In brief
  • January guidance kept low risk wellness products outside strict device enforcement
  • August Class I recall pulled 20,160 Luna sleep therapy units over firmware
  • North America medical wellness market sits at US$44.4 billion for 2026

Products sold only to support healthy habits remain outside strict medical device enforcement when risk stays low. The Food and Drug Administration restated that position in revised guidance dated January 6, 2026, which set context for the August 19, 2026 Class I recall of 20,160 BMC Luna G3 APAP Model LG3600 units in the United States.

The document carries the title General Wellness: Policy for Low Risk Devices. It supersedes the 2019 guidance and addresses low risk products that support a healthy lifestyle.

Software features designed purely to maintain or encourage healthy living, with no link to diagnosis, cure, mitigation, prevention or treatment, fall outside the medical device definition under Section 520(o)(1)(B). Products that are not software with that same purpose get enforcement discretion, which means the agency does not plan to enforce requirements under the Federal Food, Drug, and Cosmetic Act.

Drugs, biologics, dietary supplements, foods, cosmetics handled by other FDA Centers and combination products stay outside the policy. Non-invasive products that estimate blood pressure for wellness purposes may qualify when the intended use remains strictly wellness related and other criteria are satisfied.

A wearable that estimates blood glucose to track nutritional effects may qualify when it is specifically contraindicated for people with diabetes and pre-diabetes. A blood glucose wearable that relies on minimally invasive microneedle technology does not count as low risk even when its claims stay purely wellness based.

Sensor based wellness products lose general wellness status when they suggest particular clinical steps, provide treatment direction, or measure for screening, diagnosis, monitoring or management of disease. They also lose that status when they claim to replace an FDA cleared device or when they mention particular diseases or diagnostic thresholds.

The Luna G3 APAP recall illustrated where that boundary continues to hold. BMC Medical Co., Ltd. reported the action on July 15, 2026 after identifying a firmware defect, and FDA listed it under Recall Number Z-2979-2026.

Firmware version G3-2.00.76 could produce an error message followed by automatic shutdown and loss of therapy during high pressure, high respiratory rate and high peak flow. BMC moved firmware to version G3-2.00.77 for 20,160 units held at the United States importers warehouse from October through December 2024, then later found potentially up to 196 units may have missed the upgrade. BMC had gotten no complaints or serious adverse reports as of the September 8, 2026 notice. Whether any unupgraded units remain in use is not known.

Forecasts suggest steady expansion on the wellness side of that divide. The North America medical wellness devices market holds a value of US$44.4 billion in 2026 and is expected to reach US$71.8 billion by 2033 at a compound annual growth rate of 7.1 percent. The United States is expected to hold 80 percent market share in 2026, while Canada is called the fastest growing region.

Diabetic monitoring devices are projected to account for 37 percent of revenue share in 2026, and retail sales are anticipated to exceed 62 percent. Consumer grade devices still face questions about variable readings relative to hospital grade equipment, along with data privacy concerns.

Watch whether 2026 retail results align with forecasts, and how validation standards develop for everyday trackers that sit near beauty routines.

Written by

Heather Castellan

Heather looks after the brands Gloss Report works with and makes sure every sponsored page says so. She was a colour cosmetics buyer for seven years, which is where she learned how a shade range gets cut before it ever reaches the shelf.

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