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Resource — regulatory reference

Peptide compounding status

Where each substance currently stands with FDA, and what that means for a 503A pharmacy or a product developer.

Last reviewed

Whether a substance can lawfully be compounded turns on which route it qualifies under, not on how widely it is sold. This page sets out where the commonly requested peptides and compounding substances sit today, and on what basis. It is a reference, not legal advice — confirm any substance against FDA's own bulk drug substances list before you formulate or purchase.

Section 503A

Three routes, and only three

Under Section 503A a bulk drug substance qualifies for compounding one of three ways. Everything on this page is sorted by which route applies.

The three statutory routes
RouteWhat it means
USP or NF monographThe substance has an active compendial monograph. Directly eligible.
Component of an approved drugThe substance is a component of a currently FDA-approved drug product. Directly eligible.
On the 503A bulks listFDA has placed the substance on the list through rulemaking. This is the route the headline peptides are waiting on.

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Route 01Directly eligible

USP or NF monograph

The substance has an active compendial monograph.

Eligible
Route 02Directly eligible

Component of an approved drug

The substance is a component of a currently FDA-approved drug product.

Eligible
Route 03Through rulemaking

On the 503A bulks list

FDA has placed the substance on the list through rulemaking. This is the route the headline peptides are waiting on.

Pending

A substance that qualifies under none of the three cannot be compounded from bulk, whatever its reputation or availability.

Status

Directly eligible today

These qualify through a compendial monograph or as a component of an approved drug. They do not depend on the 503A bulks list.

  • Eligible basis shown beside it
  • Qualified weaker or less settled footing
  • Not recommended committee outcome
Substances qualifying today, with basis
SubstanceBasisStatusNotes
GlutathioneUSP monographEligible—
OxytocinUSP monograph; component of an approved drugEligible—
MethylcobalaminUSP monographEligibleVitamin B12
Ascorbic acidUSP monographEligibleVitamin C
L-CarnitineUSP monographEligible—
NAD+Category 1QualifiedUnder evaluation, not identified as presenting significant safety risks. FDA exercises enforcement discretion — a weaker footing than a monograph.
Sermorelin acetateComponent of a formerly approved drugQualifiedThe reference product was withdrawn. Qualifying on a withdrawn product is less settled than on a current approval. Confirm before relying on it.

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Special case

GLP-1 receptor agonists: a special case

Semaglutide, tirzepatide and liraglutide are components of FDA-approved drugs, so they clear the first hurdle. That is not what governs them.

Timeline
What happenedWhen
Tirzepatide removed from FDA's drug shortage listOctober 2024
Semaglutide removed from FDA's drug shortage listFebruary 2025
FDA proposed excluding semaglutide, tirzepatide and liraglutide from the 503B bulks list30 April 2026
Comment period closed29 June 2026

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Where that leaves a 503A pharmacy

A compounded version of a commercially available drug is an "essentially a copy" problem. A pharmacy may compound these only where the prescriber documents a clinically significant difference for that specific patient — a documented allergy to an inactive ingredient in the commercial product, or a clinically justified concentration that is not commercially available. Patient preference and cost are not sufficient. Volume is capped at four or fewer prescriptions of that formulation a month.

Where that leaves a 503B outsourcing facility

If FDA's April proposal is finalised, neither the 503B bulks list nor the shortage list provides a basis to compound these from bulk.

Pending and restricted

Under review, and still restricted

Under review

FDA has scheduled a further advisory committee review for February 2027 covering GHK-Cu, Melanotan II, Cathelicidin (LL-37), Dihexa acetate and PEG-MGF. GHK-Cu was withdrawn from Category 1 in April 2026 ahead of that review.

Category 2

Substances FDA has determined raise significant safety concerns. A Category 2 designation effectively rules the substance out for 503A compounding.

The April 2026 change

FDA removed twelve peptide bulk drug substances from Category 2 in April 2026. Removal is not permission: those substances sit outside both categories pending advisory committee review and final agency action.

Category assignments move. Check FDA's own bulk drug substances list before relying on any status here.

Where we fit

We manufacture and we test. We do not dispense.

TPP Tech operates a sterile injectable manufacturing site in San Diego with an on-site analytical laboratory. We manufacture under contract and we test — identity, purity, content and safety — for compounding pharmacies, product developers and research-use suppliers.

Nothing on this page is a commitment to supply any particular substance. What we can do is tell you what a formulation needs analytically, and test it. See our peptide analytical testing services.

Talk to us about your program

FAQ

Frequently asked questions

Short answers on what the categories mean and what a recommendation does and does not change.

01Can a pharmacy compound BPC-157 or TB-500 right now?

No. FDA's advisory committee recommended both for the 503A bulks list in July 2026, but a recommendation is not authorisation. They reach the list through final rulemaking, which can take more than a year, and cannot lawfully be compounded until that is complete — even where pharmaceutical-grade API is available to buy.

02What does Category 1 actually mean?

That FDA is still evaluating the substance and has not identified significant safety risks, and is exercising enforcement discretion in the meantime. It is a weaker position than a USP monograph or a place on the 503A bulks list, and it can change.

03Is compounded semaglutide still legal?

Only narrowly. Semaglutide came off FDA's shortage list in February 2025, which removed the basis most compounders relied on. A 503A pharmacy may compound it where a prescriber documents a clinically significant difference for that specific patient, and fills four or fewer prescriptions of that formulation a month. Preference and cost do not qualify.

04Why were twelve peptides removed from Category 2 in April 2026?

FDA removed them ahead of advisory committee review. Removal is not permission — those substances now sit outside both categories pending review and final agency action.

05Does a USP monograph make a substance legal to compound?

It satisfies one of the three statutory routes under Section 503A. Other requirements still apply, including the restriction on compounding what is essentially a copy of a commercially available drug.

06Does TPP supply these substances?

We manufacture under contract and we test. We do not dispense compounded medicines, and this page is a regulatory reference rather than a product list.