EUTECNIQ Sciences

See every page on one mapArrow keys move through results · Enter opens · Esc closes

Advanced ingredient development Proposed service

A differentiated botanical ingredient is one whose identity, composition, process and evidence can all be checked

For companies that want a new or better botanical ingredient for supplements, foods, cosmetics or research: the proposed stages and gates, the rules and FDA notification record behind the route, and the documents a customer would receive.

Status. EUTECNIQ is in formation and has not yet developed an ingredient. The pathway below is its proposed working method. Toxicology, clinical studies and commercial manufacturing would be done by qualified partners.

1,365dated new dietary ingredient notifications on FDA's list, 1995 to February 2026
71 daysmedian from listed submission to FDA's listed response
82.3%of responses came within the 75-day window (21 CFR 190.6)
24CFR rule sets mapped for a bulk-ingredient developer with a laboratory and solvent extraction
The journey

Four kinds of partner bring a material, a market or a technology; each would leave with documents a buyer can test

Choose a partner to follow its path from the rules to the documents it would receiveProposed service flow
Rules link to eCFR or the U.S. Code. Stages and documents are EUTECNIQ proposals; EUTECNIQ has no laboratory yet, and none of these documents is an FDA certificate. Documents are described in the deliverables library.
Text version: partners, rules, stages and documents

Partners

  • Ingredient suppliers Hold a raw material or extract and need a specification, a data package and a route to U.S. buyers.
  • Brand owners Need an ingredient a competitor cannot match by buying the same plant powder.
  • International producers Grow or process a botanical abroad and need identity, safety and regulatory documents for the United States (see global ingredients).
  • Technology partners Have a delivery or process technology and need botanical applications, data and a licensing path.

Rules that shape the route

  • 21 CFR 190.6 New dietary ingredient notification, 75 days before marketing.
  • 21 CFR 170 Food additives and GRAS for food uses.
  • 21 CFR 111 Specifications and identity tests at the supplement maker.
  • 21 CFR 117 Food CGMP for ingredient-only plants.
  • 21 CFR 1, Subpart L Foreign supplier verification by the U.S. importer.
  • 21 CFR 101 Labeling and claims for foods and supplements.
  • 35 U.S.C. 101 What can be patented; products of nature cannot.

Development stages (proposed)

What the partner would receive

Founder experience Founder-reported

The founder reports prior industry work formulating botanical actives in liquid, emulsion, suspension and powder formats, running stability programs and transferring processes to contract manufacturers. That work belongs to his former employers and is not EUTECNIQ's. See the founder profile.

The problem

Two extracts sold under one plant name can differ in species, plant part, chemotype, solvent and composition

Eight pairs that are often treated as equal and are notScientific distinctions
Eight pairs of terms that are often treated as equal and are notSame botanical name≠ Same compositionExtraction yield≠ PurityHigher marker content≠ Higher biological activitySimilar chromatographicfingerprint≠ Equivalent ingredientStability testing≠ Validated shelf lifeIncreased bioavailability≠ Improved efficacyIncreased bioavailability≠ Reduced toxicityLaboratory feasibility≠ Commercial demonstrationEight pairs of terms that are often treated as equal and are notSame botanical name≠ Same compositionExtraction yield≠ PurityHigher marker content≠ Higher biological activitySimilar chromatographic fingerprint≠ Equivalent ingredientStability testing≠ Validated shelf lifeIncreased bioavailability≠ Improved efficacyIncreased bioavailability≠ Reduced toxicityLaboratory feasibility≠ Commercial demonstration
Distinctions used throughout this site; the evidence behind each is on the bioavailability, USP, ICH and COA and purification pages.
Text version of the eight pairs

Buyers cannot tell two extracts apart from a label. A differentiated ingredient closes that gap with documents a customer can test.

  • Same botanical name≠Same composition
  • Extraction yield≠Purity
  • Higher marker content≠Higher biological activity
  • Similar chromatographic fingerprint≠Equivalent ingredient
  • Stability testing≠Validated shelf life
  • Increased bioavailability≠Improved efficacy
  • Increased bioavailability≠Reduced toxicity
  • Laboratory feasibility≠Commercial demonstration
What can be developed

Six kinds of ingredient, each with its own technical risk and an early regulatory question

The regulatory question is listed because it decides which data the later stages must produce.

Six kinds of ingredient, with the technical risk and the first regulatory question for eachEUTECNIQ planning view
Six kinds of botanical ingredient with what defines each, its main technical risk and the regulatory question to answer earlyNovel botanical ingredientNo U.S. marketing history in the intended category.•Risk: Identity methods and safety data start fromlittle or nothing.•Ask early: New dietary ingredient, new foodsubstance, or both?Standardized extractControlled to a defined content of markerconstituents.•Risk: A marker chosen for easy analysis may nottrack the activity of interest.•Ask early: Does the process chemically alter it?FDA's view is still in draft guidance.Chemotype-specific ingredientPlants of one species whose dominant constituentsdiffer consistently.•Risk: The chemotype has to be confirmed lot bylot at the source.•Ask early: Does the cited history of use apply tothis chemotype?Enriched fractionConcentrated in one constituent class by resins,partitioning or membranes.•Risk: Unwanted constituents concentrate too;yield falls as purity rises.•Ask early: Does existing safety evidence coverthe new intake?Delivery-enabled formBuilt into an emulsion, spray-dried powder,encapsulate or phospholipid complex.•Risk: Physical stability in the product; evidencefor any performance claim.•Ask early: Excipient status; is it a nanomaterial?FDA asks to be contacted first.Taste-engineered formModified to reduce bitterness or astringency.•Risk: Masking can slow release and changeexposure.•Ask early: Are the masking agents lawful in thecategory?Six kinds of botanical ingredient with what defines each, its main technical risk and the regulatory question to answer earlyNovel botanical ingredientNo U.S. marketing history in the intended category.•Risk: Identity methods and safety data start from little ornothing.•Ask early: New dietary ingredient, new food substance,or both?Standardized extractControlled to a defined content of marker constituents.•Risk: A marker chosen for easy analysis may not trackthe activity of interest.•Ask early: Does the process chemically alter it? FDA'sview is still in draft guidance.Chemotype-specific ingredientPlants of one species whose dominant constituents differconsistently.•Risk: The chemotype has to be confirmed lot by lot atthe source.•Ask early: Does the cited history of use apply to thischemotype?Enriched fractionConcentrated in one constituent class by resins,partitioning or membranes.•Risk: Unwanted constituents concentrate too; yield fallsas purity rises.•Ask early: Does existing safety evidence cover the newintake?Delivery-enabled formBuilt into an emulsion, spray-dried powder, encapsulate orphospholipid complex.•Risk: Physical stability in the product; evidence for anyperformance claim.•Ask early: Excipient status; is it a nanomaterial? FDAasks to be contacted first.Taste-engineered formModified to reduce bitterness or astringency.•Risk: Masking can slow release and change exposure.•Ask early: Are the masking agents lawful in thecategory?
Regulatory questions: FDA draft NDI guidance (2016 revised draft; Section IV.B still draft as of October 2026); FDA final NDI identity and safety guidance (October 2026), Section VIII.2 on nanomaterials.
Show the table (6 rows): Ingredient types with their defining feature, main technical risk and the regulatory quest
Ingredient types with their defining feature, main technical risk and the regulatory question to answer early.
Ingredient typeWhat defines itMain technical riskRegulatory question to answer early
Novel botanical ingredientA species, plant part or preparation with no U.S. marketing history in the intended category.Identity methods and safety data start from little or nothing.Is it a new dietary ingredient, a new food substance, or both? Each has its own route.
Standardized extractAn extract controlled to a defined content of one or more marker constituents.A marker chosen for easy analysis may not track the activity of interest.Does the process chemically alter the ingredient compared with its marketed form? FDA's view on "chemically altered" is still in draft guidance.
Chemotype-specific ingredientMaterial from plants of one species whose dominant constituents differ consistently from other plants of that species.The chemotype has to be confirmed lot by lot at the source.Does the cited history of use apply to this chemotype?
Enriched fractionA fraction concentrated in one constituent class by separation, such as adsorption resins, liquid-liquid partitioning or membranes.Enrichment can concentrate unwanted constituents too, and yield falls as purity rises.Concentration changes intake. Does the existing safety evidence cover the new exposure?
Delivery-enabled formThe ingredient built into an emulsion, spray-dried powder, encapsulate or phospholipid complex.Physical stability in the final product, and evidence for any performance claim.Do the added excipients have the right status for the category? Is the result a nanomaterial? For nanomaterial forms FDA recommends contacting it before a new dietary ingredient notification.
Taste-engineered formAn ingredient modified to reduce bitterness or astringency.Masking can slow release and change exposure.Are the masking agents lawful in the intended category?

Regulatory notes: FDA draft guidance, "Dietary Supplements: New Dietary Ingredient Notifications and Related Issues" (2016 revised draft; Section IV.B still draft as of October 2026); FDA final guidance, "NDI Notifications and Related Issues; Identity and Safety Information About the NDI" (October 19, 2026), Section VIII.

Development pathway

Eight stages, each ending in a written decision

Each stage produces a document a customer can audit; a stage passes only when its gate is met.

Eight stages, eight written gates, and who would do the work at eachProposed method
Eight proposed development stages from target profile to transfer, each with its aim, measurements, output, written gate and who would do the work1. Target profile2. Source and identity3. Composition and hazards4. Extraction and enrichmentEUTECNIQ + customerWork•Aim: intended use, market, format,daily amount, claim to test•Measures: literature, regulatoryreview, competing specifications•Output: target profile; routehypothesisGate 1•A lawful route exists and the profileis technically plausibleEUTECNIQHerbarium, DNA labsWork•Aim: species, plant part, chemotype;supplier qualified•Measures: macroscopy,microscopy, HPTLC, DNA assupport, voucher•Output: identity file; supplier recordGate 2•Identity confirmed by orthogonalmethods on representative lotsEUTECNIQContract labs at firstWork•Aim: what it contains and must notcontain•Measures: LC-MS, HPLC-DAD,markers, ICP-MS, pesticides,mycotoxins, microbiology•Output: composition profile; hazardscreenGate 3•No intrinsic hazard at the intendedexposure that processing cannotremoveEUTECNIQWork•Aim: reach the target compositionevery time•Measures: solvent screen, yield andpurity per step, mass balance,residual solvents•Output: process description; labbatchesGate 4•Target composition in replicatebatches, acceptable yield andsolvent residues5. Formulation and delivery6. Stability and specification7. Safety and regulatory route8. Scale-up, IP and transferEUTECNIQWork•Aim: dispersion, dose, taste andstability in the format•Measures: solubility, dispersibility,size, zeta potential, dissolution,sensory•Output: prototypes with physical andsensory dataGate 5•Prototype meets physical andsensory targets in the intendedproductEUTECNIQWork•Aim: limits every lot must meet;change over time•Measures: real-time and acceleratedstability, degradation products•Output: specification, methods,stability protocolGate 6•Pilot lots meet the specification; nounexplained stability trendEUTECNIQ strategyCROs, counselWork•Aim: safety basis for the intendeduse and market•Measures: exposure, history of use,toxicology where gaps require•Output: route memo; safety dossieror notification draftGate 7•Evidence supports the intended useat the intended exposureCMOs, patent counselEUTECNIQ comparabilityWork•Aim: commercial scale; protect whatis new•Measures: comparability of lab, pilotand commercial lots•Output: transfer package, inventiondisclosures, filings where justifiedGate 8•Commercial lots comparable todevelopment lots; freedom tooperate reviewedWritten gate: pass, stop or loop back. Teal pills: EUTECNIQ's own scientists once its laboratory exists. Dashed: partners.Eight proposed development stages from target profile to transfer, each with its aim, measurements, output, written gate and who would do the work1Target profileWork•Aim: intended use, market, format, daily amount,claim to test•Measures: literature, regulatory review, competingspecifications•Output: target profile; route hypothesisGate 1•A lawful route exists and the profile is technicallyplausibleEUTECNIQ + customer2Source and identityWork•Aim: species, plant part, chemotype; supplierqualified•Measures: macroscopy, microscopy, HPTLC, DNA assupport, voucher•Output: identity file; supplier recordGate 2•Identity confirmed by orthogonal methods onrepresentative lotsEUTECNIQHerbarium, DNA labs3Composition and hazardsWork•Aim: what it contains and must not contain•Measures: LC-MS, HPLC-DAD, markers, ICP-MS,pesticides, mycotoxins, microbiology•Output: composition profile; hazard screenGate 3•No intrinsic hazard at the intended exposure thatprocessing cannot removeEUTECNIQContract labs at first4Extraction and enrichmentWork•Aim: reach the target composition every time•Measures: solvent screen, yield and purity per step,mass balance, residual solvents•Output: process description; lab batchesGate 4•Target composition in replicate batches, acceptableyield and solvent residuesEUTECNIQ5Formulation and deliveryWork•Aim: dispersion, dose, taste and stability in theformat•Measures: solubility, dispersibility, size, zetapotential, dissolution, sensory•Output: prototypes with physical and sensory dataGate 5•Prototype meets physical and sensory targets in theintended productEUTECNIQ6Stability and specificationWork•Aim: limits every lot must meet; change over time•Measures: real-time and accelerated stability,degradation products•Output: specification, methods, stability protocolGate 6•Pilot lots meet the specification; no unexplainedstability trendEUTECNIQ7Safety and regulatory routeWork•Aim: safety basis for the intended use and market•Measures: exposure, history of use, toxicologywhere gaps require•Output: route memo; safety dossier or notificationdraftGate 7•Evidence supports the intended use at the intendedexposureEUTECNIQ strategyCROs, counsel8Scale-up, IP and transferWork•Aim: commercial scale; protect what is new•Measures: comparability of lab, pilot and commerciallots•Output: transfer package, invention disclosures,filings where justifiedGate 8•Commercial lots comparable to development lots;freedom to operate reviewedCMOs, patent counselEUTECNIQ comparability
EUTECNIQ proposal; it has not run these stages. Exposure and efficacy studies are optional and run alongside stages 05 to 07 when a claim needs them.
Text version: objective, measurements, output, gate and owner for each stage
Each development stage with its objective, key measurements, output, decision gate and who would do the work.
StageObjectiveKey measurementsOutputDecision gateWho does it
01 Target profileDefine the intended use, market, format, daily amount and the claim to be tested.Literature and regulatory review; specifications of competing ingredients.Target ingredient profile and a regulatory route hypothesis.A lawful route exists and the profile is technically plausible.EUTECNIQ with the customer
02 Source and identityConfirm species, plant part and chemotype where relevant; qualify the supplier.Macroscopy and microscopy, HPTLC fingerprint, DNA methods as support, voucher specimen.Identity file and supplier qualification record.Identity confirmed by orthogonal methods on representative lots.EUTECNIQ; herbarium and DNA laboratories as partners
03 Composition and hazardsKnow what the material contains and what it must not contain.LC-MS and HPLC-DAD profiles, marker assays, elemental impurities by ICP-MS, pesticide residues, mycotoxins, microbiology.Composition profile and hazard screen.No intrinsic hazard at the intended exposure that processing cannot remove.EUTECNIQ; contract laboratories until in-house methods exist
04 Extraction and enrichmentDesign a process that reaches the target composition every time.Solvent screening, yield and purity at each step, mass balance, residual solvents.Process description, laboratory batches and mass balance.Target composition reached in replicate batches with acceptable yield and solvent residues.EUTECNIQ
05 Formulation and deliveryMake the ingredient work in its format: dispersion, dose, taste and stability.Solubility and dispersibility, particle or droplet size, zeta potential, dissolution, sensory panels.Prototype forms with physical and sensory data.The prototype meets physical and sensory targets in the intended product.EUTECNIQ
06 Stability and specificationSet the limits every lot must meet and learn how the ingredient changes over time.Real-time and accelerated stability: assay, degradation products, physical attributes.Specification, test methods, stability protocol and interim data.Pilot lots meet the specification, with no unexplained trend in stability data.EUTECNIQ
07 Safety and regulatory routeBuild the safety basis for the intended use in the intended market.Exposure estimate, history-of-use evidence, toxicology studies where the gaps require them.Regulatory route memo; safety dossier or notification draft.The evidence supports the intended use at the intended exposure.EUTECNIQ for strategy and dossier; contract research organizations for toxicology; regulatory counsel
08 Scale-up, IP and transferMove the process to commercial scale and protect what is new.Comparability of laboratory, pilot and commercial lots.Technology-transfer package, invention disclosures, patent filings where justified.Commercial lots are comparable to development lots; freedom to operate has been reviewed.Contract manufacturers and patent counsel; EUTECNIQ for comparability

"EUTECNIQ" means work planned for its own scientists once its laboratory exists; "partner" means qualified external organizations.

Specification

A specification turns a botanical into an ingredient that can be bought, tested and released

The skeleton that 21 CFR 111.70(e) requires for supplements serves the other markets too.

Six attributes define what every lot must meet, each with its methods21 CFR 111.70(e) Proposed methods
A botanical ingredient specification as six attributes around one release decision, each with what it controls and the methods EUTECNIQ proposes; the identity method is one the customer can repeatIngredient specificationLimits every lot must meet before releaseSupplements: identity, purity, strength,composition and contamination limits (21 CFR111.70(e))IdentityThe right species, plant part and preparation•Methods: Macroscopy, microscopy; HPTLC or LCfingerprint against reference materialPurityNo adulterants or unintended constituents•Methods: Orthogonal fingerprints, targetedadulterant screensStrengthContent of the defined marker or activeconstituents•Methods: HPLC with UV, diode-array or MSdetection, validated for the matrixContaminant limitsElemental impurities, pesticides, mycotoxins,residual solvents, microorganisms•Methods: ICP-MS; LC-MS/MS, GC-MS/MS;headspace GC; culture microbiologyCompositionPattern of constituent classes, extraction solvent,any carrier•Methods: Fingerprint similarity, loss on drying,carrier contentPhysical attributesParticle size, bulk density, moisture, dispersibility•Methods: Laser diffraction, bulk and tappeddensity, loss on drying, dispersion testsA supplement maker must run at least one appropriate identity test on every dietary ingredient before use (21 CFR 111.75(a)(1)(i)), so the specification wouldinclude an identity method the customer can repeat in its own laboratory.Six specification attributes with methodsIngredient specificationLimits every lot must meet21 CFR 111.70(e). Identity method repeatable by thecustomer (111.75(a)(1)(i)).IdentityThe right species, plant part and preparation.Methods: Macroscopy, microscopy; HPTLC or LCfingerprint against reference materialStrengthContent of the defined marker or active constituents.Methods: HPLC with UV, diode-array or MS detection,validated for the matrixCompositionPattern of constituent classes, extraction solvent, anycarrier. Methods: Fingerprint similarity, loss on drying,carrier contentPurityNo adulterants or unintended constituents. Methods:Orthogonal fingerprints, targeted adulterant screensContaminant limitsElemental impurities, pesticides, mycotoxins, residualsolvents, microorganisms. Methods: ICP-MS;LC-MS/MS, GC-MS/MS; headspace GC; culturemicrobiologyPhysical attributesParticle size, bulk density, moisture, dispersibility.Methods: Laser diffraction, bulk and tapped density,loss on drying, dispersion tests
21 CFR 111.70(e) and 111.75(a)(1)(i), eCFR current to October 21, 2026. Method choices are EUTECNIQ proposals.
Text version of the specification attributes
Specification attributes, what each controls, and the methods EUTECNIQ proposes to use.
AttributeWhat it controlsMethods EUTECNIQ proposes
IdentityThe right species, plant part and preparation.Macroscopy and microscopy; HPTLC or LC fingerprint against reference material.
StrengthContent of the defined marker or active constituents.HPLC with UV, diode-array or mass-spectrometric detection, validated for the matrix.
CompositionThe pattern of constituent classes, the extraction solvent and any carrier.Fingerprint similarity, loss on drying, carrier content.
PurityAbsence of adulterants and unintended constituents.Orthogonal fingerprints and targeted adulterant screens.
Contaminant limitsElemental impurities, pesticide residues, mycotoxins, residual solvents and microorganisms.ICP-MS; LC-MS/MS and GC-MS/MS; headspace GC; culture-based microbiology.
Physical attributesParticle size, bulk density, moisture and dispersibility.Laser diffraction, bulk and tapped density, loss on drying, dispersion tests.

A supplement maker must run at least one appropriate identity test on every dietary ingredient before use (21 CFR 111.75(a)(1)(i)). A well-built ingredient specification therefore includes an identity method the customer can repeat in its own laboratory.

Comparability

When the process changes, comparability data show whether the ingredient changed with it

Scale-up, a new supplier or a new solvent can shift composition.

Compare before accepting: five attributes, one predefined acceptance limitProposed protocol FDA guidance
A comparability protocol, written before a process change, compares five attributes of old and new lots against a predefined acceptable difference; three FDA documents explain why regulators careA changeProtocol written before the change: compare•Chromatographic fingerprints and their similarity•Ratios between marker constituents, not only totals•Impurity and contaminant profiles•Physical attributes that affect the finished product•Early stability trends of the new lotsScale-upNew supplierNew solventWithin thepredefinedacceptabledifference?ComparableChanged lots accepted as thesame ingredientThe ingredient changedRegulatory status may need tobe reassessedYesNoWhy regulators careDraft guidanceFDA's 2016 revised draft NDI guidance discusseswhen a manufacturing change creates a newdietary ingredient (still draft)Final guidance, 2014Consult FDA about a significant manufacturingchange to a food substance on the market,especially with nanotechnologyFinal guidance, 2016Botanical drugs: batch consistency linked toconsistent effect through the totality of theevidenceComparability protocol and why regulators careA changeScale-up, a new supplier or a new solventProtocol written before the change: compare•Chromatographic fingerprints and their similarity•Ratios between marker constituents, not only totals•Impurity and contaminant profiles•Physical attributes that affect the finished product•Early stability trends of the new lotsDecisionWithin the predefined acceptable difference? Yes:changed lots accepted. No: the ingredient changed;regulatory status may need reassessment.Draft guidanceFDA's 2016 revised draft NDI guidance discusseswhen a manufacturing change creates a new dietaryingredient (still draft)Final guidance, 2014Consult FDA about a significant manufacturing changeto a food substance on the market, especially withnanotechnologyFinal guidance, 2016Botanical drugs: batch consistency linked toconsistent effect through the totality of the evidence
FDA draft NDI guidance (docket FDA-2011-D-0376, October 2026 version), Section IV.A; FDA, Assessing the Effects of Significant Manufacturing Process Changes (June 2014, FDA-2011-D-0490); FDA, Botanical Drug Development (December 2016, Revision 1).
Text version of the protocol and the guidance

What a comparability protocol compares Proposal

  • Chromatographic fingerprints and their similarity.
  • Ratios between marker constituents, not only their totals.
  • Impurity and contaminant profiles.
  • Physical attributes that affect the finished product.
  • Early stability trends of the new lots.

Why regulators care

  • Draft guidance FDA's 2016 revised draft NDI guidance discusses when a manufacturing change creates a new dietary ingredient. That section is still draft as of October 2026.
  • Final guidance FDA's June 2014 guidance on significant manufacturing process changes recommends consulting FDA about such a change to a food substance already on the market, especially when it involves an emerging technology such as nanotechnology.
  • Final guidance For botanical drugs, FDA links batch consistency to consistent therapeutic effect through a "totality of the evidence" approach (December 2016).

Sources: FDA draft NDI guidance (docket FDA-2011-D-0376, October 2026 version), Section IV.A; FDA, "Assessing the Effects of Significant Manufacturing Process Changes…" (June 2014, docket FDA-2011-D-0490); FDA, "Botanical Drug Development" (December 2016, Revision 1).

Delivery, stability, taste

Delivery, stability and taste are engineered from the molecule's own properties

A carrier is chosen after the active's solubility, stability and dose are known, then tested in the final product.

Four distinctions decide the delivery, stability and taste workPublished science
Four distinctions behind delivery, stability and taste: solubility versus dispersibility; thermodynamically stable microemulsions versus kinetically stable nanoemulsions and amorphous dispersions; chemical degradation versus physical separation; taste masking versus releaseDelivery: solubility is not dispersibilitySolution: molecules dissolvedSolubility: how much dissolvesDispersion: droplets or particlesDispersibility: how well they stay spreadThey need different fixes.Stable, or only slow to break downFree energySeparated phases or crystalsMicroemulsionthermodynamically stableNanoemulsion oramorphousdispersionBreakdown or recrystallization:slow, but downhillMcClements 2012; Bhujbal et al. 2021. Schematic, not to scale.Stability: two different failures, two different testsChemical degradationOxidation, hydrolysisRead by the assay and bydegradation productsPhysical separationCreaming, cakingRead by appearance, size andphysical attributesStability testing produces data. A shelf life is a conclusion drawn fromdata on the final product in its package.Taste: masking can slow releaseBitter or astringentactiveMany polyphenolsand alkaloidsMaskingEncapsulation,complexation orflavor systemsTwo checksTrained sensorypanel anddissolution testA coating that hides taste can also slow release, which can changeexposure.Delivery, stability and taste distinctionsDeliverySolubility is not dispersibilitySolubility is how much dissolves; dispersibility is howwell particles or droplets stay spread. They needdifferent fixes.DeliveryStable, or only slow to break downMicroemulsions are thermodynamically stable.Nanoemulsions are not and persist only becausebreakdown is slow. Amorphous solid dispersions raiseapparent solubility; recrystallization is their main risk.StabilityTwo different failuresChemical degradation (oxidation, hydrolysis) andphysical separation (creaming, caking) need differenttests. Stability testing produces data; a shelf life is aconclusion drawn from data on the final product in itspackage.TasteMasking can slow releaseEncapsulation, complexation or flavor systems hidebitterness; each would be checked with a trainedsensory panel and a dissolution test.
Schematic, not to scale. Taste-masking checks are EUTECNIQ proposals.McClements 2012, Soft Matter 8:1719; Bhujbal et al. 2021, Acta Pharm Sin B 11:2505; FDA, Small Entity Compliance Guide for 21 CFR Part 111 (December 2010). More on the delivery and emulsions pages.
Text version of the four distinctions

Delivery

Solubility is how much dissolves. Dispersibility is how well particles or droplets stay spread through a liquid. They need different fixes.

Microemulsions are thermodynamically stable; nanoemulsions are not, and persist only because breakdown is slow. Amorphous solid dispersions raise apparent solubility, and recrystallization is their main risk.

McClements 2012, Soft Matter 8:1719; Bhujbal et al. 2021, Acta Pharm Sin B 11:2505. More on the delivery and emulsions pages.

Stability

Chemical degradation, such as oxidation or hydrolysis, and physical separation, such as creaming or caking, are different failures with different tests.

Stability testing produces data. A shelf life is a conclusion drawn from data on the final product in its package. Part 111 does not require an expiration date, but FDA says a firm should have data to support any date it puts on a label.

FDA, Small Entity Compliance Guide for 21 CFR Part 111 (December 2010), citing 72 FR 34752 at 34855.

Taste and sensory Proposal

Many polyphenols and alkaloids are bitter or astringent. Masking options include encapsulation, complexation and flavor systems.

Each option would be checked with trained sensory panels and with dissolution testing, because a coating that hides taste can also slow release.

Bioavailability research

Bioavailability research measures exposure, and exposure alone establishes neither efficacy nor safety

A formulation can improve one step between dose and outcome and leave the others unchanged.

From dose to outcome: what each kind of study can showEstablished pharmacology
  1. Dose in the productLabel amount and assay
  2. ReleaseDisintegration and dissolution tests
  3. Bioaccessible fractionIn vitro digestion, for example INFOGESTBioaccessibility
  4. Absorption and first-pass metabolismCell permeability models; metabolism assays
  5. Systemic exposureHuman pharmacokinetic study: AUC and CmaxBioavailability
  6. Effect at the targetMechanism and biomarker studies
  7. Health outcomeRandomized, controlled human trialEfficacy
Each step can fail on its own. Raising exposure helps only when exposure was the limiting step. It also raises exposure to any harmful constituent, and an enhancer that works by blocking metabolism can change how other drugs are handled. Brodkorb et al. 2019, Nat Protoc 14:991 (INFOGEST static digestion method).
Piperine raised serum curcumin by blocking a clearance step that some drugs sharePeer-reviewed
Piperine inhibits glucuronidation, which raised serum curcumin in healthy volunteers; in laboratory studies it also inhibits P-glycoprotein and CYP3A4, so the same mechanism could raise exposure to drugs taken at the same timeDose2 g curcumin with 20 mgpiperine, healthy volunteers(Shoba et al. 1998)Gut wall and liverGlucuronidationConjugates curcumin in the liver andintestineP-glycoproteinDrug efflux transporterCYP3A4Drug-metabolizing enzymePiperineMore curcumin in serumThe authors reported a 2000% increasein bioavailabilityPossible higher exposure toco-administered drugsThe same mechanism; laboratoryevidence (Bhardwaj et al. 2002)Inhibition given as the mechanism of the human resultInhibition found in laboratory studiesExposure is not efficacy, and higher exposure includes exposure to any harmful constituent.Piperine and curcumin: mechanism and interaction riskDose2 g curcumin with 20 mg piperine in healthy volunteers(Shoba et al. 1998)Piperine inhibits•Glucuronidation of curcumin (shown in the humanstudy)•P-glycoprotein, a drug efflux transporter (laboratorystudies)•CYP3A4, a drug-metabolizing enzyme (laboratorystudies; Bhardwaj et al. 2002)ResultSerum curcumin rose; the authors reported a 2000%increase in bioavailabilityRiskThe same mechanism could raise exposure to drugstaken at the same time
Shoba et al. 1998, Planta Med 64:353; Bhardwaj et al. 2002, J Pharmacol Exp Ther 302:645.
Text version of the piperine example and the transfer problem

A worked example: piperine and curcumin Peer-reviewed

In a 1998 study, 20 mg of piperine given with 2 g of curcumin raised serum curcumin in healthy volunteers. The authors reported a 2000% increase in bioavailability.

Piperine inhibits glucuronidation. In laboratory studies it also inhibits the human drug transporter P-glycoprotein and the enzyme CYP3A4. The mechanism that raises curcumin exposure could therefore raise exposure to drugs taken at the same time.

Shoba et al. 1998, Planta Med 64:353; Bhardwaj et al. 2002, J Pharmacol Exp Ther 302:645.

Why published numbers rarely transfer

Reported gains for curcumin formulations vary with the product, the comparator, the dose and the analytical method. One review flags hydrolysis of plasma samples, which measures conjugates together with free curcumin, as an inappropriate practice.

For nanomaterial forms, FDA's October 2026 NDI guidance says data on the non-nano version are unlikely to address safety concerns specific to the nanomaterial.

Jamwal 2018, J Integr Med 16:367; Stohs et al. 2020, Molecules 25:1397; FDA final NDI identity and safety guidance (October 19, 2026), Section VIII.

Explanation, details and sources

Why published numbers rarely transfer. Reported gains for curcumin formulations vary with the product, comparator, dose and analytical method; one review flags hydrolysis of plasma samples, which measures conjugates with free curcumin, as an inappropriate practice. For nanomaterial forms, FDA's October 2026 NDI guidance says data on the non-nano version are unlikely to address nanomaterial-specific safety concerns.

Jamwal 2018, J Integr Med 16:367; Stohs et al. 2020, Molecules 25:1397; FDA final NDI identity and safety guidance (October 19, 2026), Section VIII.

Proposal EUTECNIQ would report exposure studies as exposure studies, name the analyte measured (free or total), and not turn a pharmacokinetic result into an efficacy or safety claim. Human studies would run at qualified clinical sites under IRB oversight; see clinical research.

Regulatory strategy

The regulatory route is chosen before the expensive studies, because it decides which studies count

The same extract can need a different safety package in each market. Stage 01 fixes the market; stage 07 builds the evidence that market expects.

FDA's list holds 1,365 dated new dietary ingredient notifications since 1995, and its responses cluster just inside the 75-day windowFDA data
FDA's list gives dates, not outcomes, so acknowledgments and objections are not separated. Days are the listed response date minus the listed submission date; a filing date can differ from the submission date, and a substantive amendment restarts the 75 days (21 CFR 190.6(d)). 2026 is a partial year.FDA, Submitted 75-Day Premarket Notifications for New Dietary Ingredients, List of NDINs 1995 to the Present (XLSX; page content current as of July 10, 2026; read October 24, 2026). Seven entries without a submission date are excluded. Counted by EUTECNIQ.
Data tables: notifications per year and days to response
Notifications on FDA's NDIN list by calendar year of submission (1,365 with dates; 2026 is partial)
19951996199719981999200020012002200320042005200620072008200920102011201220132014201520162017201820192020202120222023202420252026
Notifications2814192431205364435764734047534942334048609342335442334559719
Days from listed submission date to listed FDA response date (1,359 notifications; median 71 days; 82.3% within 75 days)
0-30 days31-45 days46-60 days61-75 days76-90 days91-120 days>120 days
Notifications96611348281275756
Twenty-four CFR rule sets touch a bulk-ingredient developer that runs a laboratory and extracts with solventseCFR counts

Area is the number of sections in eCFR, a measure of length, not of importance; "*" marks rules that apply only in the circumstances they name. Select a part to open it in eCFR.Applicability as mapped on the CFR atlas; section counts from the eCFR API, up to date as of October 21, 2026. Orientation, not legal advice.
Data table: every rule set in the treemap
CFR parts for a bulk-ingredient developer: A bulk-ingredient developer with a laboratory and solvent extraction (eCFR section counts)
Rule setWhat it coversAgency groupeCFR sectionsLevel
21 CFR Part 111Current Good Manufacturing Practice in Manufacturing, Packaging, Labeling, or Holding Operations for Dietary Supplements. CGMP for anyone who makes, packages, labels or holds a dietary supplement, including identity tests of dietary ingredients.FDA · 21 CFR84Check
21 CFR Part 117Current Good Manufacturing Practice, Hazard Analysis, and Risk-Based Preventive Controls for Human Food. CGMP, hazard analysis and preventive controls for human food, including dietary ingredients.FDA · 21 CFR61Applies
21 CFR Part 101Food Labeling. Food labels: Supplement Facts (§ 101.36), health claims (§ 101.14) and structure/function statements (§ 101.93).FDA · 21 CFR50Check
21 CFR Part 1, Subpart RLaboratory Accreditation for Analyses of Foods. Certain food tests, such as tests to support admission of an import, must be run by a LAAF-accredited laboratory.FDA · 21 CFR42Check
21 CFR Part 58Good Laboratory Practice for Nonclinical Laboratory Studies. Good laboratory practice for nonclinical studies supporting the FDA submissions listed in § 58.3; NDINs are not listed.FDA · 21 CFR36Check
21 CFR Part 1, Subpart OSanitary Transportation of Human and Animal Food. Shippers, loaders, carriers and receivers keep food safe during transport; § 1.900(b) lists exempt operations.FDA · 21 CFR18Check
21 CFR Part 1, Subpart HRegistration of Food Facilities. Facilities that make, process, pack or hold food for U.S. consumption register with FDA and renew every two years.FDA · 21 CFR14Applies
21 CFR Part 1, Subpart JEstablishment, Maintenance, and Availability of Records. Keep records of the immediate previous source and the immediate subsequent recipient of food.FDA · 21 CFR13Applies
21 CFR Part 173, Subpart CSecondary Direct Food Additives Permitted in Food for Human Consumption. Residue limits for extraction solvents in named foods, such as hexane at 25 ppm in spice oleoresins.FDA · 21 CFR11Check
21 CFR Part 7, Subpart CEnforcement Policy. FDA's recall policy: recalls are voluntary actions, classified by health hazard, with a recall strategy.FDA · 21 CFR10Check
21 CFR Part 11Electronic Records; Electronic Signatures. Electronic records and signatures that meet FDA record rules must be trustworthy, reliable and equivalent to paper.FDA · 21 CFR10Applies
21 CFR Part 190Dietary Supplements. A new dietary ingredient needs notification to FDA at least 75 days before marketing, unless the food-supply exception applies.FDA · 21 CFR1Check
40 CFR Part 180Tolerances and Exemptions for Pesticide Chemical Residues in Food. Tolerances and exemptions for pesticide residues in food; inert-ingredient exemptions are in §§ 180.910–180.960.EPA · 40 CFR755Applies
40 CFR Part 261Identification and Listing of Hazardous Waste. Which wastes are hazardous: ignitable wastes (§ 261.21) and listed wastes such as spent solvents (§ 261.31).EPA · 40 CFR83Check
40 CFR Part 262Standards Applicable to Generators of Hazardous Waste. Duties of hazardous-waste generators, scaled by generator category.EPA · 40 CFR66Check
29 CFR 1910.1200Hazard communication.. Hazard communication: hazard classification, labels, safety data sheets and worker training.OSHA · 29 CFR1Applies
29 CFR 1910.106Flammable liquids.. Storage and handling of flammable liquids, such as ethanol and hexane used in extraction.OSHA · 29 CFR1Applies
29 CFR 1910.119Process safety management of highly hazardous chemicals.. Process safety management, triggered for example by 10,000 lb of a flammable liquid with flash point below 100 °F in one process.OSHA · 29 CFR1Check
29 CFR 1910.132General requirements.. Workplace hazard assessment and personal protective equipment.OSHA · 29 CFR1Applies
29 CFR 1910.134Respiratory protection.. Respiratory protection programs where respirators are needed.OSHA · 29 CFR1Check
29 CFR 1910.147The control of hazardous energy (lockout/tagout).. Lockout/tagout of hazardous energy during servicing and maintenance of machines.OSHA · 29 CFR1Check
29 CFR 1910.307Hazardous (classified) locations.. Electrical equipment in hazardous (classified) locations, such as rooms with flammable vapors.OSHA · 29 CFR1Check
29 CFR 1910.1000Air contaminants.. Permissible exposure limits for air contaminants, such as solvent vapors.OSHA · 29 CFR1Check
29 CFR 1910.1450Occupational exposure to hazardous chemicals in laboratories.. Chemical hygiene plan and exposure controls for laboratory use of hazardous chemicals.OSHA · 29 CFR1Applies
Total24 rule sets; 9 apply, the rest apply only in the circumstances they name1263857 in rules that apply
Show the table (5 rows): First regulatory question and route for each target market.
First regulatory question and route for each target market.
Target marketFirst questionUsual route
Dietary supplementIs it a new dietary ingredient, and does the food-supply exception apply?New dietary ingredient notification, or records showing marketing before October 15, 1994.
Food or beverageIs it a food additive, or generally recognized as safe for this use?GRAS conclusion and notice, or a food additive petition.
CosmeticIs every claim a cosmetic claim, and is safety on skin substantiated?Safety substantiation, facility registration and product listing.
Drug researchIs there a sponsor prepared to file an IND?Partner-led drug development.
Outside the United StatesWhich national category fits, and who must hold the authorization?International market access.
Intellectual property

Protectable inventions usually lie in the process and the formulation, rarely in the plant

A naturally occurring substance is not patent-eligible merely because it has been isolated.

Protectable inventions sit in the engineering around the plantLaw and case law Candidate inventions proposed
Where protectable inventions sit in a development program: not in the plant or an isolated natural compound, but in four kinds of engineering around it, with process know-how kept as a trade secret where disclosure would not payTrade secret: process know-how where disclosure would not payCandidate patents: engineered around the plant (35 U.S.C. 101: any new and useful process, machine, manufacture or composition of matter)Extraction and enrichmentsequences giving anunexpected composition oryieldDelivery-system compositionsand methods of making themStabilization andtaste-masking methodsAnalytical methods thatconfirm identity or chemotypeThe plant, or a natural compound merely isolated from itNot patent-eligible on that basis (Myriad, 2013); USPTO asks whether anature-based product is markedly different from its natural counterpart (MPEP2106.04(c))Where protectable inventions sitNot patent-eligible merely because isolatedThe plant, or a natural compound isolated from it(Myriad, 2013; MPEP 2106.04(c))Candidate patents (35 U.S.C. 101)•Extraction and enrichment sequences giving anunexpected composition or yield•Delivery-system compositions and methods ofmaking them•Stabilization and taste-masking methods•Analytical methods that confirm identity orchemotypeTrade secretProcess know-how where disclosure would not pay
35 U.S.C. 101; Association for Molecular Pathology v. Myriad Genetics, Inc., No. 12-398 (U.S. June 13, 2013); USPTO, MPEP § 2106.04(c). EUTECNIQ holds no patents; ownership in a program would be fixed in the written agreement (see commercialization and licensing).
Text version of candidate inventions and limits

Candidate inventions in a development program Proposal

  • Extraction and enrichment sequences that give an unexpected composition or yield.
  • Delivery-system compositions and the methods of making them.
  • Stabilization and taste-masking methods.
  • Analytical methods that confirm identity or chemotype.
  • Process know-how kept as a trade secret where disclosure would not pay.

The limits Law and case law

The Supreme Court held that "a naturally occurring DNA segment is a product of nature and not patent eligible merely because it has been isolated" (2013). USPTO examiners ask whether a nature-based product has markedly different characteristics from its natural counterpart.

Patentability is decided case by case. EUTECNIQ holds no patents. Ownership of inventions made in a program would be fixed in the written agreement; see commercialization and licensing.

35 U.S.C. 101; Association for Molecular Pathology v. Myriad Genetics, Inc., No. 12-398 (U.S. June 13, 2013); USPTO, MPEP § 2106.04(c).

Engagement models

Three ways to work together, sized to the question

Three engagement models cover three, seven or all eight stagesProposed
Three proposed engagement models drawn as spans of the eight stages: feasibility covers 01–03, a development program 01–07, co-development 01–0801Target02Source03Composition04Extraction05Formulation06Stability07Safety, route08Scale-up, IPFeasibility studyFor an early question about onematerialStages 01 to 03Literature and regulatory screen; identityand composition snapshot; go or no-gomemoDevelopment programFor a defined ingredient targetStages 01 to 07Written gate after each stage; specification, process description, stability protocol; route memo andsafety planCo-developmentFor an ingredient or technology bothparties will own or licenseStages 01 to 08Agreed ownership, cost sharing and licensing terms; joint gates; scale-up and transferThree engagement models by stage spanStages 01 to 03Feasibility studyFor an early question about one material. Literatureand regulatory screen; identity and compositionsnapshot; go or no-go memo.Stages 01 to 07Development programFor a defined ingredient target. Written gate after eachstage; specification, process description, stabilityprotocol; route memo and safety plan.Stages 01 to 08Co-developmentFor an ingredient or technology both parties will ownor license. Agreed ownership, cost sharing andlicensing terms; joint gates; scale-up and transfer.
Scope, fees and ownership terms would be set in a written proposal after a scoping discussion.
Text version of the three models
Stages 01 to 03

Feasibility study

For an early question about one material.

  • Literature and regulatory screen
  • Identity and composition snapshot
  • Go or no-go memo with next steps
Stages 01 to 07

Development program

For a defined ingredient target.

  • Written gate at the end of each stage
  • Specification, process description, stability protocol
  • Regulatory route memo and safety plan; partner studies contracted with the customer's approval
Stages 01 to 08

Co-development

For an ingredient or technology both parties will own or license.

  • Agreed ownership, cost sharing and licensing terms
  • Joint stage gates
  • Scale-up and technology transfer

Discuss an ingredient program

Tell us about the material, the target market and the question you need answered first. The reply would propose a scope, starting with a feasibility study where the answer is not yet clear.