Contains Nonbinding Recommendations 
Classification and Requirements for 
Laser Illuminated Projectors (LIPs) 
(Laser Notice No. 57)
 
______________________________________________________________________________ 
Guidance for Industry and 
Food and Drug Administration Staff 
Document issued on May 8, 2019. 
The draft of this document was issued on October 2, 2017. 
This document supersedes Immediately in Effect Guidance Document: 
Classification and Requirements for Laser Illuminated Projectors (LIPs), 
dated February 18, 2015. 
For questions about this document, contact the Division of Radiological Health at (301) 796-2121 
or Patrick Hintz at (301) 796-6927 or via email at Patrick.Hintz@fda.hhs.gov. 
U.S. Department of Health and Human Services 
Food and Drug Administration 
Center for Devices and Radiological Health  Contains Nonbinding Recommendations 
Preface
 
Public Comment 
You may submit electronic comments and suggestions at any time for Agency consideration to 
https://www.regulations.gov. Submit written comments to the Dockets Management Staff, Food 
and Drug Administration, 5630 Fishers Lane, Room 1061, (HFA-305), Rockville, MD 20852. 
Identify all comments with the docket number FDA-2014-D-2245. Comments may not be acted 
upon by the Agency until the document is next revised or updated. 
Additional Copies 
Additional copies are available from the Internet.  You may also send an e-mail request to CDRH-
Guidance@fda.hhs.gov to receive a copy of the guidance. Please use the document number 
1400056 to identify the guidance you are requesting.  Contains Nonbinding Recommendations 
Table of Contents 
I.  Introduction .............................................................................................................................. 1 
II.  Background .............................................................................................................................. 2 
III. Scope ........................................................................................................................................ 3 
IV. Policy ........................................................................................................................................ 4 
Appendix A. .................................................................................................................................... 9  Contains Nonbinding Recommendations 
Classification and Requirements for 
Laser Illuminated Projectors (LIPs) 
(Laser Notice No. 57) 
Guidance for Industry and 
Food and Drug Administration Staff 
This guidance represents the current thinking of the Food and Drug Administration (FDA or 
Agency) on this topic.  It does not establish any rights for any person and is not binding on 
FDA or the public.  You can use an alternative approach if it satisfies the requirements of the 
applicable statutes and regulations.  To discuss an alternative approach, contact the FDA staff 
or Office responsible for this guidance as listed on the title page. 
I. Introduction 
This guidance describes FDAs policy with respect to certain laser illuminated projectors that 
comply with International Electrotechnical Commission (IEC) standards during laser product 
classification1 under the Electronic Product Radiation Control provisions of the Federal Food, 
Drug, and Cosmetic Act (the FD&C Act) that apply to electronic products. 
For purposes of this guidance, the term laser illuminated projector (LIP) refers to a type of 
demonstration laser product2 regulated under 21 CFR 1040.10(b)(13) that is designed to project a 
display image without the use of raster-scanned collimated laser beams.  LIPs may be used in 
locations such as indoor or outdoor cinema theaters, laser shows, presentations at conventions, as 
image/data projectors in an office setting, or in a home. 
Lasers are being used in LIPs as an alternative to conventional lamps in projectors.  Although 
these LIPs emit laser light from extended sources and their uncollimated beams do not present 
the same hazards as other lasers, they are laser products that present risks and must undergo 
classification in accordance with 21 CFR 1040.10(c). 
Under 21 CFR 1040.10(c), FDA recognizes four major hazard classes (I to IV) of lasers, 
including three subclasses (IIa, IIIa, and IIIb).  Under this classification procedure higher laser 
                                                          
1 The requirements for classifying laser products are set forth in 21 CFR part 1040. 
2 The term demonstration laser product is defined under 21 CFR 1040.10(b)(13) to mean any laser product 
manufactured, designed, intended, or promoted for purposes of demonstration, entertainment, advertising display, or 
artistic composition.  
1  Contains Nonbinding Recommendations 
classes correspond to more powerful lasers and a higher potential to pose serious danger if used 
improperly.  
As demonstration laser products, LIPs and applications for LIPs cannot exceed Class IIIa 
emission limits as specified in 21 CFR 1040.11(c) (which is comparable to IEC 60825-1 Ed. 3.03
Class 3R) unless granted a variance by FDA under 21 CFR 1010.4.  Some LIPs and applications 
for LIPs will exceed the Class IIIa limits and therefore require a variance to exceed those 
emission limits.  
This guidance document describes FDAs intent to clarify the application of certain aspects of 
the performance standard requirements in 21 CFR 1040.11(c) for LIPs.  Because the radiant 
emission levels produced by LIPs can be scientifically characterized by an alternative IEC 
standard, IEC 62471-5: Ed. 1.0, FDA does not intend to enforce the requirements under 21 CFR 
1040.10(c)(1) and 21 CFR 1040.11(c) when LIP manufacturers conform to these standards under 
the situations outlined in sections III and IV of this guidance.  For LIP manufacturers that do not 
conform with the situations outlined in sections III and IV of this guidance, FDA intends to 
consider whether those manufacturers laser products comply with 21 CFR 1040.10(c)(1) and 21 
CFR 1040.11(c), among other applicable requirements.  Such manufacturers may elect to 
evaluate their laser products in accordance with FDAs guidance entitled Laser Products  
Conformance with IEC 60825-1 Ed. 3 and IEC 60601-2-22 Ed. 3.1 (Laser Notice No. 56); 
Guidance for Industry and FDA Staff4 however, sub-clause 4.4 of IEC 60825-1 Ed. 3 would not 
apply to these products. 
FDAs guidance documents, including this guidance, do not establish legally enforceable 
responsibilities.  Instead, guidances describe the Agency's current thinking on a topic and should 
be viewed only as recommendations, unless specific regulatory or statutory requirements are 
cited.  The use of the word should in Agency guidance means that something is suggested or 
recommended, but not required. 
II.  Background 
IEC is a global organization that prepares and publishes international standards for electrical, 
electronic, and related technologies, including laser products.  FDA acknowledges that standard 
IEC 60825-1: Ed. 3 allows alternative classification procedures for certain laser products that 
produce extended source light emissions, such as LIPs.  Under this alternative classification 
procedure, LIPs are categorized by optical safety Risk Groups (RGs) specified in standard IEC 
62471-5: Ed. 1.0: Photobiological safety of lamps and lamp systems - Part 5: Image projectors. 
Under the IECs classification procedure, LIPs are assigned a Risk Group of 0, 1, 2, or 3, where 
higher Risk Groups correspond to higher radiation outputs and a higher potential to pose serious 
danger if used improperly.  The laser standard, IEC 60825-1:Ed. 3 has an exemption Subclause 
                                                          
3 International Electrotechnical Commission (IEC) 60825-1 Ed. 3.0: Safety of laser products - Part 1: Equipment 
classification, and requirements 
4https://www.fda.gov/regulatory-information/search-fda-guidance-documents/laser-products-conformance-iec-
60825-1-ed-3-and-iec-60601-2-22-ed-31-laser-notice-no-56 
2 Contains Nonbinding Recommendations 
4.4 that, if satisfied, qualifies the laser product for the use of classification risk groups from the 
IEC series of lamp standards. 
FDA recognizes the advantages of one set of worldwide standards for classifying laser products, 
including LIPs.  Moreover, FDA believes that, under certain circumstances set forth below, the 
relevant IEC standards adequately categorize the risks to health posed by qualified LIPs.  
Therefore, FDA does not intend to enforce the requirements in 21 CFR 1040.10(c)(1) and 21 
CFR 1040.11(c) for qualified LIPs that conform to certain IEC 62471-5:Ed. 1 RGs under the 
situations described in this guidance. 
III.  Scope 
This guidance only applies to LIPs with extended source emissions that meet all of the following 
factors: 
(a) The projector is neither a childrens toy laser product5 nor a medical device.6
(b) The projector does not produce scanned laser radiation.7
(c) The projectors laser illumination system is an alternative to a conventional projector 
light source. 
(d) The projector passes the IEC 60825-1:Ed. 3 radiance limit threshold (LT), subclause 4.4 
of IEC 60825-1:Ed. 3 using the measurement conditions discussed in IEC 60825-1:Ed. 3 
Information Sheet ISH2. 
(e) Applicability of RG2 LIPs is limited to Table 1 (below) using source angular extent  and 
emissions expressed as a fraction of the RG2 accessible emission limit (AEL) after 
classifying the LIP to IEC 62471-5:Ed. 1.  RG1 and RG0 LIPs have no applicability 
restrictions.  
                                                          
5 See FDAs guidance entitled Minimizing Risk for Childrens Toy Laser Products 
(https://www.fda.gov/regulatory-information/search-fda-guidance-documents/minimizing-risk-childrens-toy-laser-
products). 
6 The term device is defined in 201(h) of the FD&C Act to include an instrument, apparatus, implement, 
machine, contrivance, implant, in vitro reagent, or other similar or related article, including any component, part, or 
accessory, which is . . . intended for use in the diagnosis of disease or other conditions, or in the cure, mitigation, 
treatment, or prevention of disease, in man . . . or intended to affect the structure or any function of the body of 
man.       
7 The term scanned laser radiation is defined under 21 CFR 1040.10(b)(37) to mean laser radiation having a time-
varying direction, origin or pattern of propagation with respect to a stationary frame of reference.  
3 Contains Nonbinding Recommendations 
Table 1 Applicable RG2 LIPs 
Source  (milliradians)  Limit Threshold Fraction 
measured at 1 m  of RG2 AEL 
 11  1.0 
10  0.92 
9  0.83 
8  0.73 
7  0.64 
6  0.55 
5  0.45 
LIPs that do not meet all these factors are outside the scope of this guidance and FDA will 
continue to consider the requirements found at 21 CFR 1040.10(c)(1) and 21 CFR 1040.11(c) for 
those LIPs.  Non-applicable LIPs may be considered individually in a variance submitted to FDA 
under 21 CFR 1010.4. 
IV.  Policy 
FDA does not intend to enforce the requirements in 21 CFR 1040.10(c)(1) and 21 CFR 
1040.11(c) for manufacturers of LIPs within the scope of this guidance (see Section III above) 
that fall within all of the situations described in paragraphs (a), (b), and (c) set forth below.  For 
LIPs within the scope of this guidance that do not fall within the situations described in 
paragraphs (a), (b), and (c) below, FDA discusses some unique aspects to how it expects to 
regulate them in paragraph (d) below. 
(a) Provided that the LIPs meet the descriptions in Section III, manufacturers first conduct 
measurements for classifying LIPs.  Normative standard IEC 62471: Ed. 1 Subclause 
5.2.2 supplies important information for optical measurement conditions. The 
classification measurements and analysis include all exit pupil radiation from lasers, 
phosphors and LEDs. As provided in paragraph (c)(iv) below, conformance to subclause 
5.2.2 is noted in reports to FDA and supporting records are kept in accordance with 21 
CFR 1002.30.  
(b) Provided that the LIPs meet the descriptions in Section III and are measured as described 
in paragraph (a), manufacturers then classify the LIPs in RGs and laser classes and certify 
their product as follows: 
(i)  Classify the projector to a risk group according to IEC 62471-5:Ed. 1 
Photobiological Safety of Lamps and Lamp Systems, Part 5: Image Projectors. 
(ii)  Determine that the informative Annex B in IEC 62471-5:Ed. 1 is not applicable to 
the projector. 
4 Contains Nonbinding Recommendations 
(iii)  If the LIP output exceeds a fraction of 0.6 (60%) of the RG2 AEL, supply special 
labeling and user information to reduce exposure risks to children: 
a.  An additional Product Warning label is placed near the symbol of Figure 8 in 
IEC 62471-5:Ed. 1 (staring prohibited):  WARNING:  MOUNT ABOVE 
THE HEADS OF CHILDREN  Text and border of the label is black on an 
orange background.  The warning statement may also be combined with the 
staring prohibited label if the warning text has an orange background or 
orange header for the signal word, WARNING. 
b.  The Users Manual Installation Instructions additionally state: WARNING:  
MOUNT ABOVE THE HEADS OF CHILDREN.  The use of a ceiling mount 
is recommended with this product to place it above the eyes of children. 
(iv)  With respect to the embedded phosphor-pump laser(s), certify the LIP (1) as a 
Class I laser product according to applicable requirements of 21 CFR 1010, 
1040.10, and 1040.11; or (2) as an IEC Class 1 laser product using the process 
discussed in Laser Notice No. 56.8 Conform to the accessible laser class 
requirements during procedures of Maintenance and Service, as applicable, in 
accordance with 21 CFR Part 1040.  For LIPs with embedded alignment laser(s) 
that are visible only during Maintenance or Service, certify the LIP as applicable 
to Laser Class I, II or IIIa or as IEC Class 1, 2 or 3R for the visible alignment 
laser emissions. 
(c) For LIPs that are in RG 0, 1, or 2, meet the descriptions in Section III and are measured 
and classified according to the procedures in paragraphs (a) and (b) of this section, 
manufacturers: 
(i)  Use the following modified statements of compliance on the certification label, as 
applicable: 
a.  Complies with 21 CFR 1040.10 and 1040.11 except for conformance as a 
Risk Group [0, 1 or 2  Select appropriate RG] LIP as defined in IEC 62471-
5:Ed. 1.0.  For more information see Laser Notice No. 57, dated May 8, 
2019.; or, 
b.  Complies with FDA performance standards for laser products except for 
conformance as a Risk Group [0, 1, or 2  Select appropriate RG] LIP as 
defined in IEC 62471-5:Ed. 1.0.  For more information see Laser Notice No. 
57, dated May 8, 2019. or, 
c.  Complies with 21 CFR 1040.10 and 1040.11 except for conformance as a 
Risk Group (0, 1, or 2  Select appropriate RG) LIP as defined in IEC 62471-
                                                          
8 https://www.fda.gov/regulatory-information/search-fda-guidance-documents/laser-products-conformance-iec-
60825-1-ed-3-and-iec-60601-2-22-ed-31-laser-notice-no-56 
5 Contains Nonbinding Recommendations 
5:Ed. 1.0.  For more information see Laser Notice No. 57, dated May 8, 
2019. 
(ii)  Conform to all labeling specifications as provided in IEC 62471-5:Ed. 1.0 with 
the following exceptions/additions:  
a.  With regard to RG0 LIPs, the second sentence in Subclause 6.5.2 of IEC 
62471-5:Ed. 1 is not applicable.  
b.  Always include the label for RG1 LIPs as provided in Subclause 6.5.3 of IEC 
62471-5:Ed. 1.  The statement in Subclause 6.5.3 of IEC 62471-5:Ed. 1 that 
the label for RG1 LIPs is optional is not applicable. 
(iii)  Conform to requirements applicable to the Operation Manual as specified in 
Subclause 6.6.3 of IEC 62471-5:Ed. 1 with the following additions: 
a.  Notice is given to supervise children and to never allow them to stare into the 
projector beam at any distance from the projector.  
b.  Notice is given to use caution when using the remote control for starting the 
projector while in front of the projection lens.  
c.  Notice is given to the user to avoid the use of optical aids such as binoculars 
or telescopes inside the beam. 
(iv)  Submit product reports and annual reports and comply with all other reporting and 
recordkeeping requirements as required by 21 CFR 1002.  Product reports for 
LIPs will document how the product meets the descriptions in Section III, was 
measured, classified, and certified according to the procedures in paragraphs (a) 
and (b) of this section, and complies with the requirements of 21 CFR 1010, 21 
CFR 1040.10, and 21 CFR 1040.11.  The manufacturer may use Form FDA 3632 
Guide for Preparing Product Reports for Lasers and Products Containing 
Lasers9 to submit these reports. 
For manufacturers that follow the steps described in this paragraph, FDA will not object 
to manufacturers selling these LIPs to the general public without obtaining a variance 
approval from the FDA. 
(d) The following situations apply to LIPs that are in RG3, meet the descriptions in Section 
III, and are measured, classified and certified according to the procedures in paragraphs 
(a) and (b) of this section: 
(i)  CDRH considers LIPs that are in RG3 to be demonstration laser products 
equivalent to Laser Classes IIIb or IV (IEC 60825-1 Ed. 3 Class 3B or 4) that are 
                                                          
9 https://www.fda.gov/media/72593/download 
6 Contains Nonbinding Recommendations 
defined under 21 CFR 1040.10(b)(9)-(11).  Laser products in these classes exceed 
the Class IIIa limit for demonstration laser products in 21 CFR 1040.11(c).  When 
demonstration laser products are Class IIIb or IV, a variance approval by FDA is 
required under 21 CFR 1010.4 that permits the laser product to exceed the 
demonstration laser product class limit of IIIa.  For variance approvals under 21 
CFR 1010.4 of such RG3 LIPs products, FDA generally makes the approvals 
conditional on the laser products being sold only to manufacturers of laser light 
shows currently holding a valid variance or to cinema theater operators. 
(ii)  FDA also generally makes variance approvals under 21 CFR 1010.4 for RG3 
LIPs conditional on the display of the warning specified in IEC 62471-5:Ed. 1. 
No direct exposure to beam shall be permitted on RG 3 LIPs products RG label 
and a symbol representing or a label stating Not for household use. 
(iii)  FDA will also generally make approvals of variances for RG3 LIPs subject to the 
condition that user information include installation instructions that include 
directions that specify mounting the projector high enough to provide clearance 
for people who may walk beneath the beam path or establishing a restricted 
access area that extends beyond the beam hazard distance.  For Class IIIb or IV 
LIPs, submit a variance request in accordance with 21 CFR 1010.4.  The variance 
application must provide the submission information requirements specified in 21 
CFR 1010.4(b). 
(iv)  Submit product reports and annual reports and comply with all other reporting and 
recordkeeping requirements under 21 CFR 1002.  Product reports for LIPs will 
document how the product meets the descriptions in Section III, was measured, 
classified, and certified according to the procedures in paragraphs (a) and (b) of 
this section, and complies with the requirements of 21 CFR 1010, 21 CFR 
1040.10, and 21 CFR 1040.11.  The manufacturer may use Form FDA 3632 
Guide for Preparing Product Reports for Lasers and Products Containing 
Lasers10 to submit these reports. 
(v)  Cinema theaters in which RG3 LIPs are in use do not need to have a variance 
approval to use the projector because the LIP manufacturers variance has a 
condition of approval under 21 CFR 1010.4 that adequate instructions for the 
cinema theater to implement a safe installation under any reasonably foreseeable 
uses be provided.  
(vi)  Subclause 3.14 of IEC 62471-5:Ed. 1 defines a Hazard Distance that is collinear 
to the optical projection axis.  The optical projection axis may be tilted with 
respect to the optical axis of the projection lens.  The Hazard Distance alone does 
not sufficiently describe a 3-dimensional Hazard Zone.  The Hazard Zone 
encompasses a region of space that is considered RG3. 
                                                          
10 https://www.fda.gov/media/72593/download 
7 Contains Nonbinding Recommendations 
a.  RG3 LIPs for fixed installation at locations other than cinema theaters should 
be installed at a height not lower than 3 m vertically.  The lowest tip of the 
Hazard Zone should be no lower than 3 m measured vertically above the floor.  
Horizontal clearance to the Hazard Zone should be 2.5 m measured 
horizontally.  Any human access to the Hazard Zone, if applicable, is to be 
restricted by barriers.  Manufacturers of RG3 LIPs should assure that the fixed 
installation is performed by authorized installers, who are trained to perform 
installations in accordance with the manufacturers instructions. 
b.  RG3 LIPs that prevent human access to the Hazard Zone (v) by use of a 
engineering controls (see IEC 62471-5:Ed. 1 (6.4.2)) will not require a 
variance application. 
(vii)  RG3 LIPs may be distributed to laser light show manufacturers possessing a 
variance approval to produce laser light shows (LLS).  The conditions of approval 
for using LIPs in LLSs are provided in LLS variance-granting letters. 
Summary of exceptions or additions to IEC 62471-5:Ed. 1: 
IEC 62471-5  Description  Exception or Addition and Reason 
Subclause 
4.1  RG2 projector application  Exception as FDA does not consider 
safe in all applications 
5.2.1  Measurement throw ratio  Not applicable 
6.5.2  RG0 label  Label required 
6.5.3  RG1 label  Label required, not optional 
6.5.4  RG2 additional label  Additional warning against eye 
exposure for close exposures less than 
1 m 
6.6.3.1  General user information  Additional instructions to supervise 
children, no staring, and not use optical 
aids 
6.6.3.4  User warnings specific to  Additional instructions to install above 
brightest RG2 projectors  the reach of children 
8 Contains Nonbinding Recommendations 
Appendix A. 
FDAs concerns over the Risk Group Classification system used for LIPs: 
Both IEC 62471:First edition and IEC 62471-5:Ed. 1 define a hazard-based risk classification 
system that is equivalent to that of 21 CFR 1040.10.  The laser risk Class IIIa (21 CFR 
1040.10(b)(8)) has served as a transitional risk-based hazard class to the more hazardous Classes 
IIIb and IV.  Class III (both IIIa and IIIb) accessible radiation levels can produce biological 
damage to human tissue resulting from accidental exposure.  Laser Class IIIa radiation is an 
acceptable risk for many products but has not been recognized by FDA as safe for use by 
children (see Risk of Eye and Skin Injuries from Hand-held Lasers: FDA Safety Communication, 
Dec. 22, 2015).11  The brightest RG2 products require additional warnings and installation 
instructions to protect children from reasonably foreseeable exposures that could occur if the 
products were installed on tabletops or mobile carts.  FDA recommends against installing the 
brightest (see Section (IV)(b)(v) of this guidance) RG2 projectors on tabletops or carts because 
such locations place the projection lens near eye-heights for children.  FDA notes that Subclause 
6.4.2 of IEC 62471-5:Ed. 1 Power reduction by sensor system can be considered effective for 
reducing the risk of hazardous light exposure and may enhance projector safety.  FDA does not 
object to the use of power-reduction sensors in place of warning labels and user instructions 
specified in Section (IV)(b)(v) of this guidance for RG2 projectors. 
                                                          
11 http://wayback.archive-
it.org/7993/20170722040812/https:/www.fda.gov/MedicalDevices/Safety/AlertsandNotices/ucm478707.htm 
9