Reference table
The peptides removed from Category 2 in April 2026 — are they lawful now?
The answer
No. Removal ended an explicit prohibition and conferred no authorization; the substances were not added to Category 1, they sit on no list, and no lawful compounding route followed from the removal.
Category 2 of the FDA's interim 503A bulks list is the category for substances with identified safety concerns, and placement in it bars a licensed pharmacy from compounding the substance. Leaving that category therefore reads, at a glance, like clearance.
It is not clearance. The alternative to Category 2 is Category 1, which holds substances under review without identified safety concerns and which pharmacies may compound while the review continues. The April 2026 action moved twelve peptides out of Category 2 and into neither category: they were removed without being listed. A substance on no list has no lawful compounding route, whatever the list it is no longer on was called.
Denominator
This index's own verified record states that twelve peptides were removed in April 2026; that figure comes from the ledger, not from this page. The rows below are the removed peptides this index tracks and carries a dated entry for, which is fewer than twelve. The remainder are outside this index's coverage, and this page does not name them rather than guess at them.
Rows are read from MOLECULES[].record[] entries dated April 2026, MOLECULES[].status — the same dated ledger the molecule index renders. No cell on this page is typed by hand.
| Molecule | Status today | What happened after the removal |
|---|---|---|
| BPC-157 | PCAC-recommended · pending | The Pharmacy Compounding Advisory Committee votes 8–6 (one abstention) to recommend adding BPC-157 to the section 503A bulks list. The vote is advisory; FDA rulemaking is required before any pharmacy may compound it. FDA has published no minutes, transcript or vote summary for this meeting; the tally is as reported by McDermott Will & Schulte and LumaLex Law. |
| DSIP | No lawful route | PCAC votes 6–7 (one abstention) against recommending 503A listing — the panel's only rejection. FDA has published no minutes, transcript or vote summary for this meeting; the tally is as reported by McDermott Will & Schulte and LumaLex Law. |
| Epitalon | PCAC-recommended · pending | PCAC votes 7–4 (one abstention) to recommend 503A listing; advisory only. FDA has published no minutes, transcript or vote summary for this meeting; the tally is as reported by McDermott Will & Schulte and LumaLex Law. |
| KPV | PCAC-recommended · pending | PCAC votes 8–6 (one abstention) to recommend 503A listing; advisory only. FDA has published no minutes, transcript or vote summary for this meeting; the tally is as reported by McDermott Will & Schulte and LumaLex Law. |
| MOTS-c | PCAC-recommended · pending | PCAC votes 7–5 (two abstentions) to recommend 503A listing; advisory only. FDA has published no minutes, transcript or vote summary for this meeting; the tally is as reported by McDermott Will & Schulte and LumaLex Law. |
| Semax | PCAC-recommended · pending | PCAC votes 8–5 (one abstention) to recommend 503A listing; advisory only. FDA has published no minutes, transcript or vote summary for this meeting; the tally is as reported by McDermott Will & Schulte and LumaLex Law. |
| TB-500 | PCAC-recommended · pending | PCAC votes 8–6 (one abstention) to recommend 503A listing; advisory only. FDA has published no minutes, transcript or vote summary for this meeting; the tally is as reported by McDermott Will & Schulte and LumaLex Law. |
Six of the removed peptides gained an advisory recommendation in July and none gained a lawful route; the vote ledger holds the arithmetic and the pending page holds the consequence. Every Category 2 removal this index carries a dated entry for was reviewed at that meeting; the peptides removed in April and never scheduled for review are outside this index's coverage, and this page does not name them rather than guess at them. A substance whose nomination was withdrawn, such as GHK-Cu, reached neither the removal nor the vote and is tracked on the nomination tracker instead.
Other tables
Evidence reviews