Eleven proposed technical documents would carry the evidence from each stage to the people who decide, and none of them is an FDA certificate
Each deliverable would be a EUTECNIQ technical document with defined contents, inputs and limits: what it would contain, which question it answers, who would do the work and what it is not.
446of FDA's 1,938 Part 111 citations in fiscal 2025 named § 111.70, specifications
265named § 111.75, the tests that show specifications are met
Status. EUTECNIQ offers no services yet and has produced none of these documents. No prices or turnaround times are published. Partner work would go to qualified outside organizations under written agreements; none is signed.
Library
Each document answers one decision-level question at one stage of the pathway
Stages refer to the development pathway. Select a deliverable for its full entry.
Where each document sits on the pathway, and which documents feed othersProposed document set
Arrows show only the inputs each entry names: the safety dossier needs the identity passport and characterization package, because its conclusion applies to a specified material; the NDIN package needs all three.Explanation, details and sources
Text version of the figure: each of the eleven documents, the pathway stage it serves and the question it answers.
Is there something protectable, who would own it, and how would it be sold?
Why these documents
Specifications and the tests that show they are met are the Part 111 requirements FDA cites most, every year since 2019
Form 483 citations of 21 CFR Part 111 by section, fiscal years 2019–2025: select a year to sortFDA data
FDA, Inspection Observations spreadsheets FY2019–FY2025, Foods tab, rows citing 21 CFR 111 summed by section (retrieved Oct 24, 2026). FDA notes the files cover system-generated Form 483s only, not every observation.Data table: citations by section and fiscal year
FDA Form 483 citations of 21 CFR Part 111, top 12 sections
Section
FY2019
FY2020
FY2021
FY2022
FY2023
FY2024
FY2025
§ 111.70 Specifications
236
150
145
271
247
366
446
§ 111.75 Tests to show specifications are met
158
92
76
129
104
173
265
§ 111.205 Master manufacturing record established
72
43
30
62
61
88
95
§ 111.260 Batch record contents
46
76
25
37
35
85
103
§ 111.103 Quality-control written procedures
74
38
36
64
54
67
67
§ 111.255 Batch record established
70
39
33
63
62
68
60
§ 111.210 Master manufacturing record contents
45
48
15
39
31
68
93
§ 111.105 Quality-control personnel duties
45
25
28
37
47
44
38
§ 111.453 Holding and distribution procedures
44
24
21
32
41
40
49
§ 111.553 Complaint procedures
37
22
22
33
30
30
40
§ 111.503 Returned-product procedures
30
13
9
28
28
33
56
§ 111.123 Quality control of records and operations
26
17
17
28
27
30
27
All Part 111 citations
1,444
871
704
1,218
1,173
1,583
1,938
The characterization package, identity passport and supplier qualification package would document specifications and their basis; a citation history says nothing about any one firm.
Explanation, details and sources
An FDA Form 483 lists an investigator's observations at the end of an inspection; it is not a final agency determination. FDA's yearly spreadsheets count how often each regulation was cited on system-generated 483s. Section 111.70 requires specifications for components, in-process points, finished batches, labels and packaging; section 111.75 requires tests or examinations to determine whether they are met, including an identity test for each dietary-ingredient lot. The FY2024 and FY2025 files record citations at a coarser paragraph level than earlier years, so the figure sums by section.
Deliverables
What each document would contain, what it needs and where its claims stop
73 content elements across eleven documents: select a stage or a document to see what it would containProposed contents
Built from the “Contains” line of each entry below, split at semicolons. Stage groups follow the library table.
The same identity, composition and safety evidence would recur across several documentsProposed contents
A dot means the entry lists that element under "Contains". Column numbers follow the library table above.
Laboratory work would start in house; toxicology, human studies, counsel and commercial scale would go to partnersProposed division of work
Phase I is proposed for 2027; Phase II follows only after its gate (facilities roadmap). The NDIN notifier is the manufacturer or distributor of the ingredient or the supplement (21 CFR 190.6).
None of the eleven documents is a certificate, an approval or a legal opinionLimits set by rule and evidence
eCFR, 21 CFR 111.75 and 190.6, current to Oct 21, 2026; FDA, NDI identity and safety final guidance (Oct 2026); ILAC-P8:11/2023 on accreditation claims. Not legal advice.Full entries for all eleven documents: contains, answers, typical inputs, who would do the work, what it is not
01
Ingredient identity passport
Phase IPartner · DNA, NMR
Contains
Accepted botanical name with author, plant part and source description; voucher or reference-material record; macroscopic and microscopic description; HPTLC fingerprint and HPLC or LC-MS marker profile against authenticated reference material; targeted adulterant results; processing history for extracts; the identity specification proposed for routine lots.
Answers
Is this the right species and plant part? Which adulterants are plausible, and were they excluded? How should identity be confirmed on every future lot?
Typical inputs
Samples from several lots; supplier documents; authenticated reference material or a voucher specimen.
Who would do the work
In house, Phase I: microscopy, HPTLC, HPLC and LC-MS. Partner: DNA barcoding of crude material and NMR.
What it is not
Not a certificate of authenticity from any authority. It describes the lots tested and does not certify future lots, which still need the identity test the buyer's own rules require (21 CFR 111.75(a)(1)(i)).
02
Analytical characterization package
Phase IPartner · out-of-scope tests
Contains
Quantitation of marker or active compounds with method summaries; chromatographic fingerprint and untargeted profile; elemental impurities, pesticide residues, residual solvents, mycotoxins and microbial counts; moisture and particle size; method validation or verification summaries; lot-to-lot variability; a draft specification with its justification.
Answers
What is in the material, and at what level? How variable is it between lots? Which specification can be justified and measured reliably?
Typical inputs
Representative samples from several lots; reference standards; the intended market and product category.
Who would do the work
In house, Phase I: UHPLC, LC-MS/MS, GC-MS, ICP-MS and microbiology. Partner: accredited laboratories for tests outside the planned scope.
What it is not
Not an accredited test report: EUTECNIQ holds no ISO/IEC 17025 accreditation, and an accreditation would cover only listed tests. Results describe the samples tested and represent a lot only if sampling was representative.
03
Botanical safety dossier
Assessment in housePartner · CROs, experts
Contains
Intended conditions of use and an exposure estimate; documented history of use; review of toxicology, human and adverse-event data; constituents of concern and how the specification controls them; an interaction assessment; gap analysis and a proposed testing plan; a safety narrative.
Answers
Is the intended dose, population and duration supported? What could go wrong, and for whom? Which studies would close the remaining gaps?
Typical inputs
The identity passport and characterization package, because the conclusion applies to a specified material; intended use and dose; published literature; any existing studies.
Who would do the work
In house: exposure assessment, literature review and writing. Partner: toxicology studies at contract research organizations; independent expert review.
What it is not
Not an FDA determination of safety, and not a GRAS conclusion by itself. It covers the specified material only: a differently processed extract or a nanomaterial form needs its own evaluation.
04
NDIN development and notification support package
Assembly in housePartner · counsel
Contains
Analysis of whether a notification appears to be required, noting that FDA's guidance on that question is still draft; identity information organized to FDA's October 2026 final guidance; manufacturing description and specifications; history of use or other evidence of safety; the safety narrative and safety calculations; a checklist against 21 CFR 190.6(b); master-file considerations under FDA's April 2024 draft guidance.
Answers
Does this ingredient appear to need a notification? Is the identity and safety evidence organized as FDA recommends? What is missing?
Typical inputs
Identity passport, characterization package and safety dossier; intended conditions of use; regulatory counsel's view.
Who would do the work
In house: technical assembly. Partner: regulatory counsel and toxicology experts. The notifier is the manufacturer or distributor of the ingredient or the supplement (21 CFR 190.6).
What it is not
Not FDA approval. FDA does not approve NDI notifications, and an acknowledgment without objection is not an independent FDA finding of safety. Not legal advice, and no outcome is promised.
05
Regulatory market-access assessment
In housePartner · in-country counsel
Contains
Classification of the intended product in each target market by intended use; the ingredient's status, including existing authorizations or novel status; claims boundaries; the filings each market requires and who must hold them; evidence gaps; a recommended order of work.
Answers
In which markets can this be sold, as what, and with which claims? Which filings or evidence come first?
Typical inputs
Product concept, composition and specifications; target markets; intended claims.
Who would do the work
In house: regulatory science. Partner: regulatory counsel and in-country consultants. See international market access.
What it is not
Not legal advice and not an authorization. Classification depends on intended use and claims, and rules change; every assessment is dated.
06
Ingredient comparability package
Phase IPilot lots · Phase II
Contains
A side-by-side comparison of a new supplier, site, process or scale against reference lots: identity, fingerprint similarity, marker content, impurity profile, physical attributes and stability-indicating attributes; acceptance criteria set before testing; a statistical comparison; the conclusion and residual risks.
Answers
Is material from the new source, process or scale equivalent for its intended use? Does the change raise new safety or regulatory questions?
Typical inputs
Reference lots and new lots; a description of the change; current specifications.
Who would do the work
In house: Phase I analytics, and pilot-scale lots from Phase II. Partner: orthogonal tests outside the planned scope.
What it is not
Not proof of equivalent effect in people: comparability is shown attribute by attribute. A manufacturing change may still need regulatory assessment, and FDA's views on manufacturing changes and NDI status are in draft guidance.
07
Bioavailability and delivery technology dossier
Phase IPartner · human PK
Contains
A physicochemical profile (solubility, partitioning, ionization, stability); the identified limit to absorption; the rationale for the chosen delivery system; formulation characterization (droplet or particle size distribution, surface charge, encapsulation efficiency, physical stability); in vitro dissolution and digestion results; a human pharmacokinetic study design if exposure claims are intended.
Answers
What limits absorption: solubility, dissolution, permeability or metabolism? Which delivery approach addresses that limit? What evidence would show higher exposure in people?
Typical inputs
A characterized active or extract; target dose and format; published pharmacokinetic data.
Who would do the work
In house, Phase I: formulation and in vitro testing. Partner: human pharmacokinetic studies and plasma bioanalysis. See advanced delivery.
What it is not
Not evidence of bioavailability on its own. Nanoemulsion stability is not demonstrated bioavailability, in vitro bioaccessibility is not systemic exposure, and higher exposure is not clinical benefit.
08
Supplier qualification package
Phase IPartner · in-country audits
Contains
Supplier questionnaire and document review; an audit report, onsite or remote and sized to risk; confirmatory testing of the supplier's certificate results across several lots; a risk ranking; the approval decision and requalification schedule; FSVP or supply-chain program notes for importers.
Answers
Can this supplier's material and documents be relied on? Which tests must the buyer still run? How often should the supplier be re-verified?
Typical inputs
Supplier documents; samples from several lots; site access for an audit.
Who would do the work
In house, Phase I: analytics and quality. Partner: in-country auditors for foreign sites. See global ingredients.
What it is not
Not a certification of the supplier by FDA or anyone else. A qualified certificate does not remove the identity test required for each dietary-ingredient lot (21 CFR 111.75(a)(1)), and the buyer's own obligations remain.
09
Process development and transfer package
Lab · Phase IPilot · Phase IIPartner · CMOs
Contains
Process description and flow diagram; mass and energy balances; critical process parameters and critical quality attributes with their ranges; scale-up rationale; equipment and utility needs; in-process controls; cleaning considerations; a draft master manufacturing record; pilot batch data; a risk assessment; a transfer protocol with acceptance criteria.
Answers
Can this process make on-specification material at the next scale? Which parameters matter, and in what ranges? What does the receiving site need?
Typical inputs
The laboratory process; specifications; target scale and the receiving site's equipment.
Who would do the work
In house: laboratory scale in Phase I and the pilot plant in Phase II, after its gate. Partner: commercial-scale runs at contract manufacturers until Phase III.
What it is not
Not a validated commercial process: process validation at the receiving site is that site's responsibility. Not drug process validation, which is outside the plan.
10
Formulation applications package
Phase I
Contains
Prototype formulations in target formats such as capsules, powders, beverages or topical emulsions; excipient compatibility; physical and chemical stability under defined storage, including accelerated conditions; manufacturability notes; a proposed finished-product specification and stability protocol.
Answers
How does the ingredient behave in this format? Which concentration, excipients and process steps work? Which stability risks remain?
Typical inputs
The ingredient and its specification; target format and market; the customer's base formula, if any.
Who would do the work
In house, Phase I formulation laboratory. Partner: commercial production by the customer or a contract manufacturer.
What it is not
Not a validated shelf life: accelerated data support a shelf life but do not establish one. Prototypes are not commercial products, and the regulatory category depends on intended use and claims.
11
IP and commercialization assessment
In housePartner · patent counsel
Contains
A prior-art landscape of patents and literature; observations on what may be new; questions for counsel on patentability and freedom to operate; ownership and inventorship mapping under the governing agreements; protection options (patent, trade secret, know-how license, master file); commercial routes and their risks; third-party market data, labeled as such.
Answers
Is there something protectable? Who would own it? What should counsel review? Which commercial route fits?
Typical inputs
Technical data from earlier stages; agreements; target markets.
Not a legal, patentability or freedom-to-operate opinion. EUTECNIQ owns no patents; the founder's patents are assigned to Yazaki.
Explanation, details and sources
Four views of the same eleven entries: contents, who would do the work, and what each is not. "In house" means a capability planned for a proposed facility phase; "partner" means a qualified external organization.
Common standard
Every document would show where each statement comes from and where its claims stop
A proposed house standard, so a reader can audit a conclusion without calling the author.
Five elements would be built into every deliverableSchematic, not a real document
Proposed document standard for every EUTECNIQ deliverable; none has been produced.Text version: the house standard and what no deliverable would claim
Built into every deliverable
An evidence label on each statement: measured by EUTECNIQ, measured by a partner, published literature, model output or proposal.
The method and method version behind each result, with raw data retained.
A scope and limitations section, written before the conclusions.
Quality review, approval signatures and a version history.
Confidentiality and data-ownership terms agreed before work starts.
Proposal
What no deliverable would claim
Identity passport≠Certificate of authenticity
Characterization package≠Accredited test report
Safety dossier≠FDA safety finding
NDIN support package≠FDA approval
Delivery dossier≠Demonstrated bioavailability
Stability data≠Validated shelf life
Sources: eCFR, 21 CFR 111.75 and 190.6, current to Oct 21, 2026; FDA, NDI identity and safety final guidance (Oct 2026) and NDI notification master file draft guidance (Apr 2024); ILAC-P8:11/2023 on accreditation claims. Not legal advice.
Which document would answer your question?
Describe the ingredient, the market and the decision ahead. EUTECNIQ is in formation; early conversations help define scope.