EUTECNIQ Sciences

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Quality by design and control strategy ICH guidance U.S. regulations Proposed practice

Quality by design starts from the quality a product must have, traces it to the materials and process parameters that move it, and builds the controls that hold it

The ICH chain from target profile to lifecycle, applied to four botanical product types and linked to the hazard analysis U.S. food rules require. Product tables are proposed starting points.

Related: a 3D design space with a reliability slider · scale-up and tech transfer

4ICH guidelines in one chain: Q8(R2), Q9(R1), Q10, Q12
4botanical product types with proposed target profiles and CQA tables
8long-term stability pull points for a 36-month claim under ICH Q1A(R2)
2.6–18×range of 25 °C shelf lives one 6-month accelerated result can imply

Status. EUTECNIQ has no products, processes or data; everything below is a proposal. ICH guidelines are written for drugs and serve here as good practice beside 21 CFR Part 111.

The ICH chain

Four ICH guidelines form one chain: product knowledge in Q8(R2), risk in Q9(R1), the quality system in Q10 and change in Q12

From target profile to lifecycle, and the guideline that governs each linkICH Q8(R2), Q9(R1), Q10, Q12
QTPPtarget profileQ8(R2) CQAswhat must staywithin limits RiskassessmentQ9(R1) CMAs andCPPsinputs that move CQAs Design spaceoptionalQ8(R2) ControlstrategyQ8(R2), Q10 Lifecyclemonitor, improveQ10, Q12 knowledge from routine production feeds back ICH Q8(R2) Pharmaceutical Development: QTPP, CQAs, design space, control strategy ICH Q9(R1) Quality Risk Management: applies at every step ICH Q10 Pharmaceutical Quality System ICH Q12 changes
ICH Q9(R1) states two primary principles: the evaluation of risk to quality "should be based on scientific knowledge and ultimately link to the protection of the patient," and "the level of effort, formality and documentation of the quality risk management process should be commensurate with the level of risk."ICH Q8(R2), Step 4, August 2009; ICH Q9(R1), adopted 18 January 2023; ICH Q10, Step 4, 4 June 2008; ICH Q12, adopted 20 November 2019. Diagram by EUTECNIQ.

Definitions in the guidelines' own words, with a botanical reading of each

Explanation, details and sources

A quality target product profile (QTPP) summarizes the quality the product should have. Attributes that must stay within limits become critical quality attributes (CQAs); risk assessment links them to the inputs that move them, and the control strategy holds those inputs.

TermDefinition (quoted)SourceFor a botanical extract (EUTECNIQ reading)
Quality target product profile (QTPP)"A prospective summary of the quality characteristics of a drug product that ideally will be achieved to ensure the desired quality, taking into account safety and efficacy of the drug product."ICH Q8(R2) glossaryIdentity, strength (marker content), contaminant limits, physical form, stability and packaging, written before development starts.
Critical quality attribute (CQA)"A physical, chemical, biological or microbiological property or characteristic that should be within an appropriate limit, range, or distribution to ensure the desired product quality."ICH Q8(R2) glossaryMarker content, fingerprint, residual solvent, water activity, microbial counts, elemental contaminants.
Critical process parameter (CPP)"A process parameter whose variability has an impact on a critical quality attribute and therefore should be monitored or controlled to ensure the process produces the desired quality."ICH Q8(R2) glossaryExtraction temperature and solvent composition; evaporator temperature; dryer outlet temperature.
Critical material attribute (CMA)"A physical, chemical, biological, or microbiological property or characteristic of an input material" that "should be within an appropriate limit, range, or distribution to ensure the desired quality of that drug substance, excipient, or in-process material."Yu LX et al., AAPS J 2014 (authors including FDA scientists); not an ICH glossary termSpecies and plant part, marker content and contaminant load of each raw lot, milled particle size.
Design space"The multidimensional combination and interaction of input variables (e.g., material attributes) and process parameters that have been demonstrated to provide assurance of quality."ICH Q8(R2) glossaryFor a drug, proposed by the applicant and approved by the regulator. Supplements have no such filing; a demonstrated region still documents why set points are where they are (see design space and optimization).
Proven acceptable range"A characterised range of a process parameter for which operation within this range, while keeping other parameters constant, will result in producing a material meeting relevant quality criteria."ICH Q8(R2) glossary; Part II, section 2.4.5One-factor ranges. Q8(R2) states that a combination of proven acceptable ranges does not constitute a design space.
Control strategy"A planned set of controls, derived from current product and process understanding that ensures process performance and product quality."ICH Q10 (quoted in the Q8(R2) glossary)Raw-material specifications and identity tests, set-point ranges, in-process checks, release tests and the stability program.
Process analytical technology (PAT)"A system for designing, analyzing, and controlling manufacturing through timely measurements (i.e., during processing) of critical quality and performance attributes of raw and in-process materials and processes with the goal of ensuring final product quality."ICH Q8(R2) glossary; FDA PAT guidance (2004)For example, near-infrared measurement of marker content during extraction.
Real time release testing"The ability to evaluate and ensure the quality of in-process and/or final product based on process data, which typically include a valid combination of measured material attributes and process controls."ICH Q8(R2) glossaryA long-term goal; it requires validated models and is not planned for early operations.
Risk"The combination of the probability of occurrence of harm and the severity of that harm."ICH Q9(R1) glossary (from ISO/IEC Guide 51:2014)Applied to consumers: an adulterated or contaminated lot reaching the market.
Established conditions"Legally binding information considered necessary to assure product quality."ICH Q12, section 3.2.1Applies to drug marketing applications only. Supplements have no marketing authorization, so there are no established conditions.
Four product types

Each product type has its own critical attributes, measured by named compendial methods and held at a specific step of the process

For a standardized dry extract, each critical attribute is held at a named stepProposed control points
Process control map for a standardized dry extract: identity, contaminants and microbes controlled at raw-material receipt; marker content at extraction set points and standardization; residual solvent at the evaporator end point and dryer; water, particle size and density at the dryer and packaging; release testing at the endRaw-material receipt1Identity test of eachlot; supplierqualification andraw-material testing;raw-material limitsIdentity andfingerprintElementalcontaminants andpesticidesMicrobial qualityExtraction2Set points: extractiontemperature andsolvent compositionMarker contentEvaporation3Evaporator end pointResidual solventStandardization4Carrier added to bringthe extract to itsdeclared strengthMarker contentSpray drying5Outlet temperature;atomizer setting; feedsolidsResidual solventWater and wateractivityParticle size anddensityPackaging6Moisture-barrierpackagingWater and wateractivityRelease7Release testingagainst thespecificationIdentity andfingerprintMarker contentMicrobial qualityMMQCreleaseATDTTICInstrument bubbles show proposed PAT uses from this page: AT, NIR or UV at the extraction end point; DT, evaporator end point by density (or refractive index); TIC,dryer outlet temperature held by feed-rate trim.Plant materialSolvent extractProductCritical quality attribute controlled here
Restates the "Where it is controlled" column of the dry-extract table below; hold times also bear on microbial quality. Equipment symbols are schematic, not to scale, and imply no vendor design.

Dry extract: identity and marker content lead; a wrong raw lot cannot be fixed later

Show the table (5 rows)
QTPP elementProposed targetWhy it is in the profile
IdentityStated species and plant part; drug-to-extract ratio and extraction solvent declaredA supplement maker must test the identity of every dietary ingredient (21 CFR 111.75(a)(1)(i))
StrengthMarker content within a stated range, set per productDefines the dose the customer formulates with
Purity and contaminantsLimits for residual solvent, elemental contaminants, pesticides and microbesPart 111 requires limits on contamination that may adulterate (111.70(b)(3) and (e))
Physical formFree-flowing powder with a stated particle size and bulk densityBlending and encapsulation downstream
StabilityRetest period supported by data in the commercial packageMarker loss and moisture uptake over time
Show the table (7 rows)
CQAWhy it is criticalHow it is measuredWhere it is controlled
Identity and fingerprintSubstitution and adulteration change the whole compositionUSP ⟨563⟩ Identification of Articles of Botanical Origin; ⟨203⟩ HPTLC procedure; HPLC fingerprintRaw-material receipt (identity test of each lot); release
Marker contentSets the declared strengthHPLC (USP ⟨621⟩ Chromatography), validated per ICH Q2(R2)Extraction set points; standardization with carrier; release
Residual solventSolvent left after evaporation and dryingUSP ⟨467⟩ Residual Solvents (headspace GC)Evaporator end point; dryer outlet temperature
Water and water activityMicrobial growth, caking and chemical changeUSP ⟨921⟩ Water Determination; ⟨922⟩ Water Activity; ⟨731⟩ Loss on DryingDryer outlet temperature; moisture-barrier packaging
Elemental contaminants and pesticidesCarried in from soil, water and cultivationUSP ⟨2232⟩ Elemental Contaminants in Dietary Supplements (with ⟨233⟩ procedures); ⟨561⟩ Articles of Botanical Origin (pesticides)Supplier qualification and raw-material testing
Microbial qualityBotanicals carry soil and plant microfloraUSP ⟨2021⟩, ⟨2022⟩ and ⟨2023⟩ (nutritional and dietary supplements)Raw-material limits; hold times; release
Particle size and densityBlend uniformity and capsule fillUSP ⟨429⟩ Light Diffraction Measurement of Particle Size; ⟨616⟩ Bulk Density and Tapped Density of PowdersAtomizer setting; feed solids

Nanoemulsion: droplet size and its stability fail first

Show the table (5 rows)
QTPP elementProposed targetWhy it is in the profile
Form and useOil-in-water liquid concentrate carrying a lipophilic extract, diluted into beveragesDisperses a poorly water-soluble active in water
StrengthMarker content per mL within a stated rangeDose per serving after dilution
Appearance after dilutionStated clarity or turbidity, no visible separationCustomer acceptance; depends on droplet size
Physical and chemical stabilityNo creaming or separation and limited oxidation over the retest periodA nanoemulsion is not thermodynamically stable, so it separates over time (McClements 2012)
Microbial safetyMicrobial limits met; preservation and pH system statedWater-based product
Show the table (6 rows)
CQAWhy it is criticalHow it is measuredWhere it is controlled
Droplet size and polydispersityGoverns creaming rate, Ostwald ripening and appearanceUSP ⟨430⟩ Particle Size Analysis by Dynamic Light ScatteringHomogenizer pressure and passes; emulsifier-to-oil ratio
Zeta potentialElectrostatic repulsion between dropletsElectrophoretic light scattering (ISO 13099-2)Emulsifier choice; pH and ionic strength
Marker contentDeclared strengthHPLC (USP ⟨621⟩), validated per ICH Q2(R2)Formulation; release
Oxidation of the oil phaseOff-flavor and loss of oxidizable activesPeroxide value (USP ⟨401⟩ Fats and Fixed Oils)Nitrogen blanketing; antioxidants; temperature during homogenization
pHPreservative efficacy and droplet chargeUSP ⟨791⟩ pHFormulation; in-process check
Microbial qualityWater-based productUSP ⟨2021⟩, ⟨2022⟩ and ⟨2023⟩Preservation system; hygienic filling; release
  • Small, stable droplets≠demonstrated bioavailability, which needs human pharmacokinetic data

Spray-dried powder: moisture and glass transition decide flow and protection

Show the table (4 rows)
QTPP elementProposed targetWhy it is in the profile
FormFree-flowing powder that disperses in waterUse in powders, tablets and beverages
Protection of the activeMost of the active inside the wall material, with little on the surfaceSurface active oxidizes and degrades first
StrengthActive content within a stated rangeDose
StabilityNo caking and limited loss over the retest periodAmorphous powders take up water and become sticky
Show the table (6 rows)
CQAWhy it is criticalHow it is measuredWhere it is controlled
Moisture and water activityLowers the glass transition temperature; supports microbial growthUSP ⟨921⟩; ⟨922⟩Outlet temperature; feed rate
Glass transition temperatureAbove it, an amorphous powder becomes sticky and cakesDifferential scanning calorimetry (USP ⟨891⟩ Thermal Analysis)Wall material; moisture
Encapsulation efficiencyShare of active protected inside the particleSurface versus total active by solvent wash and HPLC (no compendial method; method to be validated)Feed emulsion droplet size; solids; inlet temperature
Particle size, density and flowDosing and blendingUSP ⟨429⟩; ⟨616⟩; ⟨1174⟩ Powder FlowAtomization; feed solids
Physical stateRecrystallization changes dissolution and stabilityX-ray powder diffraction (USP ⟨941⟩)Formulation; storage humidity
Active content and residual solventStrength; solvent carried from the feedHPLC (USP ⟨621⟩); USP ⟨467⟩Feed preparation; drying

Capsule: Part 111 itself names the attributes

21 CFR 111.70(e) requires product specifications "for the identity, purity, strength, and composition of the finished batch of the dietary supplement, and for limits on those types of contamination that may adulterate."

Show the table (6 rows)
CQAWhy it is criticalHow it is measuredWhere it is controlled
Identity of each dietary ingredientRequired for every lot of every dietary ingredientAt least one appropriate identity test per dietary-ingredient lot (111.75(a)(1)(i)); botanical methods as aboveComponent receipt
Strength per capsuleLabel claimValidated assay (HPLC, USP ⟨621⟩)Blend uniformity; fill weight
Weight variationDose uniformity between capsulesUSP ⟨2091⟩ Weight Variation of Dietary SupplementsIn-process fill-weight checks
DisintegrationThe capsule must open for its contents to dissolveUSP ⟨2040⟩ Disintegration and Dissolution of Dietary SupplementsExcipients; capsule shell; storage humidity
ContaminantsAdulteration limitsUSP ⟨2232⟩; ⟨2021⟩–⟨2023⟩Component specifications; release
Water activityShell brittleness or softening; microbial growthUSP ⟨922⟩Room humidity; packaging

USP general chapter titles as registered by USP (USP–NF DOI records, Crossref prefix 10.31003), checked October 23, 2026; 21 CFR 111.70 and 111.75 (eCFR, current as of October 21, 2026); ICH Q2(R2), adopted 1 November 2023; ISO 13099-2 (2025 edition replaces 2012). Targets are EUTECNIQ proposals.

Which compendial methods serve which product type: one chromatography chapter serves all fourFrom the proposed CQA tables
Built from the "How it is measured" column of the four CQA tables above; node size counts the critical attributes a method serves. Attributes whose method has no compendial chapter are not drawn. Drag a node; hover for names.USP general chapter titles as listed on this page; ICH Q2(R2); ISO 13099-2.
Data table: methods by product type
MethodProduct types (number of CQAs)
The table fills in from the four CQA tables when the page's scripts run; the tables above list every method.

USP ⟨621⟩ chromatography appears in all four CQA lists; the water-activity (⟨922⟩) and microbial (⟨2021⟩, ⟨2023⟩) chapters each serve three.

Explanation, details and sources

A proposed QTPP and CQA list for four planned product types. Methods are USP general chapters or ICH guidelines; targets are placeholders each program would set from data.

Initial risk assessment

A cause-and-effect matrix ranks which inputs to study first; in this illustrative scoring, solvent composition and extraction temperature lead

Top-ranked input
Its score
Inputs with a 9 in this ranking
Process inputs × CQAs for a spray-dried standardized extractIllustrative scores Proposed
9 strong3 moderate1 weak0 none expectedCMA: critical material attribute candidate · CPP: critical process parameter candidate
Input (type)Identity and fingerprint
weight 10
Marker content
weight 10
Degradation products
weight 7
Residual solvent
weight 8
Water and water activity
weight 6
Particle size and flow
weight 4
Microbial quality
weight 9
Elemental and pesticide residues
weight 9
Weighted total
Botanical identity and plant part CMA93000013156
Marker content of the raw lot CMA39000000120
Contaminant load of the raw lot CMA0000000981
Bioburden of the raw lot CMA0000009081
Milled particle size CMA0310000037
Extraction temperature CPP39900010192
Extraction time CPP1330001070
Solvent composition (ethanol fraction) CPP99110001204
Solvent-to-solid ratio CPP0301000038
Evaporator temperature and vacuum CPP13930000127
Concentrate hold time CPP1330003088
Spray-dryer inlet temperature CPP0133331094
Spray-dryer outlet temperature CPP01399300169
Feed solids and feed rate CPP0013390085
Carrier ratio (e.g., maltodextrin) CPP09003300120
Initial risk assessment proposed by EUTECNIQ; scores are hypotheses, weights are management proposals, and neither is data. ICH Q8(R2) Part II, section 2.3, describes this use of risk assessment: rank parameters "based on prior knowledge and initial experimental data," then refine the list by experiment.
Why the 9 scores are 9 (mechanisms)
  • Identity and plant part → identity and fingerprint. A different species or part has a different set of constituents.
  • Raw-lot marker content → marker content. Extraction recovers a fraction of what the plant contains.
  • Contaminant load → elemental and pesticide residues. Extraction concentrates whatever is soluble; processing does not remove elements.
  • Bioburden → microbial quality. Without a microbial-reduction step, counts track the raw material.
  • Extraction temperature → marker content and degradation. Diffusion and solubility rise with temperature, and so do degradation rates (Arrhenius).
  • Solvent composition → identity, fingerprint and marker content. Ethanol fraction sets which constituents dissolve; the design-space study shows marker-type responses peaking near 60% ethanol.
  • Evaporator temperature → degradation. Time at temperature in the concentrate is the largest heat exposure.
  • Dryer outlet temperature → residual solvent and water. The outlet temperature sets the final moisture and the driving force for solvent removal.
  • Feed solids and rate → particle size. Droplet size from the atomizer scales with feed viscosity and solids.
  • Carrier ratio → marker content. Adding carrier is how an extract is standardized down to its declared strength.
Explanation, details and sources

Each cell scores how strongly an input should move a CQA on the 0, 1, 3, 9 scale; weighted row totals rank the inputs. Scores are mechanism-based hypotheses that designed experiments then confirm or demote.

Ishikawa diagram

A fishbone sorts the causes of out-of-specification marker content into materials, process parameters and measurement before the first batch

Six cause categories for an out-of-specification marker result, tagged by typeProposed analysis
Marker contentout ofspecification MaterialsWrong species or plant part · CMALow marker in the raw lot · CMAHigh moisture at receipt · CMAUnqualified supplier change · GMP MethodsExtraction temperature drift · CPPSolvent ratio off target · CPPConcentrate held too long · CPPStandardization math error · GMP MachinesJacket fouling slows heat-up · CPPWorn mill screen · CMADryer outlet sensor drift · CPPBalance out of calibration · GMP MeasurementReference standard purity · AnalyticalLow sample-prep recovery · AnalyticalCo-elution in the method · AnalyticalUnrepresentative sampling · Analytical PeopleTraining gaps · GMPTranscription errors · GMPSample mislabeling · GMP EnvironmentHeat or humidity in storage · CMALight and oxygen exposure · CMASeasonal raw-material variation · CMA
Tags: CMA, a material attribute to specify or test; CPP, a process parameter to control; Analytical, a cause in the test itself (an apparent failure); GMP, a system control. The tags decide the next action: a CPP goes into the designed experiments, an analytical cause into method validation (ICH Q2(R2)), a GMP cause into procedures and training.ICH Q8(R2), Appendix 2, example A; ICH Q9(R1), Annex I.1 (cause-and-effect diagrams). Causes are EUTECNIQ's proposed starting list.
Explanation, details and sources

ICH Q8(R2) Appendix 2 describes the sequence: draw an Ishikawa diagram, rank the causes with FMEA or a similar tool, then test the high-ranked ones by designed experiments. The operational-excellence library uses the same tool after a failure.

HACCP and preventive controls

Food-safety hazards follow a parallel logic: HACCP's seven principles and its decision tree find the steps where control is essential

FAO and WHO. General Principles of Food Hygiene, CXC 1-1969 (adopted 1969; revised 1997, 2003, 2020, 2022), sections 17 and 19; English text read in the FAO/WHO/Japan Food Hygiene Association bilingual edition. Definitions: a critical control point is "a step at which a control measure or control measures, essential to control a significant hazard, is/are applied in a HACCP system."

The decision tree asks four questions at each step where a significant hazard is identified

Choose a worked example or answer the questions.

About the worked examples

Choose a worked example or answer the questions yourself. The examples are illustrative teaching judgments, not a hazard analysis of a real process.

Q1. Can the significant hazard be controlled to an acceptable level at this step by prerequisite programs (e.g. GHPs)?

    Codex example CCP decision tree, with the current path highlightedCodex text
    Q1. Can the significant hazard be controlled to an acceptable levelat this step by prerequisite programs (e.g. GHPs)? Q2. Do specific control measures for the identified significanthazard exist at this step? Q3. Will a subsequent step prevent or eliminate the identifiedsignificant hazard or reduce it to an acceptable level? Q4. Can this step specifically prevent or eliminate the identifiedsignificant hazard or reduce it to an acceptable level? This step is not a CCP. This step is not a CCP. Evaluatesubsequent steps for a CCP. That subsequent step shouldbe a CCP. Modify the step, process or productto implement a control measure. This step is a CCP. Yes No No Yes Yes No No Yes
    Codex footnotes: at Q1, consider the likelihood and severity of the hazard and whether prerequisite programs suffice; if no CCP is found at Q2 to Q4, modify the process or product and repeat the hazard analysis; at Q4, if a control at this step works together with one at another step, both steps should be considered CCPs.FAO and WHO. CXC 1-1969, revised 2022, Annex IV, Figure 1 (example CCP decision tree); questions and outcomes quoted. Codex states that other tools can be used if the requirements of Step 7 are met.
    Explanation, details and sources

    The Codex General Principles of Food Hygiene (CXC 1-1969, revised 2022) apply seven HACCP principles in a 12-step sequence:

    StepTask (Codex wording)HACCP principle
    1Assemble HACCP team and identify scopePreliminary step
    2Describe productPreliminary step
    3Identify intended use and usersPreliminary step
    4Construct flow diagramPreliminary step
    5On-site confirmation of flow diagramPreliminary step
    6List all potential hazards that are likely to occur and associated with each step, conduct a hazard analysis to identify the significant hazards, and consider any measures to control identified hazards1. Conduct a hazard analysis and identify control measures
    7Determine the critical control points2. Determine the critical control points (CCPs)
    8Establish validated critical limits for each CCP3. Establish validated critical limits
    9Establish a monitoring system for each CCP4. Establish a system to monitor control of CCPs
    10Establish corrective actions5. Establish the corrective actions to be taken when monitoring indicates a deviation from a critical limit at a CCP has occurred
    11Validation of the HACCP plan and verification procedures6. Validate the HACCP plan and then establish procedures for verification to confirm that the HACCP system is working as intended
    12Establish documentation and record keeping7. Establish documentation concerning all procedures and records appropriate to these principles and their application

    U.S. law: Part 111 for supplements, Part 117 for dietary ingredients

    In U.S. law, finished supplements follow Part 111 and dietary-ingredient manufacture generally follows Part 117, whose preventive controls include but are not limited to CCPs.

    Part 117's hazard-analysis and preventive-control subparts do not apply to supplement operations that comply with Part 111; the exemption does not cover dietary ingredients sold to other manufacturers.

    The two rules use related but distinct terms:

    Topic21 CFR Part 111 (dietary supplements)21 CFR Part 117 (human food, incl. dietary ingredients)
    Who is coveredAnyone who manufactures, packages, labels or holds a dietary supplement (111.1(a))Food facilities. Subparts C and G do not apply to supplement operations "in compliance with the requirements of part 111" and FD&C Act section 761 (117.5(e))
    Where control is requiredSpecifications "for any point, step, or stage in the manufacturing process where control is necessary to ensure the quality of the dietary supplement" (111.70(a))Preventive controls for each "hazard requiring a preventive control" found by a written hazard analysis (117.130, 117.135)
    Hazard identificationThrough specifications for identity, purity, strength, composition and contaminant limits (111.70(b), (e))Biological, chemical (including radiological) and physical hazards that occur naturally, are introduced unintentionally, or are introduced "for purposes of economic gain" (117.130(b))
    Types of controlComponent, in-process and finished-batch specifications; identity testing; master and batch recordsProcess, food allergen, sanitation and supply-chain controls, a recall plan and other controls; controls at CCPs "if there are any CCPs" (117.135)
    CCP definitionNot used"A point, step, or procedure in a food process at which control can be applied and is essential to prevent or eliminate a food safety hazard or reduce such hazard to an acceptable level" (117.3)
    ValidationTests and examinations must be "appropriate, scientifically valid methods" (111.75(h)(1))Preventive controls must be validated as capable of controlling the hazards (117.160)
    EUTECNIQ proposalFinished-supplement operations under Part 111Ingredient-only operations under Part 117, with a written food safety plan; HACCP tools used inside it
    Questions for counsel Needs counsel
    • Which program covers an extract sold to a customer who only encapsulates or labels it? FDA's compliance guide applies Part 111 to an ingredient supplier whose customer "simply packages" or labels it as a supplement.
    • How should a site making both bulk extracts and finished supplements divide its Part 111 and Part 117 programs and records?
    • Which supplier-verification duties apply to imported botanicals (Foreign Supplier Verification Program, 21 CFR Part 1 Subpart L)?
    • Does any Part 117 exemption or modified requirement apply at the planned scale?

    No counsel opinions have been obtained yet; not legal advice. More on the two rules: quality system.

    eCFR, 21 CFR 111.1, 111.70, 111.75; 21 CFR 117.3, 117.5(e), 117.130, 117.135, 117.160 (current as of October 21, 2026); FDA, Small Entity Compliance Guide for the dietary supplement CGMP rule (citing 72 FR 34752 at 34791); 80 FR 55908 (September 17, 2015).

    Process analytical technology

    Measuring quality during processing lets a plant adjust the batch in progress; published studies show near-infrared models can track constituents during extraction

    At-line, on-line and in-line differ in where the sample goesFDA guidance definitions
    Three places to measure during processing: at-line, where a sample is removed and analyzed nearby; on-line, where a sample stream is diverted through an analyzer and may return; in-line, where a probe measures inside the streamProcess streamAt-line“the sample is removed, isolated from, andanalyzed in close proximity to the processstream.”On-line“the sample is diverted from the manufacturingprocess, and may be returned to the processstream.”In-line“the sample is not removed from the processstream and can be invasive or noninvasive.”AnalyzernearbySample removedAnalyzeron a side streammayreturnInvasive probeNoninvasive,through a windowDefinitions quoted from FDA's PAT guidance (2004), section IV. Drawings are schematic and imply no equipment choice.
    Relative differences can still drive feed-forward or feedback control.FDA. Guidance for Industry: PAT, a Framework for Innovative Pharmaceutical Development, Manufacturing, and Quality Assurance (September 2004), section IV.
    Text version of the three definitions
    • At-line: "the sample is removed, isolated from, and analyzed in close proximity to the process stream."
    • On-line: "the sample is diverted from the manufacturing process, and may be returned to the process stream."
    • In-line: "the sample is not removed from the process stream and can be invasive or noninvasive."

    FDA. Guidance for Industry: PAT, a Framework for Innovative Pharmaceutical Development, Manufacturing, and Quality Assurance (September 2004), section IV; Pan X et al. Sensors. 2015;15(4):8749–8763; Delueg S et al. Molecules. 2019;24(13):2480. Proposed uses are EUTECNIQ plans, not installed equipment.

    Explanation, details and sources

    FDA's PAT framework (September 2004) groups the tools in four categories and distinguishes three measurement locations. A measurement "need not be absolute values of the attribute of interest."

    The four tool categories, a published botanical example of each, and the proposed use:

    PAT tool category (FDA)Published botanical exampleProposed EUTECNIQ use
    Process analyzersOn-line NIR at pilot-scale extraction of Fructus aurantii, calibrated against HPLC for naringin, hesperidin and neohesperidin; ensemble PLS lowered prediction error (Pan et al. 2015). At-line NIR during maceration of rosemary leaves in 70% ethanol; test-set R² 0.93 to 0.96 for three reference assays (Delueg et al. 2019).NIR or UV at the extraction end point; UV switching at the resin-column cut point
    Multivariate tools for design, data acquisition and analysisPartial least squares calibration of spectra to reference assays (both studies above)Designed experiments and PLS models, validated before use for decisions
    Process control toolsNot shown in these studiesDryer outlet temperature held by feed-rate trim; evaporator end point by density or refractive index
    Continuous improvement and knowledge management toolsNot shown in these studiesTrending of CPPs and CQAs across lots (see control charts)
    Control strategy

    Control strategies range from extensive end-product testing to real-time engineering control, and a new botanical process would start at the testing end

    A new botanical process would start at level 3 and climb only with dataProposed starting point
    Three levels of control strategy as a staircase: level 3 relies on extensive end-product testing, level 2 on reduced testing within a design space, level 1 on real-time engineering control; a new botanical process would start at level 3Level 3Proposed starting pointExtensive end-product testing; tightlyconstrained material attributes and processparametersFor a botanical extract: Fixed set points and fullrelease testing of every lotLevel 2Reduced end-product testing; flexibleattributes and parameters within theestablished design spaceFor a botanical extract: Extraction time adjustedto raw-lot marker content within a demonstratedregion; reduced testing justified by dataLevel 1Automatic engineering control monitors theCQAs of output materials in real timeFor a botanical extract: PAT-based end pointsand real-time release; a long-term option thatneeds validated modelsLess end-product testing, more process understanding: each step up has to be earned with data
    Level descriptions paraphrase Yu et al. (quoted in full in the text version). ICH Q8(R2) lists what a control strategy can include: control of input material attributes, product specifications, controls for unit operations, in-process or real-time release testing, and a monitoring program for verifying multivariate prediction models.
    Text version: the three levels, quoted, and what each would mean for a botanical extract
    LevelDescription (quoted)What it would mean for a botanical extract
    Level 3"The level of control traditionally used in the pharmaceutical industry. This control strategy relies on extensive end-product testing and tightly constrained material attributes" and process parameters.Fixed set points, full release testing of every lot. The proposed starting point.
    Level 2"Pharmaceutical control with reduced end-product testing and flexible material attributes and process parameters within the established design space."Extraction time adjusted to raw-lot marker content within a demonstrated region; reduced testing justified by data.
    Level 1"Automatic engineering control to monitor the CQAs of the output materials in real time."PAT-based end points and real-time release; a long-term option that needs validated models.

    Yu LX, Amidon G, Khan MA, Hoag SW, Polli J, Raju GK, Woodcock J. Understanding pharmaceutical quality by design. AAPS J. 2014;16(4):771–783; ICH Q8(R2) Part II, section 2.5. The botanical column is EUTECNIQ's proposal.

    Explanation, details and sources

    Yu and co-authors, including FDA scientists, described three levels of control. Moving up a level replaces end-product testing with process understanding, which has to be earned with data.

    Stability as a CQA

    A 6-month accelerated result implies a 25 °C shelf life 2.6 to 18 times the 40 °C life, depending on activation energy

    ICH Q1A(R2), Step 4, 6 February 2003, section 2.1.7.1; ICH Q1E, Step 4, 6 February 2003. A consolidated revision of ICH Q1 reached Step 2 in April 2025; ICH's Q1 work plan of February 2026 anticipated Step 4 in November 2026. FDA, Small Entity Compliance Guide (Part 111), section IX, citing 72 FR 34752 at 34855.

    First-order loss with Arrhenius temperature dependencek(T) = k40 exp[ −EaR(1T − 1313.15 K) ]
    t90 = ln(10/9)k(T), k40 = −ln(1 − loss)6 months
    Rate constant at 40 °C
    t90 at 40 °C
    t90 at the storage temperature
    25 °C, if Ea = 50 kJ/mol
    25 °C, if Ea = 150 kJ/mol
    Lowest Ea giving the target at 25 °C
    Predicted time to 90% of the initial marker content, by storage temperature and activation energyIllustrative model

    Vertical axis is logarithmic. Amber marks combinations predicted to reach the target shelf life. Points mark the ICH long-term conditions at the chosen activation energy.

    Show data (predicted t₉₀ in months)
    Ea (kJ/mol)15 °C20 °C25 °C30 °C35 °C40 °C
    The table fills in when the page's scripts run; the equations give every value.
    Educational model with invented inputs; not a shelf-life assignment. A real program measures loss at several temperatures and humidities, checks that one mechanism holds, and confirms with long-term data at the labeled condition.Arrhenius equation (IUPAC Gold Book, "Arrhenius equation"); ICH Q1A(R2) storage conditions; ICH Q1E section 2.3 on extrapolation.
    Method, assumptions and limits
    What it calculates
    The first-order rate constant implied by a stated loss after 6 months at 40 °C, the rate at other temperatures for an assumed activation energy, and the time to 90% of the initial content (t90).
    Equations
    k40 = −ln(1 − f)/6 per month; k(T) = k40 exp[−(Ea/R)(1/T − 1/313.15)]; t90 = ln(10/9)/k; lowest Ea for a target t* at 25 °C: Ea = R ln(t*k40/ln(10/9)) / (1/298.15 − 1/313.15).
    Variables and units
    f fraction lost; T in kelvin; R = 8.314462618 J/(mol·K); Ea in kJ/mol; times in months.
    Assumptions
    Single first-order pathway; Arrhenius behavior from 15 to 40 °C; no humidity, oxygen or light effect; no change of physical state. One mechanism at every temperature; humidity ignored (40 °C/75% RH is also more humid than 25 °C/60% RH, which the model does not separate); activation energy is an input, not known until measured at several temperatures.
    Valid range
    Loss 1–25% at 40 °C; Ea 50–150 kJ/mol; 15–40 °C. The range of activation energies is illustrative, chosen to show sensitivity.
    What it does not establish
    A shelf life, a retest period or an expiration date. For drugs, ICH Q1E caps extrapolation and requires confirmation with long-term data.
    Verification
    Independent Python reference in tests/numerics/ref/platform-qbd-control-strategy.py, which integrates the rate law numerically to the 90% point.

    ICH Q1E caps extrapolation, so 12 months of real-time data support at most 24 months for a drug

    Choose what the data show and the months of long-term data.

    Scope of the cap

    The cap applies to room-temperature drug products; supplements have no federal equivalent.

    Longest retest period or shelf life that may be proposed
    Of which extrapolated beyond the data
    Arrhenius projection at 25 °C (model above)

    No significant change at the accelerated condition; little or no change and variability: up to twice, but not more than 12 months beyond, the long-term period (2.4.1.1).

    ICH Q1E, sections 2.4.1 and 2.4.2 (room-temperature storage). Supporting data and statistical conditions apply as stated in the guideline.

    Explanation, details and sources

    ICH Q1A(R2) sets the storage conditions; ICH Q1E limits extrapolation beyond real-time data, and the model above shows why. Supplements have no federal expiration-date requirement, but FDA says a firm "should have data to support any such date that you place on a product label."

    Study (general case)Storage conditionMinimum period covered by data at submission
    Long term25 °C ± 2 °C / 60% RH ± 5% RH, or 30 °C ± 2 °C / 65% RH ± 5% RH12 months
    Intermediate30 °C ± 2 °C / 65% RH ± 5% RH (none if 30 °C/65% RH is the long-term condition)6 months
    Accelerated40 °C ± 2 °C / 75% RH ± 5% RH6 months

    The Arrhenius model is also used on the science lab page (time course of an accelerated study) and drying and particle engineering (moisture and powder stability).

    Stability protocol

    ICH Q1A(R2) tests stability every 3 months in year one, every 6 in year two, then yearly through the shelf life

    Storage conditions and their tolerances, general case and refrigerated productsICH guidance (drugs)
    ICH Q1A(R2) general-case storage conditions as boxes of temperature and relative humidity with their tolerances: long term 25 C plus or minus 2 at 60 percent RH plus or minus 5 (or 30 C at 65 percent RH), 12 months of data at submission; intermediate 30 C at 65 percent RH, 6 months; accelerated 40 C at 75 percent RH, 6 months; refrigerated products: long term 5 C plus or minus 3, accelerated 25 C at 60 percent RH0 °C10 °C20 °C30 °C40 °C30%40%50%60%70%80%Relative humidityLong term 25/60: 25 °C ± 2 °C, 60% RH ± 5% RH; 12 months at submissionIntermediate 30/65: 30 °C ± 2 °C, 65% RH ± 5% RH; 6 months (or long term)Accelerated 40/75: 40 °C ± 2 °C, 75% RH ± 5% RH; 6 monthsRefrigerated products: long term 5 °C ± 3 °C (RH not specified), 12 months; accelerated 25 °C/60% RH, 6 monthsRefrigerated products: long term 5 °C ± 3 °C (RH not specified)General case (Q1A(R2) 2.1.7.1, 2.2.7.1)Long term 25/60: 25 ± 2 °C, 60 ± 5% RH12 months at submissionIntermediate 30/65: 30 ± 2 °C, 65 ± 5% RH6 months (or long term)Accelerated 40/75: 40 ± 2 °C, 75 ± 5% RH6 monthsIntermediate testing is called for after a significantchange at the accelerated condition. Drugguidance; Part 111 requires no expiration date, butany date on a label needs supporting data (FDA).
    ICH Q1A(R2), Step 4, 6 February 2003, sections 2.1.7 and 2.2.7 (storage conditions and minimum periods at submission).
    Long-term pull points8
    All pull points11
    Test occasions, 3 primary batches33
    Minimum pull points by storage conditionICH guidance (drugs)
    ICH Q1A(R2) sections 2.1.6 and 2.2.6 (testing frequency) and 2.2.3 (at least three primary batches).
    Method, assumptions and limits
    What it calculates
    The minimum time points ICH Q1A(R2) recommends for a proposed shelf life of at least 12 months, and the test occasions for three primary batches.
    Rules
    Long term: every 3 months over the first year, every 6 months over the second year, and annually thereafter through the proposed shelf life. Accelerated: at least three time points including the initial and final (e.g., 0, 3 and 6 months) from a 6-month study. Intermediate, when called for by a significant change at the accelerated condition: at least four time points (e.g., 0, 6, 9, 12 months) from a 12-month study. Refrigerated products: long term 5 °C ± 3 °C, accelerated 25 °C ± 2 °C/60% RH ± 5% RH, no intermediate condition.
    Valid range
    Shelf lives of 12 to 60 months in whole years. Reduced designs (bracketing, matrixing) and extra points near expected significant change are not modeled.
    Does not establish
    A shelf life or a regulatory obligation for supplements: Part 111 does not require an expiration date, though FDA expects data behind any date on a label. A consolidated revision of ICH Q1 is in progress (Step 2 April 2025).
    Verification
    Unit tests in tests/unit/qbd.test.js; independent reference cases in tests/numerics/ref/platform-qbd-control-strategy.py.

    A 36-month claim needs 8 long-term pull points, and every point is tested on at least three primary batches.

    Lifecycle

    After launch, the quality system keeps the process in its demonstrated region and routes every change through review

    Four Q10 elements keep the process in its region; Q12 tools stay with drugsICH Q10 (2008), Q12 (2019)
    ICH Q10 quality system: four elements in a cycle resting on two enablers, knowledge management and quality risk management; ICH Q12 tools for post-approval change apply to drug marketing applications onlyKeep the process in itsdemonstrated regionProcess performanceand product qualitymonitoringCorrective andpreventive action(CAPA)Change managementManagement reviewEnablers: knowledge management · quality risk managementICH Q10 (2008)ICH Q12 (2019): drug marketing applications onlyEstablished conditions: “legally binding informationconsidered necessary to assure product quality”Post-approval change management protocol (PACMP)Product lifecycle management (PLCM) documentA change to an established condition needs a submissionto the regulator. Supplements have no marketingauthorization, so these tools do not apply; EUTECNIQproposes written change control as good practice.
    ICH Q10, Pharmaceutical Quality System (Step 4, June 4, 2008), section 3.2 (elements) and section 1.6 (enablers); ICH Q12 (Step 4, November 20, 2019). Both are written for drugs; for supplements the change-control proposal is EUTECNIQ good practice.
    Text version of the ICH Q10 elements and ICH Q12 tools

    ICH Q10 elements

    • Process performance and product quality monitoring system
    • Corrective action and preventive action (CAPA) system
    • Change management system
    • Management review of process performance and product quality

    Enablers: knowledge management and quality risk management.

    ICH Q10, 2008

    ICH Q12 tools

    • Established conditions: "legally binding information considered necessary to assure product quality"
    • Post-approval change management protocol (PACMP)
    • Product lifecycle management (PLCM) document

    A change to an established condition needs a submission to the regulator.

    ICH Q12, 2019
    Explanation, details and sources

    ICH Q10 names four elements and two enablers. ICH Q12's change tools apply to drug marketing applications; for supplements EUTECNIQ proposes written change control as good practice.

    Scale-up rules, FDA's three process-validation stages and ICH Q10 technology transfer are on Scale-up and tech transfer.

    Build the quality case for a botanical product

    EUTECNIQ would answer a product concept with a proposed QTPP, CQA list, risk assessment and test plan.