The FDA's action against compounded peptides
In September 2023, the FDA moved several peptide bulk drug substances to its Category 2 list, significantly impacting compounding pharmacies and patients. Compounding pharmacies can no longer use these substances, as the FDA cited significant safety risks including insufficient safety data, potential impurities, and adverse immune response risks. This decision has sparked debate, with some arguing it limits access to beneficial therapies, while the FDA maintains it is necessary for drug safety.
The Category 2 bulk drug substance list
FDA regulations stipulate that compounding pharmacies may only use bulk drug substances meeting specific criteria. The FDA's list categorizes substances as:
- Category 1: Eligible for human compounding under certain conditions. GHK-Cu, in some forms, was added to this list.
- Category 2: Ineligible for human compounding due to identified safety risks. Using these substances violates federal law.
Specific peptides moved to Category 2
In late 2023, the FDA recategorized about 17 peptides as Category 2 substances, barring their use in compounding. Key peptides included:
- BPC-157: Cited for lack of human clinical data and safety concerns despite its use for tissue regeneration and gut health.
- Thymosin Beta-4 (TB-500): Known for tissue regeneration, it was restricted due to concerns about impurities and immunogenicity.
- Thymosin Alpha-1 (Ta1): Restricted for compounding due to safety concerns, though it was later removed for re-review in 2024.
- Epitalon: Moved to Category 2, linked to longevity research.
- AOD-9604: Studied for fat-loss, also placed on the restricted list.
- CJC-1295 and Ipamorelin: Initially restricted growth hormone secretagogues, later removed for re-review in 2024.
Why the FDA has taken action on peptides
The FDA's actions are based on ensuring drug safety and efficacy, citing:
- Insufficient human clinical trials: Much research is limited to animal or in vitro studies, lacking data for guaranteed human safety and effectiveness.
- Quality control concerns: Issues with purity and impurities in bulk peptide substances used in compounding.
- Immunogenicity risk: The potential for the body to develop an immune response, especially with injectables.
- Potential for misuse: Concerns about peptides being used for performance enhancement.
Navigating the peptide landscape: FDA-approved vs. compounded
A comparison highlights the differences in regulatory status and availability:
Feature | FDA-Approved Peptides (e.g., Semaglutide) | Compounded Peptides (e.g., BPC-157) |
---|---|---|
Regulatory Status | Approved for specific conditions after rigorous trials and manufactured under strict oversight. | Many in Category 2, banned for human compounding due to unestablished safety and efficacy. |
Legal Availability | Available by prescription. | Unlawful for compounding pharmacies; sometimes sold as "research chemicals" but warned against by the FDA for human use. |
Primary Use Case | Treating type 2 diabetes, weight management (Ozempic, Wegovy). | Historically used in alternative medicine for anti-aging, tissue repair, muscle growth, and gut health. |
Safety and Quality | Rigorous testing ensures consistency, purity, and safety with clear dosing and side effects. | Quality can be questionable, leading to risks from impurities, incorrect dosage, and unproven safety. |
Risks of unapproved peptide sources
Following restrictions, an unregulated market has grown, with online sales of peptides labeled "for research use only" (RUO). The FDA has issued warnings against using these unapproved products for human consumption. Risks include:
- Unknown quality and potency: Lack of oversight means products may not contain advertised amounts or be free of harmful impurities.
- Lack of storage standards: Improper storage and shipping can compromise the stability of products, especially those needing refrigeration.
- Potential for adverse events: Without clinical data, the human side effects, dosages, and long-term impacts are unknown.
Conclusion
The FDA's placement of peptides like BPC-157 and Thymosin Beta-4 on the Category 2 list restricts their use by compounding pharmacies. This is due to a lack of human safety data, quality control issues, and potential risks. While access is limited for some, the FDA prioritizes patient safety based on scientific evidence. Consumers should avoid unregulated sources and rely on FDA-approved treatments to minimize health risks.
Legal insight into peptide regulation
For more detailed legal analysis on the evolving regulatory landscape for compounded and bulk drug substances, including information on specific peptide categorizations, refer to articles from legal experts such as the Regulatory Affairs Professionals Society (RAPS).