MOLRECORD
Topic primer

Regulation and policy

The regulatory position of unapproved peptides in the United States turns on two lists: Category 2 of the substances nominated for compounding, and the 503A bulks list. Since 2023 the compounds on this site have moved from one toward the other without arriving. Approved GLP-1 drugs are moving the other way, out of the 503B compounding route.

TIMELINE

  1. Sep 2023
    FDA places nineteen peptides, including BPC-157 and TB-500, in Category 2.
  2. Sep 2024
    Five substances (AOD-9604, CJC-1295, ipamorelin acetate, thymosin alpha-1, selank) leave 503A Category 2 after their nominations are withdrawn.
  3. 27 Feb 2026
    HHS Secretary says about fourteen will move toward compounding eligibility.
  4. 15 Apr 2026
    FDA removes twelve peptides from Category 2 after nominations are withdrawn; PCAC meetings scheduled.
  5. 30 Apr 2026
    FDA proposes excluding semaglutide, tirzepatide and liraglutide from the 503B bulks list.
  6. 23–24 Jul 2026
    PCAC recommends six peptides for the 503A bulks list; emideltide not recommended.
  7. 27 Aug 2026
    Fifth Circuit upholds removal of semaglutide and tirzepatide from the shortage list (to verify against the opinion).
  8. by Feb 2027
    Second PCAC peptide meeting on five further substances.

ENTRIES ON THIS TOPIC · 5

1 Oct 2026
PUBLIC
A public-health school explains the peptides in the feed

A 1 October 2026 Q&A from the Harvard T.H. Chan School of Public Health lists BPC-157, TB-500, MOTS-c, CJC-1295 and ipamorelin among synthetic peptides promoted online for recovery and performance.

25 Sep 2026
POLICY
The gray market and the state patchwork

An AJMC feature describes the July advisory vote passing over the objection of FDA staff scientists, states diverging on peptide compounding, and more than forty state attorneys general writing to the agency.

23–24 Jul 2026
REGULATION
Six peptides recommended for the 503A bulks list

On 23–24 July 2026 the FDA's Pharmacy Compounding Advisory Committee voted to recommend BPC-157, KPV, TB-500, MOTS-c, epitalon and Semax for the 503A bulks list. Emideltide was not recommended.

30 Apr 2026
REGULATION
FDA proposes to end 503B compounding of semaglutide, tirzepatide and liraglutide

A 30 April 2026 proposal would exclude the three GLP-1 drugs from the 503B bulks list, closing the outsourcing-facility route that opened during the shortage years.

15 Apr 2026
REGULATION
From Category 2 to review: how twelve peptides came off the restricted list

In September 2023 the FDA placed nineteen peptides in Category 2. In April 2026 it removed twelve of them after their nominations were withdrawn and scheduled advisory meetings to consider adding them to the 503A bulks list.