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FDA peptide categories, decoded, and what none of them means

FDA sorts nominated compounding substances into categories, and the labels get quoted everywhere. This page reads the primary pages as of 30 October 2026: 17 substances sit in the "nominated but withdrawn" table, 14 in Category 2, and a new HHS enforcement policy is not an approval.

Figures read
30 October 2026, from the primary source
Next review
30 November 2026
Compiled and checked by
Whitepill editorial desk
Published
30 October 2026

Whitepill finding

On 30 October 2026, FDA's safety-risks page, current to 22 April 2026, listed 17 substances in its "nominated but withdrawn" table and 14 in Category 2, including ibutamoren mesylate (sold as MK-677). The same day, HHS published a draft, non-binding policy holding off enforcement on compounding certain peptides, which is neither an approval nor the 503A list.

FDA's page read in full on 30 October 2026 and parsed from its two tables; the Federal Register notice read the same day.

The short version

FDA categories: claims against the recordwhat gets said, and what the record shows, read 30 October 2026

What do FDA's categories mean?

Under its interim policy, FDA sorts bulk drug substances nominated for compounding into categories, defined on its 503A bulks page (content current as of 14 May 2026). Category 1 holds substances that may be eligible for the list, Category 2 ones where FDA has identified significant safety risks, and Category 3 ones nominated with too little supporting information. A separate safety-risks page carries the Category 2 details and a table of substances "nominated but withdrawn".

The labels describe how FDA sorted a nomination under a temporary policy. None of them is an approval.

The interim-policy categoriesas FDA's 503A page defines them, content current as of 14 May 2026
FDA interim policy categories for bulk drug substances nominated for compounding: Category 1 (may be eligible), then Category 2 (significant risks), then Category 3 (too little data), then Withdrawn (nominators pulled it)Category 1may be eligibleCategory 2significant risksCategory 3too little dataWithdrawnnominators pulled it
Category 1 substances may be eligible for the 503A list, and FDA does not intend to act against compounders using them if conditions are met. Category 2 substances have identified significant safety risks. Category 3 substances were nominated with insufficient supporting information, and withdrawn substances are ones that were in Category 2 until the nominators withdrew them.

Which peptides sit where, as of this page?

FDA's page, read in full on 30 October 2026 and parsed from its two tables, lists 17 substances as "nominated but withdrawn", including BPC-157, CJC-1295, Epitalon, GHK-Cu (injectable routes), Melanotan II, Selank, Semax and TB-500. These were in Category 2 until the nominators withdrew them. Listing a name here is not a recommendation or a safety finding.

Category 2 itself lists 14 substances. Here are some of them, with the routes FDA lists them for.

Some Category 2 substances and their routesparsed from FDA's table, read 30 October 2026
SubstanceListed forNote
Ibutamoren mesylate (sold as MK-677)503A; 503BFDA cites a potential for congestive heart failure in certain patients
Ipamorelin acetate503BAlso appears in the withdrawn table
Growth hormone releasing peptides 2 and 6503BSee FDA's table for the full entry
Kisspeptin-10503ASee FDA's table for the full entry
A listing here is FDA's safety label under a temporary policy, not a recommendation or a verdict on any person.

Many blogs still call the withdrawn peptides "Category 2, do not compound"; those predate the April 2026 change, which a law-firm alert (secondary) also reported. For the one that matters most to this scene, see BPC-157: status, trials and harms.

2026 so farofficial pages and press reports, dated
Peptide regulation events, April to October 2026. 2026-04-22: 22 Apr, Safety-risks page date. 2026-05-14: 14 May, 503A page date. 2026-07-23: 23 Jul, Advisory votes. 2026-08-24: 24 Aug, Letters, per a law firm. 2026-10-30: 30 Oct, HHS draft policyMayJunJulAugOctNov22 AprSafety-risks page date14 May503A page date23 JulAdvisory votes24 AugLetters, per a law firm30 OctHHS draft policy
The April and May points are the "content current as of" dates printed on FDA's pages. The 30 October point is a Federal Register notice from HHS. The July votes and August letters come from news and law-firm reports, and the text says which.

What is the HHS enforcement discretion notice?

On 30 October 2026 HHS published a Federal Register notice (91 FR 68526) announcing a draft policy under which it does not intend to take enforcement action against a state-licensed pharmacy, federal facility or licensed physician compounding with a listed peptide. It applies while FDA develops the 503A bulks list through rulemaking. The notice says the draft is not binding on HHS or the public.

Read the reasoning

Is an advisory committee vote a decision?

No. The committee voted 8 to 6, with one abstention, on 23 July 2026 in favor of adding BPC-157 to the 503A list, according to ABC News (secondary), and Time (secondary) reported that the committee went against FDA staff advice. A vote advises FDA, and the agency decides through its own process.

Leaving Category 2 does not by itself make a substance eligible for compounding, as a JD Supra summary (secondary) notes.

From nomination to the lista category is not a decision
The path from nomination to the 503A bulks list: Nominated (a request to FDA), then Category (interim label), then Advisory vote (advice, not a ruling), then FDA rulemaking (the decision)Nominateda request to FDACategoryinterim labelAdvisory voteadvice, not a rulingFDA rulemakingthe decision
An advisory committee votes on whether a substance should be on the list, and FDA then decides through its own process. HHS enforcement discretion sits beside this path: it says what HHS does not intend to pursue meanwhile, and it adds nothing to the list. As of 30 October 2026 we found no final FDA action on the 503A list.

Does "research use only" on a label change anything?

Not in FDA's view, according to a law-firm summary. Arnall Golden Gregory reported (secondary) that FDA sent warning letters to five online peptide sellers on 24 August 2026 after reviewing their websites. It also reported that, according to those letters, FDA treats the whole presentation of a product, including disease claims, dosing guidance and reconstitution tools, as evidence of intended drug use.

We have not confirmed from FDA's own database which products each letter named, so this rests on one law firm's summary. It is one reason Whitepill publishes no dosing or sourcing information.

How to read any peptide status claim
1. Find the substance on FDA's own pages, not a blog.
2. Note which table it is in, and the "current as of" date.
3. "Withdrawn" and "Category 2" mean different things; a page that mixes them up is out of date.
4. An advisory vote is advice, and an HHS enforcement policy is not an approval. Wait for FDA's action on the list.
5. "Research use only" on a label does not settle anything by itself. FDA looks at the whole presentation.

How should you use this?

How this was read

Method

FDA's two pages were fetched and read in full on 30 October 2026, and table membership comes from parsing the pages' two real tables, with the raw pages stored as dated, hashed snapshots. The HHS notice was read through the Federal Register's API and text, and its appendices could not be opened.

News and law-firm reports are labelled as secondary where they appear and may be wrong or out of date. This page explains labels; it does not give legal or medical advice, and it contains no dosing, protocol or sourcing information.

FAQ

What is FDA Category 2 for peptides?

Under FDA's interim policy, Category 2 holds bulk drug substances nominated for compounding where FDA has identified significant safety risks. It is a sorting label under a temporary policy, not an approval and not a final ruling.

Is BPC-157 in Category 2?

Not on FDA's safety-risks page as of its content date of 22 April 2026, which we read on 30 October 2026. It sits in the table of substances nominated but withdrawn. Many older blogs still call it Category 2.

What does "nominated but withdrawn" mean?

It is FDA's table for substances that were in Category 2 under the interim policy until the nominators withdrew their nominations. It is not an approval, and FDA's own text for BPC-157 still says it has identified no, or only limited, safety information.

What is the HHS enforcement discretion policy?

A draft policy HHS announced in a Federal Register notice on 30 October 2026. It says HHS does not intend to take enforcement action against state-licensed pharmacies, federal facilities or licensed physicians compounding with listed peptides while FDA develops the 503A list. It is not binding, not an approval and not the list itself.

Did FDA approve BPC-157 for compounding in July 2026?

No. An advisory committee voted 8 to 6, with one abstention, on 23 July 2026 in favor of adding it to the list, according to ABC News and Time. That vote is advice to FDA, and we found no final FDA action when we read on the date above.

Does "research use only" make a peptide legal to sell for people?

According to a law-firm summary of FDA warning letters sent on 24 August 2026, FDA looks at the whole presentation of a product, and dosing guidance or reconstitution tools on a seller's site are treated as evidence of intended drug use. We have not confirmed that from FDA's own records, and we do not give legal advice.

Bottom line

A category is a sorting label, a vote is advice, an enforcement policy is not an approval, and a label on a vial is a claim. Read the table, the date and the primary page yourself, and take any decision about your own health to a licensed clinician.

Related on Whitepill

Compound checkBPC-157: status, trials and harmsFDA status, the HHS draft policy, trial counts and test results.Compound checkMK-677 (ibutamoren): status, trials and harmsMore trials is not safer: a Category 2 listing for heart failure risk.EvidenceThe evidence ladderTrial depth for training, creatine, sunscreen and BPC-157, side by side.