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Evidence and pharmacokinetics Peer-reviewed Regulatory definitions

Each kind of evidence answers one question, and a long history of use answers none of them alone

Absorption versus benefit, dose and exposure, herb–drug interactions measured in people, safety margins and the drug pathway, each from cited published studies. EUTECNIQ's role is a proposal.

7.4×rise in mean EGCG exposure (AUC) when a single dose rose 4-fold, 200 to 800 mg
2 of 6volunteers with any serum curcumin after 10 or 12 g of a curcuminoid extract
−85 to +184%change in a drug's AUC caused by a botanical or juice in human studies
7.9%of phase 1 drug programs reached approval, all indications, 2011–2020

Status. EUTECNIQ Sciences is a company in formation with no studies or data of its own. The results on this page are published third-party studies; the evidence standard and services described are proposals.

Academy fundamentals: Course 1, History of botanical medicine · Course 8, Solubility, pH and the body · Course 9, Toxicology and dose

Dose and exposure

In a phase I study, quadrupling a single EGCG dose raised its AUC about sevenfold, not fourfold

Mean AUC of unchanged EGCG after single oral doses of 200 to 800 mg, two formulations, 5 volunteers per dose levelPublished data

Dose rose 4-fold (200 to 800 mg); mean AUC rose 7.4-fold for both formulations (22.5 to 167.1 and 21.9 to 161.4 min·µg/mL).

Data table
Mean AUC of unchanged EGCG, Chow et al. 2001
Dose (EGCG content)EGCG: AUC, min·µg/mLPolyphenon E: AUC, min·µg/mLEGCG: per 100 mg (derived)Polyphenon E: per 100 mg (derived)
200 mg22.521.911.2510.95
400 mg35.452.28.8513.05
600 mg101.979.716.9813.28
800 mg167.1161.420.8920.18
Chow HH, Cai Y, Alberts DS, Hakim I, Dorr R, Shahi F, Crowell JA, Yang CS, Hara Y. Phase I pharmacokinetic study of tea polyphenols following single-dose administration of epigallocatechin gallate and polyphenon E. Cancer Epidemiol Biomarkers Prev. 2001;10(1):53–58 (abstract values). 20 healthy volunteers, 5 per dose level, randomized crossover between the two formulations. The authors attribute the rise to possibly saturable presystemic elimination. Dashed line: exposure proportional to dose from the EGCG 200 mg point.

A fold-change measured at one dose does not transfer to another dose, and dose-normalized comparisons assume a proportionality this study did not find.

EGCG carries eight phenolic hydroxyls on four rings, with a (2R,3R) configuration at the central ringReference structure, computed conformer
Skeletal formula of (−)-epigallocatechin 3-gallate, C22H18O11, molar mass 458.38 g/mol, with rings A to D labelled and the (2R,3R) configuration shown by wedge and hash bonds; below, a ball-and-stick view of one computed conformer.
Structure: PubChem isomeric SMILES, CID 65064 (retrieved Oct 25, 2026); RDKit 2026.09 2D depiction; (2R,3R) checked against PubChem's IUPAC name; lowest-energy of 30 MMFF94 conformers. Generated illustration, EUTECNIQ. Full-size SVG
Explanation, details and sources

The same group reported a more than 60% increase in the AUC of free EGCG after 4 weeks of 800 mg once daily, but no significant change at 400 mg twice daily (Chow et al. 2003), and a more than 3.5-fold higher average Cmax of free EGCG when Polyphenon E was taken after an overnight fast rather than with a light breakfast (Chow et al. 2005). Dose, schedule and food each changed exposure to the same ingredient.

EFSA concluded that EGCG intakes of at least 800 mg/day from supplements increased serum transaminases in intervention trials (EFSA 2018; see the safety-margin section below). How dose, form and genetic susceptibility appear in documented botanical harms is set out on Lessons learned.

Chow HH, et al. Clin Cancer Res. 2003;9:3312–3319. Chow HH, et al. Clin Cancer Res. 2005;11:4627–4633. EFSA ANS Panel. EFSA J. 2018;16(4):e05239.

Absorbed but not detected

Unformulated curcumin was undetectable in serum up to 8 g and found in 2 of the 6 volunteers given 10 or 12 g

Single-dose escalation of a curcuminoid extract, 0.5 to 12 g: who had detectable serum curcumin, and how muchPublished data
Data table
Lao et al. 2006: detection by dose, and serum curcumin in the two subjects with detectable levels
DoseSubjects with detectable serum curcuminBaseline, ng/mL1 h2 h4 h
0.5, 1, 2, 4, 6 and 8 g0 of 3 at each doseNo curcumin detected
10 g1 of 3approx. 6.030.439.550.5
12 g1 of 3approx. trace29.757.651.2
Lao CD, Ruffin MT, Normolle D, et al. Dose escalation of a curcuminoid formulation. BMC Complement Altern Med. 2006;6:10, Table 2 and Results (open access). 24 healthy volunteers, 3 per dose level; standardized powder extract (C3 Complex). Baseline values as printed in the table.

Undetectable parent compound reflects the analyte and the assay; conjugated curcumin metabolites were found in every subject given 10 or 12 g (Vareed et al. 2008).

Curcumin: two methoxyphenol rings joined by a conjugated seven-carbon chain that carries a keto–enol groupReference structure, computed conformer
Skeletal formula of curcumin in its keto–enol form, C21H20O6, molar mass 368.39 g/mol: two 4-hydroxy-3-methoxyphenyl rings joined by a seven-carbon conjugated chain carrying a ketone and an enol. Below, a space-filling view of one computed three-dimensional conformer.
Structure: curcumin, PubChem CID 969516, drawn as its keto–enol tautomer; RDKit 2D depiction and lowest-energy of 30 MMFF94 conformers (ETKDGv3, seed 7). Generated illustration, EUTECNIQ. Full-size SVG
Explanation, details and sources

At 10 and 12 g, free curcumin was detectable in only one of 12 subjects at any of 14 time points (assay limit 50 ng/mL), while curcumin glucuronides and sulfates were found in all of them (Vareed et al. 2008). After 0.5 to 5 g of resveratrol, peak levels of two monoglucuronides and resveratrol-3-sulfate were 3- to 8-fold higher than those of resveratrol, and their AUCs up to 23 times greater (Boocock et al. 2007). With a radiolabeled 25 mg dose, at least 70% of resveratrol was absorbed, yet unchanged resveratrol stayed below 5 ng/mL while resveratrol plus metabolites peaked at 491 ± 90 ng/mL (Walle et al. 2004).

A tracer study that counted every labeled product of an anthocyanin is charted on Bioavailability by design.

Vareed SK, et al. Cancer Epidemiol Biomarkers Prev. 2008;17:1411–1417. Boocock DJ, et al. Cancer Epidemiol Biomarkers Prev. 2007;16:1246–1252. Walle T, et al. Drug Metab Dispos. 2004;32:1377–1382.

Five terms

Release in the gut, absorption, exposure, activity at a target and benefit in a trial are five different results

Five results along one path, from release in the gut to benefit in a trialDefinitions
Five different results on the way from a product to a benefit: release into the gut (bioaccessibility), absorption into the blood (bioavailability), the plasma concentration–time profile (exposure), a biological response (pharmacodynamic activity) and a benefit in a controlled trial (clinical efficacy)product matrixblood: to portal vein, liver, circulation12Gut lumen, epithelium and blood (schematic)Plasma concentrationCmax​AUCtime3Illustrative one-compartment oral model, ka​ 1h−1​, ke​ 0.2 h−1​Target, then outcomeEnzyme or receptorresponse measured4Patients in a controlled trialbenefit on the endpoint, for thatpopulation, dose and duration51BioaccessibilityReleased from the matrix intodigestive fluidIn vitro, e.g. INFOGEST2BioavailabilityRate and extent absorbed andavailable at the site of actionHuman blood concentrations3ExposureConcentration–time profile atthe dose takenCmax​, AUC4PharmacodynamicactivityBiological response at thatexposureEnzyme inhibition, biomarker5Clinical efficacyBenefit on a clinical or validatedendpointControlled human studyFive different results on the way from a product to a benefit, each measured differently1BioaccessibilityReleased from the matrix into digestive fluid.Measured by: In vitro, e.g. INFOGEST.2BioavailabilityRate and extent absorbed and available at the site ofaction. Measured by: Human blood concentrations.3ExposureConcentration–time profile at the dose taken.Measured by: Cmax​, AUC.4Pharmacodynamic activityBiological response at that exposure. Measured by:Enzyme inhibition, biomarker.5Clinical efficacyBenefit on a clinical or validated endpoint. Measuredby: Controlled human study.Each is necessary but not sufficient for the next.
Bioavailability: "the rate and extent to which the active ingredient or active moiety is absorbed from a drug product and becomes available at the site of action" (21 CFR 320.1). Schematic, not to scale; the plasma curve is an illustrative model, not data.21 CFR 320.1; Brodkorb A et al. Nat Protoc. 2019;14:991–1014 (INFOGEST).
Text version of the five terms
Bioaccessibility
The fraction released from the food or product matrix into the digestive fluid and available for absorption. Measured in vitro, for example with the INFOGEST digestion protocol.
Bioavailability
"The rate and extent to which the active ingredient or active moiety is absorbed from a drug product and becomes available at the site of action" (21 CFR 320.1). Measured in people from blood concentrations.
Exposure
The concentration–time profile of the relevant compound or metabolite (Cmax, AUC) at the dose taken. It depends on dose and bioavailability, and drives both effects and toxicity.
Pharmacodynamic activity
A measurable biological response at the achieved exposure, such as enzyme inhibition or a biomarker change. It shows mechanism, not benefit.
Clinical efficacy
A benefit on a clinical or validated endpoint in a controlled human study, for the population, dose and duration studied.
Explanation, details and sources

Bioavailability claims go wrong when one result is reported as another. Each is measured differently and is necessary but not sufficient for the next.

Evidence ladder

Six evidence steps decide whether a botanical becomes a product, and each answers only its own question

Two rulebooks, one body of science: the steps EUTECNIQ would apply to each product typeEUTECNIQ standard · legal minimums differ
Product type1 · Chemistry2 · Reproducibility3 · Formulation4 · Safety5 · Human evidence6 · Manufacture
Dietary supplementRequired: identity and specifications (Part 111)Required: each batch meets specificationsEUTECNIQ standardLaw: new dietary ingredients only; EUTECNIQ standardClaim substantiationRequired: Part 111
DrugRequiredRequiredRequiredRequiredControlled trials and FDA approval (partners)Drug cGMP through CDMOs
Legal minimums for supplements are lower than this standard: a premarket safety notification is required only for a new dietary ingredient (21 CFR 190.6), and stability data are needed to support an expiration date only when one is claimed. A dietary supplement is never FDA-approved; structure/function claims need substantiation, a disclaimer and notice to FDA within 30 days of first marketing (21 CFR 101.93). A drug needs adequate and well-controlled trials and FDA approval. EUTECNIQ proposes to build the infrastructure for these steps once and serve both markets, placing clinical efficacy work with partners.21 CFR 101.93 and 190.6; FDA, Botanical Drug Development guidance (Revision 1, December 2016); ICH M3(R2), Q2(R2), Q1A(R2); Brodkorb A et al. Nat Protoc. 2019;14:991–1014.
Explanation, details and sources

Traditional use sits before step 1: it points to candidates but does not establish identity, dose, consistency, safety or efficacy.

  1. Step 1

    Chemistry

    Establishes
    Identity; actives measured
    Does not establish
    Reproducibility
    How
    LC-MS, HPTLC, marker assays
  2. Step 2

    Reproducibility

    Establishes
    Composition within justified specifications
    Does not establish
    Stability in a product
    How
    Standardized extraction; methods validated per ICH Q2(R2)
  3. Step 3

    Formulation

    Establishes
    A stable, dosable product
    Does not establish
    Absorption in people
    How
    Emulsions, encapsulation, drying; stability studies
  4. Step 4

    Safety

    Establishes
    Toxicology and exposure margins
    Does not establish
    Efficacy
    How
    NDI and GRAS dossiers; IND-enabling nonclinical data (ICH M3(R2))
  5. Step 5

    Human evidence

    Establishes
    Human data for a defined claim and dose
    Does not establish
    Other claims or doses
    How
    INFOGEST screening, then pharmacokinetics and trials with clinical partners
  6. Step 6

    Manufacture

    Establishes
    Released product, lot after lot
    Does not establish
    A new claim
    How
    Part 111 release; drug GMP placed with qualified CDMOs
Grading evidence

Strength of evidence is a judgment about a body of studies, graded down for bias, inconsistency, indirectness, imprecision and publication bias

Trials start high and observational studies low; five factors move certainty down, three move it upPublished method
GRADE rates certainty for one outcome across a body of studies: randomized trials start high and observational studies low; five factors move the rating down and three, mainly for observational evidence, move it up. The RoB 2 tool checks five domains of bias in a randomized trialStartRandomized trialsCertainty of evidence for one outcomeHighVery confident the true effect lies close to theestimateModerateTrue effect likely close, but may be substantiallydifferentLowTrue effect may be substantially differentVery lowTrue effect likely substantially differentObservationalstudiesDown forRisk of biasInconsistency between studiesIndirectness: other population,dose, product or endpointImprecision: wide intervals, feweventsPublication biasUp for (mainly observational)Large effect: at least a two-foldchange in riskDose–response gradientPlausible confounding that wouldreduce the observed effectRoB 2: five places a randomized trial can go wrong1Randomization process2Deviations from intendedinterventions3Missing outcome data4Measurement of theoutcome5Selection of the reportedresultGRADE certainty levels, the factors that move them and the five RoB 2 domainsRandomized trials start High; observational studies startLow.HighVery confident the true effect lies close to the estimateModerateTrue effect likely close, but may be substantiallydifferentLowTrue effect may be substantially differentVery lowTrue effect likely substantially differentDown for· Risk of bias· Inconsistency between studies· Indirectness: other population, dose, product or endpoint· Imprecision: wide intervals, few events· Publication biasUp for (mainly observational)· Large effect: at least a two-fold change in risk· Dose–response gradient· Plausible confounding that would reduce the observedeffectRoB 2 domains1. Randomization process2. Deviations from intended interventions3. Missing outcome data4. Measurement of the outcome5. Selection of the reported result
Guyatt GH et al. BMJ. 2008;336:924–926. Balshem H et al. J Clin Epidemiol. 2011;64(4):401–406. Guyatt GH et al. J Clin Epidemiol. 2011;64(12):1311–1316. GRADE Handbook, Table 5.1. Sterne JAC et al. BMJ. 2019;366:l4898 (RoB 2).
Text version: certainty levels, rating factors, effect sizes and bias
GRADE certainty levels
LevelMeaning for a reader
HighVery confident that the true effect lies close to the estimate
ModerateModerately confident: the true effect is likely to be close to the estimate, but may be substantially different
LowLimited confidence: the true effect may be substantially different from the estimate
Very lowVery little confidence: the true effect is likely to be substantially different from the estimate
What moves the rating
DirectionFactor
DownRisk of bias; inconsistency between studies; indirectness (other population, dose, product or endpoint); imprecision (wide confidence intervals, few events); publication bias
Up (mainly observational evidence)A large effect (at least a two-fold change in risk); a dose–response gradient; plausible confounding that would reduce the observed effect

Guyatt GH et al. BMJ. 2008;336:924–926. Balshem H et al. GRADE guidelines: 3. Rating the quality of evidence. J Clin Epidemiol. 2011;64(4):401–406. Guyatt GH et al. GRADE guidelines: 9. Rating up the quality of evidence. J Clin Epidemiol. 2011;64(12):1311–1316. Level meanings paraphrase Table 5.1 of the GRADE Handbook (GRADE Working Group).

An effect size means little without its uncertainty, its sample and the risk of bias in the study that produced it

Effect sizes

Report the difference, not only the p-value

A study should report the estimated difference between groups with its 95% confidence interval: an absolute difference (for example, percentage points of responders) and, where useful, a relative one (a risk ratio). A standardized mean difference, the difference divided by the standard deviation, lets different scales be compared but hides the clinical meaning.

Sample size

Small studies overstate effects

Low statistical power reduces the chance of detecting a true effect and also the chance that a significant result reflects one. Significant results from small studies therefore tend to overestimate effect sizes (Button et al. 2013). A wide confidence interval is the honest signal of imprecision.

Sample-size calculators →
Bias

Five places a randomized trial can go wrong

The Cochrane RoB 2 tool assesses bias arising from the randomization process, from deviations from intended interventions, from missing outcome data, in measurement of the outcome and in selection of the reported result. Unblinded outcome assessment, missing outcome data and selective reporting are typical concerns these domains capture.

Button KS et al. Nat Rev Neurosci. 2013;14(5):365–376. Sterne JAC et al. RoB 2: a revised tool for assessing risk of bias in randomised trials. BMJ. 2019;366:l4898.

An effect size needs its 95% confidence interval, its sample and its risk of bias; small studies tend to overstate effects.

Explanation, details and sources
How EUTECNIQ would use grading. Every claim in a proposed evidence dossier would carry the type of evidence behind it and, for human outcomes, a GRADE-style certainty rating with the reasons for any downgrade. A claim resting on low or very low certainty would be presented as a hypothesis.
Product categories

Traditional preparations, supplements, isolated compounds and botanical drugs are different products, and traditional leads became drugs as purified molecules

Six routes from a plant or remedy to an approved molecule; paclitaxel had no traditional leadPeer-reviewed
Drugs from traditional leads and plant screening: artemisinin, arsenic trioxide, metformin from guanidine chemistry, cromolyn and amiodarone from khellin, the vinca alkaloids and paclitaxel, each as a purified, characterized moleculeLead + methodfrom Qinghao, Artemisia annuaOOOOOArtemisininA fourth-century cold-water instruction pointed tolow-temperature extractionTu 2011Chemical lineagefrom Goat's rue, Galega officinalisNH2​NH2​NHGuanidineNNHNNH2​NH2​MetforminA guanidine-rich remedy led to guanidinederivatives; metformin is syntheticBailey 2017Screeningfrom Pacific yew, Taxus brevifoliaOOONHOOHOHOOOOOOHOOPaclitaxelFound by systematic plant screening, not bytraditional useWani et al. 1971Scaffold lineagefrom Ammi visnagaOOOOOKhellinOOOOOOHOHOOOOHCromolynOOIONIAmiodaroneKhellin, a long-used smooth-muscle relaxant, was modified into new drugsEdwards 2014; Shah & Bharate 2024Lead (mineral): Arsenic trioxidefrom a folk arsenic preparation. As2​O3​ (inorganic).Used in acute promyelocytic leukemia since theearly 1990s. Wang & Chen 2008.Serendipity: Vinblastine · vincristinefrom Catharanthus roseus. C46​H58​N4​O9​ ·C46​H56​N4​O10​. Testing a folk antidiabetic use, whichproved wrong, revealed anticancer alkaloids. Noble1990.Drugs from traditional leads and plant screening, each as a purified, characterized moleculeLead + methodfrom Qinghao, Artemisia annuaOOOOOArtemisininA fourth-century cold-water instruction pointed tolow-temperature extractionTu 2011Chemical lineagefrom Goat's rue, Galega officinalisNH2​NH2​NHGuanidineNNHNNH2​NH2​MetforminA guanidine-rich remedy led to guanidine derivatives;metformin is syntheticBailey 2017Screeningfrom Pacific yew, Taxus brevifoliaOOONHOOHOHOOOOOOHOOPaclitaxelFound by systematic plant screening, not by traditionaluseWani et al. 1971Scaffold lineagefrom Ammi visnagaOOOOOKhellinOOOOOOHOHOOOOHCromolynOOIONIAmiodaroneKhellin, a long-used smooth-muscle relaxant, wasmodified into new drugsEdwards 2014; Shah & Bharate 2024Lead (mineral): Arsenic trioxidefrom a folk arsenic preparation. As2​O3​ (inorganic). Usedin acute promyelocytic leukemia since the early 1990s.Wang & Chen 2008.Serendipity: Vinblastine · vincristinefrom Catharanthus roseus. C46​H58​N4​O9​ · C46​H56​N4​O10​.Testing a folk antidiabetic use, which proved wrong,revealed anticancer alkaloids. Noble 1990.
Structures from PubChem records (CIDs 68827, 3520, 4091, 36314, 3828, 2882, 2157), drawn with RDKit; vinca alkaloid structures not drawn. Tu 2011, Nat Med; Wang & Chen 2008, Blood; Bailey 2017, Diabetologia; Edwards 2014; Shah & Bharate 2024; Noble 1990, Biochem Cell Biol; Wani et al. 1971, J Am Chem Soc.
Text version of the six routes
  1. Lead + method

    Artemisinin from Qinghao (Artemisia annua)

    Ge Hong's fourth-century instruction to soak qinghao in cold water pointed Tu Youyou's team to low-temperature extraction. Tu 2011, Nat Med

  2. Lead (mineral)

    Arsenic trioxide from Folk arsenic preparation

    Investigated by Chinese clinicians and used in acute promyelocytic leukemia since the early 1990s. Wang & Chen 2008, Blood

  3. Chemical lineage

    Metformin from Goat's rue (Galega officinalis)

    A guanidine-rich European remedy led to guanidine derivatives; metformin itself is synthetic. Bailey 2017, Diabetologia

  4. Scaffold lineage

    Cromolyn (1965) · amiodarone from Ammi visnaga

    Khellin, a long-used smooth-muscle relaxant, was modified into new drugs. Edwards 2014; Shah & Bharate 2024

  5. Serendipity

    Vinblastine · vincristine from Catharanthus roseus

    Testing a folk antidiabetic use, which proved wrong, revealed anticancer alkaloids. Noble 1990, Biochem Cell Biol

  6. Screening

    Paclitaxel from Pacific yew (Taxus brevifolia)

    Found by systematic plant screening, not by traditional use. Wani et al. 1971, J Am Chem Soc

1,881 drugs approved 1981–2019, by originPeer-reviewed
Unaltered natural product · 3.8%Natural-product derivative · 18.9%All other origins · 77.3%
Show data
Origin (Newman & Cragg category)Share of 1,881 approvalsSquares (rounded)
Unaltered natural product (N)3.8%4
Natural-product derivative (ND)18.9%19
All other origins77.3%77
Each square is 1% of approvals (rounded). Natural-product drugs and FDA "botanical drugs" are different categories: FDA lists four approved botanical drug products.Newman DJ, Cragg GM. J Nat Prod. 2020;83(3):770–803 (category shares as reported in reproductions of the review's Figure 1; the abstract does not state them).
Explanation, details and sources

One plant can appear in all four categories. Green tea is drunk as an infusion, sold as concentrated extract supplements, purified to single catechins such as EGCG, and the source of an FDA-approved botanical drug. Value came from isolating, characterizing and testing a defined molecule, not from selling the traditional preparation.

Show the table (4 rows)
CategoryWhat it isU.S. route to marketEvidence before marketingGreen tea example
Traditional preparationInfusion, decoction or powder prepared as customarily usedUsually a conventional foodFood safety law; no efficacy reviewGreen tea infusion: EFSA estimates 90–300 mg/day EGCG at mean intake
Botanical dietary supplementExtract or powder sold in a dosage form under DSHEANo premarket approval; NDI notification only for a new dietary ingredientSafety basis if new; claim substantiation; Part 111 manufacturingExtract supplements supply 5–1,000 mg/day EGCG; at least 800 mg/day raised serum transaminases in trials (EFSA 2018)
Isolated natural compoundA single purified or chemically modified constituentA supplement ingredient only if it qualifies as a dietary ingredient and is not excluded (often requiring an NDI notification); a new drug for a disease use. FDA does not treat highly purified substances as botanical drugsNDI safety basis for a supplement use; full drug development for a drug useEGCG as a single purified substance
FDA botanical drugA drug product that includes or is derived from plant materials, approved through an NDA or BLAIND, controlled trials, NDA or BLASubstantial evidence of effectiveness and safety; batch-to-batch consistency of a complex mixtureVeregen (sinecatechins), a partially purified water-extract fraction of green tea leaves, approved in 2006 for external genital and perianal warts

EFSA ANS Panel. Scientific opinion on the safety of green tea catechins. EFSA J. 2018;16(4):e05239. FDA, What Is a Botanical Drug? (content current as of September 3, 2026). Veregen prescribing information (indication and drug substance description). FDA, Botanical Drug Development: Guidance for Industry (Revision 1, December 2016).

Tradition has also caused harm

Use is not proof of safety or of effectiveness

  • Substitution: Aristolochia fangchi substituted for Stephania tetrandra in Belgian slimming pills caused renal fibrosis; 18 of 39 patients who underwent prophylactic surgery had urothelial carcinoma. Nortier et al. 2000, N Engl J Med
  • Toxic metals: lead, mercury or arsenic in 20.7% of 193 Ayurvedic medicines bought online, made in the U.S. and India. Saper et al. 2008, JAMA
  • Idiosyncratic liver injury: in ten turmeric cases from the U.S. Drug-Induced Liver Injury Network, 7 patients carried HLA-B*35:01, and 3 of the 7 products tested contained piperine. Halegoua-DeMarzio et al. 2023, Am J Med

FDA's NDI guidance treats history of use as evidence only when it is documented: relied on alone, it "generally recommends 25 years of widespread use to be the minimum", for the same material at comparable intake.

Documented harms and what each changed are on Lessons learned.

Academy: from plant record to molecule · natural products among approved drugs (Course 1)

Absorption and margins

Better absorption is measurable but is not efficacy, and anything that raises exposure at the same dose shrinks the safety margin

From formulation to benefit: what each step measuresDefinitions
  1. Solubility or dispersibilitySolubility; droplet or particle size. Dispersing an active does not dissolve it.
  2. BioaccessibilityINFOGEST in vitro digestion. Released in the gut lumen, not yet absorbed.
  3. Absorption, FaPermeability; human PK. Crossing the gut wall.
  4. First-pass escape, Fg · FhGut-wall and liver metabolism, where many botanical actives are conjugated.
  5. Bioavailability, F = Fa · Fg · FhHuman PK: AUC, Cmax. Rate and extent reaching the circulation.
  6. Exposure at the targetConcentration of the active form where it acts; exposure-based safety review.
  7. Pharmacodynamic activityBiomarker or mechanism response at that exposure.
  8. Clinical efficacyControlled human trials, only for the claim and dose studied.
21 CFR 320.1 (bioavailability definition); Amidon GL et al. Pharm Res. 1995;12:413–420; Minekus M et al. Food Funct. 2014;5:1113–1124; Brodkorb A et al. Nat Protoc. 2019;14:991–1014 (INFOGEST).
Dose and form move the margin; EGCG intakes span 5 to 1,000 mg/day, and a 10-fold exposure gain cuts a margin 10-foldEFSA 2018 Illustrative arithmetic
Left: EGCG intake from green tea infusions (mean 90 to 300 mg per day, high consumers up to 866) against supplements (5 to 1,000 mg per day), with 800 mg per day from supplements raising serum transaminases in trials. Right: illustrative arithmetic, a margin of 1,000 falls to 100 at ten times the exposure and to about 5 at 185 timesEGCG intake, mg/day (EFSA 2018)02004006008001,000Tea infusion, mean intakeTea infusion, mean intake: 90–300 mg/day90–300Tea infusion, highconsumersTea infusion, high consumers: up to 866 mg/dayup to 866SupplementsSupplements: 5–1000 mg/day5–1,000≥ 800 mg/day from supplements raised serum transaminasesSame plant; the dose and form differ.Illustrative: an exposure gain shrinks the margin1101001,000Native formNative form: margin 1,000.01,00010× exposure10× exposure: margin 100.0100185× exposure185× exposure: margin 5.4≈ 5.4Margin of exposure, log scale. Assumes linear kinetics andthe same active form; 185× is the micellar curcumin AUCratio.
EFSA ANS Panel. EFSA J. 2018;16(4):e05239. Micellar curcumin AUC ratio: Schiborr et al. 2014. Margin arithmetic assumes linear kinetics and the same active form.
Text version of the two examples
Published example

Concentration changes the margin: green tea catechins

EFSA estimated mean EGCG intake from green tea infusions at 90–300 mg/day, with high consumers up to 866 mg/day, and found supplements supplying 5–1,000 mg/day. It concluded that intakes of at least 800 mg/day from supplements increased serum transaminases in intervention trials. The plant is the same; the dose and form differ.

EFSA ANS Panel. EFSA J. 2018;16(4):e05239.
Illustrative arithmetic

Absorption gains and margins move together

If a margin of 1,000 had been established on an exposure basis for a native ingredient, the same dose in a form with 10 times the systemic exposure would leave a margin near 100, assuming linear kinetics and the same active form. With the 185-fold ratio reported for micellar curcumin, the reduction would be larger still. This is why EUTECNIQ would pair every bioavailability claim with an exposure-based safety review.

Reference points and margins →

EUTECNIQ would pair every bioavailability claim with an exposure-based safety review.

Explanation, details and sources

Each link in the chain has its own measurement; skipping a link is how bioavailability claims go wrong. Worked numbers, including the published curcumin formulation data, are on Bioavailability by design.

A margin of exposure divides a toxicity reference point (NOAEL or BMDL) by the estimated human intake. If a new form raises systemic exposure at the same dose, the exposure-based margin falls by that factor, unless the reference study is repeated with the new form or exposure is measured in both.

Safety travels with absorption. In the DILIN turmeric liver-injury series, 3 of the 7 products tested contained piperine, an absorption enhancer. Higher exposure is a safety question before it is a marketing claim.

Published curcumin exposure ratios, each relative to its own study's comparator

These ratios cannot be ranked against one another: doses, subjects, comparators, analytical methods and analytes differ, in particular whether free curcumin or total curcuminoids after enzymatic deconjugation were measured. Stohs et al. (2020) describe hydrolysis of plasma samples as a widely used but inappropriate practice for quantifying the active form, and Cuomo et al. (2011) detected only phase-2 metabolites.

185-fold

Micellar curcumin vs native powder, AUC of total curcuminoids

Schiborr et al. 2014 (n = 23)
45.9-fold

Hydrophilic-carrier formulation vs standardized curcumin in the same study

Jäger et al. 2014
7.9-fold

Phytosome formulation vs standardized curcumin in the same study

Jäger et al. 2014
29-fold

Phospholipid formulation vs standardized curcuminoid mixture

Cuomo et al. 2011

Schiborr C et al. Mol Nutr Food Res. 2014;58(3):516–527. Jäger R et al. Nutr J. 2014;13:11. Cuomo J et al. J Nat Prod. 2011;74(4):664–669. Stohs SJ et al. Molecules. 2020;25(6):1397.

Dose, form and genetic susceptibility in documented harms: Lessons learned. Reference points and margins: Toxicology.

Interactions

In human studies, botanicals raised or lowered the exposure to a co-administered drug by up to several-fold

Change in drug exposure caused by a botanical, measured in human volunteersHuman studies
Show data
BotanicalDrugExposure changeStudy
Green tea, 700 mL/day for 14 daysNadolol 30 mgAUC0–48 −85.0%; Cmax −85.3%Misaka et al. 2014 (n = 10 healthy volunteers)
St John's wortIndinavirAUC −57% (mean; SD 19)Piscitelli et al. 2000 (healthy volunteers)
Goldenseal, 14 daysMidazolam 8 mgAUC0–∞ 107.9 → 175.3 ng·h/mL (+62%)Gurley et al. 2008 (n = 16 healthy volunteers)
Grapefruit juiceFelodipine 5 mgBioavailability 284% of water (range 164–469%), i.e., +184%Bailey et al. 1991 (n = 6 men with borderline hypertension)
Misaka S et al. Clin Pharmacol Ther. 2014;95(4):432–438. Piscitelli SC et al. Lancet. 2000;355(9203):547–548. Gurley BJ et al. Clin Pharmacol Ther. 2008;83(1):61–69. Bailey DG et al. Lancet. 1991;337(8736):268–269. Values checked against the abstracts, October 22, 2026.

Inhibitors of first-pass metabolism raised drug exposure; inducers such as St John's wort lowered it.

Explanation, details and sources

Botanicals can raise or lower drug exposure several-fold

Inhibitors of first-pass metabolism, such as grapefruit furanocoumarins or goldenseal alkaloids, raise exposure. Inducers lower it: hyperforin from St John's wort binds the pregnane X receptor (Ki 27 nM) and induces CYP3A4 in human hepatocytes (Moore et al. 2000).

EUTECNIQ would offer a systematic interaction program following the NaPDI Center's recommended approaches (Paine et al. 2018) and the ICH M12 framework (2024): in vitro enzyme and transporter screens, static and physiologically based pharmacokinetic models, and partner-run clinical studies.

Evidence is coded by type: human study, in vitro or modeling, animal, or proposed mechanism. The OATP1A2 mechanism for the green tea–nadolol interaction is proposed by the authors ("possibly in part"), not proven.

Service: proposal

Moore LB et al. Proc Natl Acad Sci U S A. 2000;97(13):7500–7502. Paine MF, Shen DD, McCune JS. Drug Metab Dispos. 2018;46(7):1041–1045. ICH M12 Drug Interaction Studies (FDA final guidance, August 2024).

Risk intelligence

Botanical risk spans the whole lifecycle; four hazard types are mapped across five stages in one framework

Hazard typeOrigin and cultivationHarvest and storageExtraction and processingFormulation and productUse by consumers
Intrinsic chemical hazardsChemotype and species variationConstituent loss or degradationExtraction concentrates actives and toxicantsEGCG ≥ 800 mg/day raised ALT (EFSA 2018)Higher exposure from absorption enhancersTurmeric cases: 3 of 7 products with piperineIdiosyncratic liver injury; genetic susceptibilityHLA-B*35:01 in 7 of 10 (DILIN)
Extrinsic contamination and adulterationWrong species; soil metals; pesticidesAristolochia substitutionMolds, mycotoxins; co-harvested pyrrolizidine-alkaloid weedsPA exposure concern (EFSA 2017)Residual solvents; economic adulterationGinkgo: 3 of 8 spikedUndeclared drug adulteration776 products, 2007–2016Counterfeits and diversion
Exposure and interactionNo specific hazard mappedNo specific hazard mappedDose per serving set by the processRelease rate and dosage formCYP and transporter interactions; vulnerable groupsIndinavir AUC −57%
Process and manufacturingSupplier qualification; traceabilityDrying and storage conditionsProcess parameters; cleaning; cross-contactSpecification failuresTop Part 111 citation, FY2025: 111.70(e)Shelf-life drift
EFSA ANS Panel 2018 (green tea catechins); Halegoua-DeMarzio et al. 2023; Nortier et al. 2000; EFSA CONTAM Panel 2017 (pyrrolizidine alkaloids); Wohlmuth et al. 2014; Tucker et al. 2018, JAMA Netw Open (776 adulterated products with FDA warnings, 2007–2016); Piscitelli et al. 2000; FDA inspection observations, fiscal year 2025.
Explanation, details and sources

Red tags are documented cases. Evidence supports neither a pure-contamination nor a pure-intrinsic explanation of botanical harm, so both are controlled.

Framework: proposalCases: peer-reviewed and FDA data
A likelihood–severity score ranks the work; it never establishes that a product is safe. ICH Q9(R1) itself notes that risk scoring involves subjectivity.
Drug pathway

About 8% of phase 1 drug programs reached approval in 2011–2020, and FDA lists four approved botanical drug products

Share of Phase 1 programs reaching each later stage, all indications, 2011–2020Industry analysis
Show data
TransitionRateCumulative from Phase 1
Phase 1 → 252.0%52.0%
Phase 2 → 328.9%15.0%
Phase 3 → filing57.8%8.7%
Filing → approval90.6%7.9%
BIO, Informa Pharma Intelligence, QLS Advisors. Clinical Development Success Rates 2011–2020 (February 2021; 12,728 phase transitions). 0.520 × 0.289 × 0.578 × 0.906 = 7.9%.
FDA-approved botanical drug productsFDA
Product (active)ApplicationApprovedUse
Veregen (sinecatechins)NDA 0219022006External genital and perianal warts, topical
Fulyzaq, later Mytesi (crofelemer)NDA 2022922012Diarrhea in people with HIV/AIDS on antiretroviral therapy, when not caused by infection
NexoBrid (anacaulase-bcdb)BLA 7611922022Eschar removal in adults with deep partial-thickness or full-thickness thermal burns
Filsuvez (birch triterpenes)NDA 2150642023Wounds of dystrophic and junctional epidermolysis bullosa, from 6 months of age
FDA reviewers reported more than 800 botanical IND applications and pre-IND meeting requests in the years before 2018 (Wu et al. 2020). Submissions and approvals are different cohorts, so the two numbers are not a success rate.FDA, What Is a Botanical Drug? (content current as of September 3, 2026); FDA approval letter for BLA 761192 (December 28, 2022); Wu C et al. J Nat Prod. 2020;83(2):552–562; product labeling and sponsor announcements for indications.
Explanation, details and sources
EUTECNIQ's role

IND-enabling science and partners, not a self-funded pipeline

EUTECNIQ does not own a therapeutic pipeline. Its proposed role is the early part of drug development: characterization, mechanism and pharmacology screens, nonclinical safety under ICH M3(R2), and chemistry, manufacturing and controls (CMC) packages for an IND, sold as services or co-developed. Clinical development would be partner-funded.

The order of events matters. Under FD&C Act section 201(ff)(3)(B), an article first authorized for investigation as a new drug, with substantial clinical investigations made public, is excluded from the dietary supplement definition unless it was marketed as a food or supplement first. In letters of September 29, 2025, FDA concluded that NMN is not excluded because it was marketed as a supplement before that authorization. The route is decided for each candidate before any IND.

Roles: proposal

Trial design, sample-size calculators and published botanical trials are on Clinical research.

Mapping the evidence for an ingredient?

EUTECNIQ proposes evidence maps that separate what is established, what is plausible and what is untested, with the certainty of each human finding stated.