br>the use in the<br>treatment of full<br>face wrinkles. | Same |
| Type of Use | Over-The-Counter use | Over-The-Counter use | Over-The-Counter use | Same |
| Light Source | LEDs | LEDs | LEDs | Same |
| Power Supply | Main unit: 3.7V, 1800mAh<br>lithium battery, 6.66Wh<br>Adapter Input: 100-240Va.c., 50/60Hz<br>Adapter Output: 5Vd.c, 2A | 110-120V | No publicity | Different,<br>Note 1 |
| Wavelength | 630nm,830nm+/- 20nm | Red: 640nm+/-25nm<br>NIR: 880nm+/-50nm | 2 types:<br>- Red (630nm)<br>- IR (830nm) | Similar,<br>Note 3 |
| Panels Type | 1 Panel | 1 Panel | 1 Panel (Mask) | Same |
| Output Power | 630nm + 830nm: 30 mW/cm² | 6.5 mw/cm² | 50 mw/cm² | Different,<br>Note 2 |
| Standard dose<br>in Joules | 18J/cm² | 11.7J/cm² | 30J/cm² | Different,<br>Note 2 |
| LED distribution | Uniform distribution | Uniform distribution | Uniform distribution | Same |
| Treatment area | 20*8 | 15*8 | No publicity | Similar,<br>Note 3 |
| LED number | 630nm: 30<br>830nm: 30 | No public | Total 78 LEDs | Similar,<br>Note 3 |
| Treatment Time | 10 minutes per day, 2-5<br>times per week | 3 times a week for 30<br>min. 4 weeks | 10 minutes daily, 3<br>days per week for<br>8 weeks | Different,<br>Note 2 |
| Operation<br>interface | Device uses a timer and<br>software to control<br>treatment duration. | Device uses a timer<br>and software to control<br>treatment duration. | Device uses a<br>timer and software<br>to control<br>treatment duration. | Same |
| Software | Yes | Yes | Yes | Same |
| EMC | IEC 60601-1-2 | IEC 60601-1-2 | IEC 60601-1-2 | Same |
| Safety | IEC 60601-1<br>IEC 60601-2-57<br>IEC 60601-1-11<br>IEC 62471 | IEC 60601-1 | IEC 60601-1<br>IEC 62471 | Same |
| Biocompatibility | ISO 10993-1<br>ISO 10993-5<br>ISO 10993-10<br>ISO 10993-23 | ISO 10993-1<br>ISO 10993-5<br>ISO 10993-10 | ISO 10993-1<br>ISO 10993-5<br>ISO 10993-10 | Same |

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# Comparison in Detail(s):

Note 1: Although the "Power Supply" is a little different from the predicate devices, but they all complied with the IEC 60601-1 and IEC 60601-1-2 safety standards' requirements. So, these slight differences will not raise any safety or effectiveness issues.

Note 2: Although the "Output Power", "Standard dose in Joules", and "Treatment Time" of the subject device and predicate devices are a little different, the "Output Power" and "Standard dose in Joules" of the subject device is not higher than Predicate Device (K201107), indicating the safety of the device, and not lower than Predicate Device (K171323), indicating the effectiveness of the device. Besides, the "Treatment Time" is similar to predicate device. So, the "Output Power", "Standard dose in Joules", and "Treatment Time" of the subject device and predicate devices does not affect the effectiveness and safety of the device.

Note 3: Although the "Wavelength", "Treatment area" and "LED number" are slightly different from the predicate device, their treatment doses are all safe and effective, ang they all complied with the requirement of IEC 60601-2-57 and IEC 62471 standards. So, these slight differences will not raise any safety or effectiveness issues.

# 7. Test Summary

#### 7.1 Non-Clinical Tests Performed

- 1) Non-clinical tests were performed on the subject device in order to validate the design and to assure conformance with the following voluntary design standards in connection with medical device electrical safety, and electromagnetic compatibility:

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# K223893

- AAMI/ANSI ES60601-1 2005/(R)2012 & A1:2012, C1:2009/(R)2012 & A2:2010/(R)2012 (Cons. Text) � [Incl. AMD2:2021] Medical electrical equipment - Part 1: General requirements for basic safety and essential performance.
- � IEC 60601-1-11 Edition 2.1 2020-07 Medical Electrical Equipment --Part 1: General Requirements for Basic Safety and Essential Performance --Collateral Standard: Requirements for Medical Electrical Equipment and Medical Electrical Systems Used in the Home Healthcare Environment.
- � IEC 60601-2-57 Edition 1.0 2011-01 Medical Electrical Equipment - Part 2-57: Particular requirements for the basic safety and essential performance of non-laser light source equipment intended for therapeutic, diagnostic, monitoring and cosmetic/aesthetic use.
- � IEC 60601-1-2 Edition 4.1 2020-09 Medical electrical equipment - Part 1-2: General requirements for basic safety and essential performance - Collateral Standard: Electromagnetic disturbances -Requirements and tests.
- � IEC 62471 First edition 2006-07 Photobiological safety of lamps and lamp systems.
- � IEC 62133-2 Edition 1.0 2017-02 Secondary cells and batteries containing alkaline or other non-acid electrolytes - Safety requirements for portable sealed secondary cells, and for batteries made from them, for use in portable applications - Part 2: Lithium systems.
- � IEC 60601-1-6 Edition 3.2 2020-07 Medical electrical equipment - Part 1-6: General requirements for basic safety and essential performance - Collateral standard: Usability
- � IEC 62366-1 Edition 1.1 2020-06 Medical devices - Part 1: Application of usability engineering to medical devices

# 2) Biocompatibility

The subject device is biocompatible for its intended use. They are complied with biocompatibility standards ISO 10993-5 (Cytotoxicity), ISO 10993-10 (Sensitization) and ISO 10993-23 (Irritation).

# 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 concern, since a malfunction of, or a latent design flaw in, the Software Device leads to an erroneous diagnosis or a delay in delivery of appropriate medical care that would likely lead to Minor Injury.

# 4) Usability Testing

Usability testing was conducted on the Infrared Heat (Models: E0221), which complies with IEC 62366-1 and IEC 60601-1-6.

# 7.2 Summary of Clinical Performance

Clinical testing was not needed for this 510(k). The non-clinical performance testing described above is sufficient to support that the device can be used safely and effectively.

# 8. Date of the summary prepared: May 13, 2023

# 9. Final Conclusion:

The subject device is as safe, as effective, and performs as well as or better than the legally marketed predicated devices K171323 and K201107.