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Photobiomodulation (PBM) Devices - Premarket Notification [510(k)] Submissions: Draft Guidance for Industry and Food and Drug Administration Staff

DraftCenter for Devices and Radiological Health01/12/2023

Description

This draft guidance document provides the FDA’s recommendations on non-clinical testing, clinical studies, and labeling to support premarket submissions for photobiomodulation (PBM) devices, also known as low level light therapy (LLLT) devices. This guidance applies to class II PBM medical devices regulated under 21 CFR 878.4810, 878.4850, 878.5400, and 890.5500. This guidance also applies to the PBM component of devices that combine a PBM device with another device(s) (e.g., electrostimulation source, mechanical massager, or ultrasound). Some light-emitting products that are intended for only general wellness use and present a low risk to the safety of users and other persons, may not be within the scope of this guidance. The recommendations reflect current review practices and are intended to promote consistency and facilitate efficient review of PBM device submissions.

Scope & Applicability

Product Classes

2
Photobiomodulation (PBM) Devices

The primary subject of the guidance, also known as low level light therapy (LLLT) devices.; Subject of the guidance document; Subject of the guidance document regarding premarket notification submissions.; Subject of the premarket notification guidance; examples of warnings and precautions for PBM devices

Cold sore devices

Specific category of PBM devices with unique performance testing requirements.

Stakeholders

4
Industry

Guidance for Industry

Patient

Way questions are framed is critical to collecting unbiased patient input

Manufacturer

Entity responsible for submitting NDINs

Lay User

Intended user population for emergency use auto-injectors

Regulatory Context

Attributes

7
Energy Fluence

Radiant dose parameter for device description.; Radiant dose delivered to tissue

Fluence

Dose selection parameter defined as light energy received per unit area

Fitzpatrick skin phototype

Factor impacting dose selection in clinical studies

Fitzpatrick skin phototypes

Classification of skin types used to assess treatment-emergent risks.

Level of Concern

Categorization (minor, moderate, major) for software risk.

Wavelength

Light generation parameter for device description.; Technical parameter in nanometers

Irradiance

Radiant power parameter for device description.; Radiant power per area; Dose selection parameter defined as light power received per unit area

Identified Hazards

Hazards

7
Thermal Safety

Safety concern regarding heat generation.

Eye injury

To eliminate any possible danger to the eyes

Ocular tissue damage

Risk posed by energy and irradiance values greater than maximum permissible exposure.

Tissue damage

Risk caused by inadvertent overuse or high irradiance leading to thermal injury.; Misuse of the device might lead to injury

Electromagnetic Disturbance

Potential risk for medical electrical equipment failing to operate properly.

Eye Safety

Safety concern regarding light exposure to the eyes.

Cancerous lesions

Warning against use of non-thermal lasers over these areas

Related CFR Sections (8)

Related Warning Letters (10)

  • CGMP/QSR/Medical Devices/Adulterated

    Contec Medical Systems Co., Ltd.

    2025-10-28
  • CGMP/QSR/Medical Devices/Adulterated

    Technological Medical Advancements LLC

    2025-10-07
  • Clinical Investigator

    Shirish M. Gadgeel, M.D.

    2025-09-09
  • CGMP/QSR/Medical Devices/PMA/Adulterated/Misbranded

    Uscom Kft

    2025-08-26
  • CGMP/QSR/Medical Devices/Adulterated

    Spectra Therapy, LLC

    2025-08-12
  • CGMP/QSR/Medical Devices/Adulterated/Misbranded

    Visgeneer, Inc

    2025-08-05
  • CGMP/QSR/Medical Devices/Adulterated

    Onkos Surgical, Inc.

    2025-07-29
  • Clinical Investigator

    Mark J. Savant, M.D

    2025-07-15
  • Bioresearch Monitoring Program/Institutional Review Board (IRB)

    United Health Products, Inc.

    2025-05-20
  • Investigational Device Exemptions (IDE)/Premarket Approval Application (PMA)

    Next Science LLC

    2025-04-01

See Also (8)