Peptide Policy Watch

Compounding

How compounding rules and FDA's bulk-substance categories work.

4 posts

Sign reading U.S. Department of Health and Human Services, Food and Drug Administration, with a campus office building behind it.
FDA campus entrance sign, with Building 21 behind it. Illustrative photo. Photo: The U.S. Food and Drug Administration, Public domain. Image credits

Ever read a headline about a "compounded" drug and wondered what that means? Compounding is when a pharmacist or physician makes a customized medicine instead of dispensing a mass-produced, FDA-approved one. Many peptide headlines are really compounding headlines.

Two sections of federal law matter. Section 503A governs compounding done by pharmacies licensed in their state, by federal facilities and by licensed physicians. Section 503B covers outsourcing facilities that register with FDA. [V] For each, FDA keeps a "bulks list" of substances that may be used. Nominated substances not yet on the 503A list are sorted into Categories 1 to 3 under an interim policy, which describes FDA's enforcement stance and is not an approval. [V] FDA also states that compounded drugs are not FDA-approved. [V]

Evidence labels: [V] verified in a primary document, [S] secondary source. Reviewed October 25, 2026.

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Common questions

Are compounded drugs FDA-approved?

No. FDA's Questions and Answers page says they are not. [V]

Is Category 1 an approval?

No. Category 1 is a limited enforcement stance: for a substance FDA is evaluating, it says it "does not intend to take action against a compounder" who meets its conditions. [V]

Key terms in plain English

503A
The part of the Food, Drug, and Cosmetic Act for pharmacy and physician compounding. [V]
503B
The part for outsourcing facilities that register with FDA. [V]
Bulks list
The list FDA keeps of bulk ingredients that compounders may use under that section. [V]
Interim policy
FDA's stopgap enforcement approach while it evaluates nominated substances. [V]

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