← Product Code [GEX](/submissions/SU/subpart-e%E2%80%94surgical-devices/GEX) · K252519 # CO2 Laser Therapy System (K106) (K252519) _Hebei Keylaser Sci-Tech Co.,Ltd · GEX · Nov 7, 2025 · General, Plastic Surgery · SESE_ **Canonical URL:** https://fda.innolitics.com/submissions/SU/subpart-e%E2%80%94surgical-devices/GEX/K252519 ## Device Facts - **Applicant:** Hebei Keylaser Sci-Tech Co.,Ltd - **Product Code:** [GEX](/submissions/SU/subpart-e%E2%80%94surgical-devices/GEX.md) - **Decision Date:** Nov 7, 2025 - **Decision:** SESE - **Submission Type:** Traditional - **Regulation:** 21 CFR 878.4810 - **Device Class:** Class 2 - **Review Panel:** General, Plastic Surgery - **Attributes:** Therapeutic ## Intended Use The CO2 Laser Therapy System is used for soft tissue vaporization, coagulation in dermatology and plastic surgery, general surgery, gynecology, podiatry, dental and otorhinolaryngology. ## Device Story CO2 Laser Therapy System generates laser beam via electrically excited carbon dioxide gas; high energy density beam focused to achieve vaporization and coagulation of soft tissue. Unfocused beam used for tissue coagulation; focused beam for deeper tissue heating/treatment. Device used in hospital settings; operated by clinicians. System includes 7-joint light guide arm for beam delivery, 630-650nm red diode aiming beam, and touch screen/footswitch controls. Output allows precise surgical intervention on soft tissues, facilitating procedures across multiple specialties. Benefits include controlled tissue ablation and hemostasis. ## Clinical Evidence No clinical data. Bench testing only, including electrical safety (IEC 60601-1), laser safety (IEC 60825-1, IEC 60601-2-22), EMC (IEC 60601-1-2), and biocompatibility (ISO 10993-5, -10, -23). ## Technological Characteristics CO2 gas laser medium; 10.6 um wavelength; 30W max power. 7-joint light guide arm delivery; 630-650nm red diode aiming beam. Air cooling. Touch screen and footswitch interface. Complies with IEC 60601-1, IEC 60601-2-22, IEC 60825-1, IEC 60601-1-2. Biocompatible per ISO 10993-5, 10, 23. ## Regulatory 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 - CO2 Laser Therapy Machine ([K161925](/device/K161925.md)) ## Submission Summary (Full Text) > This content was OCRed from public FDA records by [Innolitics](https://innolitics.com). If you use, quote, summarize, crawl, or train on this content, cite Innolitics at https://innolitics.com. > > Innolitics is a medical-device software consultancy. We help companies design, build, and clear FDA-regulated software and AI/ML devices, including [a 510(k)](https://innolitics.com/services/510ks/), [a De Novo](https://innolitics.com/services/regulatory/), [a SaMD](https://innolitics.com/services/end-to-end-samd/), [an AI/ML medical device](https://innolitics.com/services/medical-imaging-ai-development/), or [an FDA regulatory strategy](https://innolitics.com/services/regulatory/). {0} FDA U.S. FOOD & DRUG ADMINISTRATION November 7, 2025 HEBEI KEYLASER SCI-TECH Co., Ltd % Ray Wang General Manager Beijing Believe-Med Technology Service Co., Ltd. Rm.912, Building #15, XiYueHui, No.5, YiHe North Rd., FangShan District Beijing, 102401 China Re: K252519 Trade/Device Name: CO2 Laser Therapy System (K106) 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: GEX Dated: August 11, 2025 Received: August 11, 2025 Dear Ray Wang: 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 (the 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 available 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. U.S. Food & Drug Administration 10903 New Hampshire Avenue Silver Spring, MD 20993 www.fda.gov {1} K252519 - Ray Wang Page 2 Additional information about changes that may require a new premarket notification are provided in the FDA guidance documents entitled "Deciding When to Submit a 510(k) for a Change to an Existing Device" (https://www.fda.gov/media/99812/download) and "Deciding When to Submit a 510(k) for a Software Change to an Existing Device" (https://www.fda.gov/media/99785/download). Your device is also subject to, among other requirements, the Quality System (QS) regulation (21 CFR Part 820), which includes, but is not limited to, 21 CFR 820.30, Design controls; 21 CFR 820.90, Nonconforming product; and 21 CFR 820.100, Corrective and preventive action. Please note that regardless of whether a change requires premarket review, the QS regulation requires device manufacturers to review and approve changes to device design and production (21 CFR 820.30 and 21 CFR 820.70) and document changes and approvals in the device master record (21 CFR 820.181). Please be advised that FDA's issuance of a substantial equivalence determination does not mean that FDA has made a determination that your device complies with other requirements of the Act or any Federal statutes and regulations administered by other Federal agencies. You must comply with all the Act's requirements, including, but not limited to: registration and listing (21 CFR Part 807); labeling (21 CFR Part 801); medical device reporting (reporting of medical device-related adverse events) (21 CFR Part 803) for devices or postmarketing safety reporting (21 CFR Part 4, Subpart B) for combination products (see https://www.fda.gov/combination-products/guidance-regulatory-information/postmarketing-safety-reporting-combination-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 Part 4, Subpart A) for combination products; and, if applicable, the electronic product radiation control provisions (Sections 531-542 of the Act); 21 CFR Parts 1000-1050. All medical devices, including Class I and unclassified devices and combination product device constituent parts are required to be in compliance with the final Unique Device Identification System rule ("UDI Rule"). The UDI Rule requires, among other things, that a device bear a unique device identifier (UDI) on its label and package (21 CFR 801.20(a)) unless an exception or alternative applies (21 CFR 801.20(b)) and that the dates on the device label be formatted in accordance with 21 CFR 801.18. The UDI Rule (21 CFR 830.300(a) and 830.320(b)) also requires that certain information be submitted to the Global Unique Device Identification Database (GUDID) (21 CFR Part 830 Subpart E). For additional information on these requirements, please see the UDI System webpage at https://www.fda.gov/medical-devices/device-advice-comprehensive-regulatory-assistance/unique-device-identification-system-udi-system. Also, please note the regulation entitled, "Misbranding by reference to premarket notification" (21 CFR 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-devices/medical-device-safety/medical-device-reporting-mdr-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/medical-devices/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-devices/device-advice-comprehensive-regulatory- {2} K252519 - Ray Wang Page 3 assistance/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, TANISHA L. HITHE -S Digitally signed by TANISHA L. HITHE -S Date: 2025.11.07 21:53:10 -05'00' Tanisha Hithe 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 {3} FORM FDA 3881 (8/23) Page 1 of 1 PSC Publishing Services (301) 443-6740 EF | DEPARTMENT OF HEALTH AND HUMAN SERVICES Food and Drug Administration Indications for Use | Form Approved: OMB No. 0910-0120 Expiration Date: 07/31/2026 See PRA Statement below. | | --- | --- | | 510(k) Number (if known) K252519 | | | Device Name CO2 Laser Therapy System (K106) | | | Indications for Use (Describe) The CO2 Laser Therapy System is used for soft tissue vaporization, coagulation in dermatology and plastic surgery, general surgery, gynecology, podiatry, dental and otorhinolaryngology. | | | Type of Use (Select one or both, as applicable) ☑ Prescription Use (Part 21 CFR 801 Subpart D) ☐ Over-The-Counter Use (21 CFR 801 Subpart C) | | | CONTINUE ON A SEPARATE PAGE IF NEEDED. | | | This section applies only to requirements of the Paperwork Reduction Act of 1995. *DO NOT SEND YOUR COMPLETED FORM TO THE PRA STAFF EMAIL ADDRESS BELOW.* | | | The burden time for this collection of information is estimated to average 79 hours per response, including the time to review instructions, search existing data sources, gather and maintain the data needed and complete and review the collection of information. Send comments regarding this burden estimate or any other aspect of this information collection, including suggestions for reducing this burden, to: Department of Health and Human Services Food and Drug Administration Office of Chief Information Officer Paperwork Reduction Act (PRA) Staff PRAStaff@fda.hhs.gov | | | "An agency may not conduct or sponsor, and a person is not required to respond to, a collection of information unless it displays a currently valid OMB number." | | {4} The assigned 510(k) Number: K252519 # 510(k) Summary This 510(k) Summary of 510(k) safety and effectiveness information is being submitted in accordance with requirements of Title 21, CFR Section 807.92. 1. Date of Preparation: 11/06/2025 2. Sponsor Identification **HEBEI KEYLASER SCI-TECH Co., Ltd** 4th Floor Building C18-2, HeGu Industry Park, Chaoyang East Road, ZhuoZhou Baoding City HeBei Province, China Contact Person: Zhen Yang Position: Chief Executive Officer Tel: +86-18611920156 Email: Thomas@key-laser.com 3. Designated Submission Correspondent Mr. Ray Wang **Beijing Believe-Med Technology Service Co., Ltd.** Rm.912, Building #15, XiYueHui, No.5, YiHe North Rd., FangShan District, Beijing, 102401, China Tel: +86-18910677558 Fax: +86-10-56335780 Email: information@believe-med.com {5} 2 4. Identification of Proposed Device Trade Name: CO2 Laser Therapy System (K106) Common Name: Powered Laser Surgical Instrument Regulatory Information Classification Name: Powered Laser Surgical Instrument Classification: II Product Code: GEX Regulation Number: 878.4810 Review Panel: General & Plastic Surgery 5. Identification of Predicate Device(s) 510(k) Number: K161925 Product Name: CO2 Laser Therapy Machine Manufacturer: Beijing Adss Development Co., Ltd 6. Device Description CO2 Laser Therapy System is a laser beam generated by electrically excited carbon dioxide gas molecules, which has a very small divergence angle and high energy density. After focusing, it can reach a power of several kilowatts per square centimeter. Has the functions of vaporization and coagulation. The unfocused original light beam irradiates the lesion tissue, which can cause coagulation of biological tissue. The CO2 laser penetrates the tissue deeper, and after irradiation, it can heat and treat the deep tissue. 7. Indications For Use Statement: The CO2 Laser Therapy System is used for soft tissue vaporization, coagulation in dermatology and plastic surgery, general surgery, gynecology, podiatry, dental and otorhinolaryngology. {6} 8. Substantially Equivalent (SE) Comparison Tab 1 General Comparison | Item | Proposed Device | Predicate Device (K161925) | Remark | | --- | --- | --- | --- | | Product Code | GEX | GEX | SE | | Regulation No. | 21 CFR 878.4810 | 21 CFR 878.4810 | SE | | Class | 2 | 2 | SE | | Where used | hospital | hospital | SE | | Intended Use | The CO2 Laser Therapy System is used for soft tissue vaporization, coagulation in dermatology and plastic surgery, general surgery, gynecology, podiatry, dental and otorhinolaryngology. | The CO2 Laser Therapy Machine is used for human tissue vaporization, coagulation in dermatology and plastic surgery, general surgery, gynecology, podiatry, dental and otorhinolaryngology. | SE | Tab 2 Performance Comparison | Item | Proposed Device | | | Predicate Device (K161925) | | | Remark | | --- | --- | --- | --- | --- | --- | --- | --- | | Maximum Power | 30W | | | 30W | | | SE | | Work Mode | Surgery (Single Pulse, Continuous, Muti-Pulse) | | | Surgery (Single Pulse, Continuous, Muti-Pulse) | | | SE | | Wavelength | 10.6 um | | | 10.6 um | | | SE | | Beam Delivery | 7 joint light guide arm | | | 7 knucklearmkey joints light arm | | | SE | | Aiming Beam | 630-650nm red diode laser (≤5 mW) | | | 650nm red diode laser (0.5 mW) | | | Similar | | Spot Size | 0.5 mm | | | 0.5 mm | | | SE | | Pulse Setting | Single Pulse | | 10-1000ms | Single Pulse | | 10-1000ms | Within Range | | | MutiPulse | Pulse Time | 10-1000ms | Muti-Pulse | Time On | 10-1000ms | | | | | Interval Time | 10-1000ms | | Time Off | 10-1000ms | | | | continuous | | 1-30W | continuous | | 0-30W | | | Control System | Touch screen, footswitch | | | Touch screen, footswitch | | | SE | | Laser Operation | Footswitch | | | Footswitch | | | SE | | Laser medium/energy source | CO2 | | | CO2 | | | SE | | Cooling System | Air cooling | | | Air cooling | | | SE | | Cleaning Method | 70% isopropyl alcohol | | | 70% medical alcohol | | | SE | {7} 4 | Dimension | 63*54* 116cm( without light arm) | FG 900 | 56*46*112 cm | Analysis | | --- | --- | --- | --- | --- | | | | FG 900-B | 60*54*32cm | | | | | FG 900-C | 46*42*125cm | | | Weight | 56Kg | FG 900 | 49 kg | Analysis | | | | FG 900-B | 28kg | | | | | FG 900-C | 43kg | | | Power input | AC 110V/60Hz | AC 110V/50Hz-60Hz | | Similar | Tab 3 Safety Comparison | Item | Proposed Device | Predicate Device K161925 | Remark | | --- | --- | --- | --- | | EMC, Electrical and Laser Safety | | | | | Electrical Safety | Comply with IEC 60601-1, IEC 60601-2-22 | Comply with IEC 60601-1, IEC 60601-2-22 | SE | | EMC | Comply with IEC 60601-1-2 | Comply with IEC 60601-1-2 | SE | | Laser Safety | Comply with IEC 60601-2-22, IEC 60825-1 | Comply with IEC 60601-2-22, IEC 60825-1 | SE | ## Analysis The only difference between proposed device and predicate device is appearance (dimension, weight), which does not affect the safety and effectiveness of proposed device. Based on the nonclinical tests performed, the proposed device is as safe, as effective, and performs as well as the legally marketed predicate device. ## 9. Non-Clinical Test Conclusion Non clinical tests were conducted to verify that the proposed device met all design specifications as was Substantially Equivalent (SE) to the predicate device. The test results demonstrated that the proposed device complies with the following standards: - IEC 60601-1 Edition 3.2 2020-08, Medical electrical equipment - Part 1: General requirements for basic safety and essential performance - IEC 60825-1:2014, Safety of laser products - Part 1: Equipment classification, and requirements - IEC 60601-2-22: 2012 Medical electrical equipment - Part 2-22: Particular requirements for basic safety and essential performance of surgical, cosmetic, therapeutic and diagnostic laser equipment - ISO 10993-10 Fourth edition 2021, Biological evaluation of medical devices - Part 10: Tests for skin sensitization - ISO 10993-23 First edition 2021-01, Biological evaluation of medical devices - Part 23: Tests for irritation - ISO 10993-5: 2009 Biological Evaluation of Medical Devices -- Part 5: Tests For In Vitro Cytotoxicity - IEC 60601-1-2 Edition 4.1 2020-09, Medical Electrical Equipment-Part 1-2: General {8} Requirements For Basic Safety And Essential Performance - Collateral Standard: Electromagnetic Compatibility-Requirements And Test 10. Clinical Test Conclusion No clinical study is included in this submission. 11. Conclusion Based on the non-clinical tests performed, the subject device is as safe, as effective, and performance as well as the legally marketed predicate device, CO2 Laser Therapy Machine cleared under K161925. 5 --- **Source:** [https://fda.innolitics.com/submissions/SU/subpart-e%E2%80%94surgical-devices/GEX/K252519](https://fda.innolitics.com/submissions/SU/subpart-e%E2%80%94surgical-devices/GEX/K252519) **Published by [Innolitics](https://innolitics.com)** — a medical-device software consultancy. We help companies design, build, and clear FDA-regulated software and AI/ML devices. 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