Regulatory · 2026

Are peptides legal in 2026?

RFK Jr. said fourteen peptides and Category 1. The FDA did twelve and neither. What is actually legal, corrected and updated for September 2026.

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Correction & update · 23 September 2026

An earlier version of this article, published in April, listed tesamorelin, sermorelin, CJC-1295, ipamorelin and AOD-9604 among the peptides covered by the February announcement, and described Category 1 as a list of substances eligible for compounding. Both statements were wrong. This version corrects them and covers what has happened since.

TL;DR

On 27 February 2026, HHS Secretary Robert F. Kennedy Jr. said on a podcast that roughly 14 of 19 restricted peptides would move back to Category 1. That was a statement of intent, not a regulatory action. What the FDA actually did, in late April, was take 12 peptides off Category 2 after their nominations were withdrawn. None was placed in Category 1 and none is on the 503A Bulks List. In July an advisory committee recommended six of them. As of September 2026, none of these peptides can lawfully be compounded on the strength of either the announcement or the vote.

What was said on 27 February, and what it was.

Kennedy made the remarks during an appearance on The Joe Rogan Experience. He said he expected an announcement within weeks, that around 14 of the 19 peptides the FDA had placed in Category 2 would move back to Category 1, and that he hoped people would end up with access through what he called ethical suppliers.

A statement from a cabinet secretary on a podcast carries political weight. It carries no legal weight. It did not amend any list, publish any rule, or change what a pharmacy may lawfully do. The coverage that followed, including a version of this article, treated the number 14 as if it described a regulatory decision. It did not.

What the FDA actually did in April.

On 16 April 2026 the FDA published a Federal Register notice setting dates for its Pharmacy Compounding Advisory Committee to review a group of peptides. Around a week later, twelve peptides came off Category 2: BPC-157, TB-500, KPV, MOTS-c, Epitalon, Semax, emideltide (DSIP), GHK-Cu in injectable form, melanotan II, cathelicidin LL-37, dihexa acetate and PEG-MGF.

They came off because the parties that had nominated them withdrew those nominations, not because the agency concluded they were safe. The FDA said explicitly that removal does not establish that a substance meets the criteria for compounding under Section 503A. And none of the twelve moved into Category 1. The number was twelve, not fourteen, and the destination was not the one announced.

What Category 1 and Category 2 actually are.

This is the part most coverage got wrong, including ours. Section 503A lets a licensed pharmacy compound for an individual patient using a bulk ingredient that has a USP monograph, is a component of an FDA-approved drug, or appears on the 503A Bulks List. That list can only be changed by a final rule, and it has admitted six substances since 1997, none of them peptides.

Since 7 January 2025, the FDA no longer assigns interim categories to newly nominated substances at all.

What happened in July.

On 23 and 24 July 2026 the advisory committee voted on seven peptides. BPC-157, KPV and TB-500 passed 8 to 6 with one abstention. MOTS-c passed 7 to 5 with two abstentions. Semax passed 8 to 5 and Epitalon 7 to 4. Emideltide failed. The FDA's own scientific reviewers had argued against the six that passed.

The committee's recommendations do not bind the FDA. Adding any of these peptides to the Bulks List requires formal notice-and-comment rulemaking, and HHS still has to act. The remaining five, including GHK-Cu, are due before the committee by the end of February 2027. We cover the vote in detail in a separate analysis and the list mechanism in our explainer on the 503A Bulks List.

The peptides that were never part of this story.

Several names that circulate alongside the announcement sit in entirely different positions:

The announcement said fourteen and Category 1. The agency did twelve and neither. That gap is the whole story of 2026 so far.

So, are peptides legal in 2026?

The accurate answer, as of 23 September 2026: none of the twelve peptides discussed here is on the 503A Bulks List, none is in Category 1, and the July recommendations have not been turned into a rule. Compounding them is not made lawful by the podcast remarks, by the removal from Category 2, or by the committee vote. The FDA retains its enforcement authority.

Products sold online as "research use only" are a separate matter. That label means they are not sold for human consumption, and nothing in 2026 has changed that. Ozemback does not link to, name or evaluate sellers of these products.

What we are tracking.

We will update this page when any of those things happens, and date every update.

Frequently asked questions

Are BPC-157 and GHK-Cu legal to compound in the United States in September 2026?

No. Neither is on the FDA's 503A Bulks List. BPC-157 was recommended by an FDA advisory committee in July 2026, but that recommendation is not binding and no rule has been published. GHK-Cu has not yet been reviewed by the committee; that review is due before the end of February 2027.

Did the FDA move 14 peptides to Category 1 in 2026?

No. On 27 February 2026 HHS Secretary Robert F. Kennedy Jr. said on a podcast that around 14 of 19 peptides would move back to Category 1. What the FDA actually did, in late April 2026, was remove 12 peptides from Category 2 after their nominations were withdrawn. None was placed in Category 1.

What is the difference between Category 1, Category 2 and the 503A Bulks List?

Categories 1 and 2 belong to an interim FDA policy for nominated substances still under evaluation. Category 1 means the agency does not currently intend to act against a substance while it evaluates it; Category 2 means it identified significant safety risks. The 503A Bulks List is the formal list in the Code of Federal Regulations, and only a final rule can add a substance to it.

What did the July 2026 advisory committee vote change?

Legally, nothing yet. The committee recommended BPC-157, KPV, TB-500, MOTS-c, Epitalon and Semax and declined emideltide. The FDA is not bound by those recommendations, and adding a substance to the list requires formal rulemaking.

Are tesamorelin, sermorelin, CJC-1295 and ipamorelin part of the 2026 reclassification?

No. Tesamorelin is an FDA-approved drug for one indication. Sermorelin sits on a separate legal pathway as a component of a formerly approved drug. The advisory committee voted against ipamorelin in October 2024 and against CJC-1295 in December 2024.

Sources & references

FDA · Apr 2026
Federal Register notice on peptide bulk drug substances and PCAC review datesUS Food and Drug Administration, 16 April 2026
FDA · Jul 2026
Pharmacy Compounding Advisory Committee meeting, 23 and 24 July 2026US Food and Drug Administration
FDA · 2024
Pharmacy Compounding Advisory Committee meetings, 29 October and 4 December 2024US Food and Drug Administration
FDA · 503A
Bulk drug substances used in compounding under Section 503A, including the interim category policyUS Food and Drug Administration
FR · 2013
Determination that Geref (sermorelin acetate) was not withdrawn from sale for reasons of safety or effectivenessFederal Register, 4 March 2013
NPR · Mar 2026
The wellness world is eager for RFK Jr.'s promised move on peptidesNPR, 31 March 2026
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The medications discussed here are prescription-only in the United States. They are legally dispensed through licensed clinicians and pharmacies, and through the telehealth platforms that hold direct supply agreements with Novo Nordisk and Eli Lilly. Ozemback is not a provider, takes no part in any clinical decision, and is not paid by any of them.

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