FDA Peptide Compounding in 2026: Decisions Explained
[Regulation · Compounding]

The FDA's 2026 Peptide Compounding Decisions, Explained

503A bulks list · Categories 1, 2, 3 · July 23-24, 2026 advisory meeting

Published · By Ethen Amezquita

Short answer: A US compounding pharmacy can only make a drug from a bulk ingredient that has a USP monograph, is part of an FDA-approved drug, or is on FDA's "503A bulks list". Most popular peptides meet none of those three. In 2026, nominations for many of them were withdrawn, FDA moved them off its category 2 table into a "withdrawn" list, and on July 23-24, 2026 its advisory committee reviewed seven peptides (BPC-157, KPV, TB-500, MOTS-c, emideltide, epitalon and semax). FDA staff recommended against adding all seven. Press reports say the committee voted to back BPC-157 and KPV. As of October 22, 2026, no final rule has been issued, so none of the seven is on the list.

"Is BPC-157 legal now?" "Can my clinic still get ipamorelin?" Most of the confusion about peptides in 2026 comes from one area of law: the rules on what pharmacies may compound. This guide explains those rules in plain words, then walks through what changed in 2026, using only FDA's own pages and documents. All dates are as of October 22, 2026.

What compounding is, and what it is not

Compounding means a pharmacist or doctor mixes a drug for a specific patient, usually from raw ingredients called "bulk drug substances." FDA's own slide deck for the July 2026 meeting sums up the basics: compounded drugs are not FDA-approved, which means FDA does not review them "for safety, efficacy, or manufacturing quality before marketing," and compounding under section 503A is "primarily overseen by state regulators."

Section 503A of the Food, Drug, and Cosmetic Act lets a licensed pharmacist or physician skip the normal approval, labeling and manufacturing rules if certain conditions are met. Section 503B covers larger "outsourcing facilities" and has its own, separate process. This article is about 503A, which is how most patient-specific peptide prescriptions are filled.

The three-door rule for ingredients

Under 503A, a bulk ingredient must pass through one of three doors. It must:

  1. comply with a USP or National Formulary monograph, if one exists; or
  2. if no monograph exists, be a component of an FDA-approved drug; or
  3. if neither applies, appear on FDA's list of bulk substances allowed for 503A compounding, the 503A bulks list.

FDA also requires that bulk ingredients come with a valid certificate of analysis and from an FDA-registered establishment. Most popular "research" peptides, including BPC-157, TB-500, KPV and MOTS-c, have no monograph and are not in any approved drug. FDA's July 2026 briefing documents say so for each one. That leaves only door three.

How a substance gets on the 503A bulks list

FDA started taking nominations in 2015. A 2019 final rule set four criteria FDA weighs together for each substance:

  1. how well the substance is characterized physically and chemically;
  2. safety issues raised by using it in compounded drugs;
  3. evidence that a compounded product works, or does not; and
  4. historical use in compounding.

FDA consults its Pharmacy Compounding Advisory Committee (PCAC) on each substance and then adds or rejects it through notice-and-comment rulemaking. The list is built slowly. FDA's page notes that the 2019 rule placed six substances on the list, and a proposed rule that year would add five and reject 26.

Categories 1, 2 and 3: the interim policy

Because the list is slow, FDA has an interim enforcement policy that sorts nominated substances into three categories:

  • Category 1: nominated with enough support to evaluate. FDA does not intend to act against pharmacies that compound with these while it decides, if the guidance conditions are met.
  • Category 2: enough support to evaluate, but FDA has identified "significant safety risks." FDA would consider enforcement action against compounding with these.
  • Category 3: nominated without enough supporting information. Also not covered by the category 1 policy.

FDA's guidance states it does not intend to place substances nominated on or after January 7, 2025 into these categories. So the category system only covers older nominations.

What changed in 2026

Withdrawn nominations, and a new "withdrawn" table

FDA's page on category 2 substances (content current as of April 22, 2026) now has a section titled "Bulk drug substances nominated but withdrawn." It says these substances were "previously in category 2" and that "the nominators" withdrew them. The table includes AOD-9604, BPC-157, cathelicidin LL-37, CJC-1295, dihexa acetate, emideltide (DSIP), epitalon, GHK-Cu for injectable routes, ipamorelin acetate, KPV, PEG-MGF, melanotan II, MOTS-c, selank acetate, semax, thymosin alpha-1 and the thymosin beta-4 fragment known as TB-500. FDA kept a summary of the safety concerns for each. The most common wording: a risk of immune reactions to injected peptides, problems with impurities, and little or no human safety data.

Being off the category 2 table does not make a substance allowed. With no nomination, it is not in category 1 either, and it still has no monograph, no approved drug and no place on the list. FDA's July briefing documents repeatedly note the nominations were withdrawn and that FDA chose to evaluate the substances "at its discretion."

GHK-Cu

FDA's category document, updated May 14, 2026, says GHK-Cu (except for injectable routes) was removed from category 1 on April 22, 2026 because the nominations were withdrawn. On May 5, 2026, one nominator said it wanted to keep its nomination for non-injectable routes, so GHK-Cu for non-injectable routes is being added back to category 1.

The same document lists some popular non-peptide substances in category 1

As of the May 14, 2026 update, category 1 includes nicotinamide adenine dinucleotide (NAD), NADH and enclomiphene citrate, among others. That means FDA is still evaluating them and its interim policy currently applies. See our posts on NAD+ injections and enclomiphene.

The July 23-24, 2026 advisory committee meeting

FDA announced the meeting in the Federal Register on April 16, 2026, with public docket FDA-2025-N-6895. The committee reviewed seven peptides, each in both free-base and acetate forms, for one proposed use each:

PeptideDayUse FDA evaluatedFDA staff position
BPC-157July 23Ulcerative colitisAgainst listing
KPVJuly 23Wound healing and inflammatory conditionsAgainst listing
TB-500July 23Wound healingAgainst listing
MOTS-cJuly 23As nominatedAgainst listing
Emideltide (DSIP)July 24As nominatedAgainst listing
EpitalonJuly 24As nominatedAgainst listing
SemaxJuly 24As nominatedAgainst listing

Each FDA evaluation ends with the same finding: "a balancing of the criteria weighs against" placing the substance on the list. For BPC-157 and TB-500, the detail is in our posts on BPC-157's human evidence and TB-500. FDA also gave a talk on "conflated bulks": many nominations did not say which salt form they meant, and FDA treats a free base and its acetate salt as two different ingredients.

The votes. FDA had not posted minutes on its meeting page when we checked on October 22, 2026. Trade press (RAPS) reported that the committee voted 8 to 6, with one abstention, to recommend BPC-157 for ulcerative colitis and also backed KPV, against the staff recommendation. We could not verify vote counts for the other five peptides from a primary source, so we do not report them.

What a "yes" vote does and does not mean

The committee advises. FDA decides, and it does so through rulemaking with public comment. FDA's briefing says it "will not issue a final determination" until the advisory process and its reviews are finished. Even if a peptide is eventually added, FDA's own slides list what that means: the compounded drug is still not FDA-approved, is not required to carry a label telling patients how to use it, does not have to follow manufacturing (CGMP) rules, and the pharmacy does not have to report adverse events to FDA. Unless the listing says otherwise, it could be compounded for any use by any route.

What this means for you

  • As of October 22, 2026, none of the seven peptides reviewed in July is on the 503A bulks list.
  • Products sold as "research use only" are a different matter. FDA has sent warning letters treating them as unapproved drugs; see what "research use only" means.
  • Rules can change after a final rule. Check FDA's bulk drug substances page for the current status before relying on any summary, including this one.
  • If you get a peptide from a pharmacy, keep the label, lot number and any certificate of analysis. Our COA guide explains what those documents show.

Whatever you use, Dose Track helps you keep the record straight: each vial's source and lot, its reconstitution date, and every dose you log against it.


Frequently asked questions

Is BPC-157 legal to compound in 2026?+
As of October 22, 2026, BPC-157 is not on the 503A bulks list, has no USP monograph and is not part of an FDA-approved drug, so it does not meet any of the three conditions for 503A compounding. An advisory committee recommended adding it in July 2026, but FDA had not issued a final rule.
What are FDA category 1, 2 and 3 bulk drug substances?+
They are interim policy groups for nominated ingredients. Category 1 substances are under evaluation and FDA does not intend to act against compounding with them if conditions are met. Category 2 substances raise significant safety risks. Category 3 substances were nominated without enough information. FDA does not place nominations made on or after January 7, 2025 into these categories.
Why were BPC-157 and other peptides removed from category 2?+
FDA's page says the nominators withdrew those nominations. FDA moved them to a "nominated but withdrawn" table and kept its summary of safety concerns. Removal from category 2 does not make them allowed.
Which peptides did the FDA advisory committee review in July 2026?+
BPC-157, KPV, TB-500 and MOTS-c on July 23, and emideltide (DSIP), epitalon and semax on July 24, each in free-base and acetate forms. FDA staff recommended against adding all seven.
Does an advisory committee vote change the law?+
No. The committee gives advice. FDA makes the decision through notice-and-comment rulemaking. Until a final rule is published, the substance is not on the 503A bulks list.
Is a compounded peptide FDA approved if it is on the bulks list?+
No. FDA's July 2026 presentation states that a drug compounded from a listed substance is still not FDA-approved, need not carry a label with directions, need not follow CGMP, and the compounder need not report adverse events to FDA.

Sources

Every number in this article comes from one of these sources, checked on October 22, 2026. This article is for education. It is not medical or legal advice, and nothing here is a dose recommendation.

  1. U.S. Food and Drug Administration. Bulk Drug Substances Used in Compounding Under Section 503A of the FD&C Act (content current as of May 14, 2026). fda.gov
  2. U.S. Food and Drug Administration. Bulk Drug Substances Nominated for Use in Compounding Under Section 503A (categories 1, 2 and 3; updated May 14, 2026). fda.gov/media/94155/download
  3. U.S. Food and Drug Administration. Certain bulk drug substances for use in compounding that may present significant safety risks (content current as of April 22, 2026). fda.gov
  4. U.S. Food and Drug Administration. July 23-24, 2026: Meeting of the Pharmacy Compounding Advisory Committee (agenda, questions, roster, briefing documents). fda.gov
  5. U.S. Food and Drug Administration. FDA Briefing Document, introduction, PCAC meeting July 23-24, 2026. fda.gov/media/193342/download
  6. U.S. Food and Drug Administration. FDA presentations, PCAC meeting July 23, 2026 (introductory remarks; conflated bulks). fda.gov/media/193773/download
  7. U.S. Food and Drug Administration. FDA briefing documents for BPC-157, KPV, TB-500, MOTS-c, emideltide, epitalon and semax. 193343, 193346, 193349, 193347, 193344, 193345, 193348
  8. Federal Register. Pharmacy Compounding Advisory Committee; Notice of Meeting; Establishment of a Public Docket (Docket No. FDA-2025-N-6895), April 16, 2026. federalregister.gov
  9. Regulatory Affairs Professionals Society (RAPS). FDA advisory committee backs two controversial peptides. July 23, 2026 (press report of the vote). raps.org