How we score US prescription peptide sellers
We score each pharmacy and clinic out of 100 against the HHS policy's conditions. Every point needs a public source. If we could not confirm something, it scores 0.
100
points in total
18
checks scored
3
checks we run ourselves
10
HHS conditions
Version 2, October 29, 2026. Version 2 adds our own checks and the blend caps.
Information only. Not medical advice. A US-licensed prescriber decides. We do not sell, prescribe or take payment from these pharmacies.
The policy
- Name
- Enforcement Discretion Policy Regarding 503A Compounding Using Certain Peptide Bulk Drug Substances
- Federal Register
- FR Doc 2026-22192, published October 30, 2026 (filed for public inspection October 28, 2026)
- Docket
- HHS-OASH-2026-0496. Comments accepted until about November 13, 2026 (two weeks after publication); check the docket for the exact closing date.
- Who it covers
- A state-licensed pharmacy, a federal facility or a licensed physician. Not 503B outsourcing facilities.
- Sources
- Federal Register notice · HHS policy PDF · archived copy
The 10 conditions, in plain words
HHS says it will not take action only when all 10 are met.
- The peptide is one of the 6 in Appendix A: BPC-157, Epitalon, KPV, MOTS-c, Semax, TB-500.
- It matches the identity in Appendix B and is used only by the routes listed there.
- The ingredient comes from an FDA-registered facility, with a valid test certificate. The certificate covers identity, purity, potency, endotoxins, heavy metals, microbes and impurities.
- The original maker, not a repacker or distributor, is FDA-registered, follows good manufacturing practice, and its facility address is on the certificate.
- The pharmacy reports what it compounds, serious adverse events and quality problems to FDA (MedWatch) and to the states. The patient label explains how to report a problem.
- The label says: "This is a compounded drug product. Not for resale."
- One peptide per product. No blends.
- Oral forms need records showing the formula is absorbed well enough in people.
- The only device packed with it is an FDA 510(k)-cleared syringe.
- Every other FD&C Act rule still applies, including clean conditions and a prescription for each named patient.
What the policy does not do
- It is enforcement discretion, not FDA approval. HHS says compounded drugs are not FDA-approved.
- It is not binding. HHS may revisit or withdraw it, for example after a safety signal or a quality problem.
- State law and state pharmacy boards still apply, including licensing in the states a pharmacy ships to.
- It does not cover blends, other peptides, or sales without a prescription.
Our 3 checks
A site saying “prescription required” is not enough. We checked three things ourselves, for every seller.
- License: who fills the order, and is it active on its state board. We used the Texas board (it also lists out-of-state pharmacies licensed to ship into Texas) and the Michigan board.
- Checkout: we added the peptide to the cart and stopped at the first gate. We never made an account, typed personal data, entered a card or pressed pay.
- Wording: we read the product, home and FAQ pages for research-use labels. Text that only contrasts the seller with research peptides does not count.
- Two passes, with no fail on checkout or wording, confirm the prescription route. A fail on checkout or wording is a red flag.
Who gets ranked
- Ranked: our checks confirm the prescription route and a covered peptide is on sale now.
- Checked, not ranked: announced but not on sale, not seeing patients yet, or we could not confirm the route. The reason is shown.
- Never ranked: sellers with research-use wording, or a checkout that takes payment before any medical step, and 503B outsourcing facilities.
The 18 checks
A check scores its points on a pass. Fail, unknown and not applicable score 0.
| Check | Points | Pass means |
|---|---|---|
| Dispensing pharmacy license | 12 | We found who fills the order and its state board record is active, not on probation. For a clinic we look for its pharmacy in the terms, FAQ, refund policy and lab reports. If it is not named, it stays unknown. |
| Medical step before payment | 8 | We put the peptide in the cart and went to checkout. A medical intake or prescriber step comes before any payment, or there is no online sale at all. |
| No research-use wording | 4 | No "research use only", "not for human consumption" or similar text on the pages that sell it, the home page or the FAQ. |
| No FDA warning letter | 7 | No FDA warning letter to the company in the last 5 years. |
| No legal action found | 4 | No government enforcement action or court ruling against it found in 5 years. Our court search is not complete, so most sellers are unknown here. |
| Single peptide only, no blends | 4 | Only single-peptide products. Any blend, such as BPC-157 with TB-500, fails (condition 7). |
| Only the 6 covered peptides | 2 | No peptides outside the 6 are marketed, such as CJC-1295 or Melanotan II. |
| Routes allowed by the policy | 3 | Every route listed for a covered peptide is one the policy allows (Appendix B). |
| Check | Points | Pass means |
|---|---|---|
| Ingredient maker named | 8 | The maker of the peptide ingredient is named in public or on a public test certificate. |
| Ingredient maker FDA-registered | 9 | That maker is in FDA's drug establishment registration list (conditions 3 and 4). |
| Batch test reports | 8 | Lot test reports are public, or offered on request with a lot number. |
| PCAB or ACHC accreditation | 5 | PCAB or ACHC accreditation confirmed on the accreditor's own page. A claim on the seller's site alone stays unknown. |
| Endotoxin and sterility testing | 5 | Endotoxin and sterility results, or a specific testing program, are shown. |
| Check | Points | Pass means |
|---|---|---|
| Prices public | 5 | A public price for at least one covered peptide. |
| States listed | 3 | A list of states served, or an explicit all-50-states claim. |
| LegitScript certified | 5 | LegitScript certification confirmed on legitscript.com. A seal on the seller's site alone stays unknown. |
| Customer reviews | 5 | Trustpilot or similar: at least 4.0 from at least 20 reviews. Below 3.5 from 20 or more, or a removed profile, fails. |
| Policy label shown | 3 | The policy label text, "This is a compounded drug product. Not for resale.", is shown to patients (condition 6). |
Hard rules
- Unknown scores 0. We do not give part marks for a claim we could not check.
- Blends: a seller that sells a blend of covered peptides, such as BPC-157 with TB-500, loses 10 points and is capped at 45. The policy covers one peptide per product (condition 7).
- Other peptides: a seller that markets peptides outside the 6 loses 5 points and is capped at 40. Both together: capped at 35.
- Pens and auto-injectors: a seller that sells a covered peptide in a pen, an auto-injector or a pre-filled cartridge loses 10 points and is capped at 45. The policy allows only one device with the drug: an FDA 510(k)-cleared syringe (condition 9).
- Points are taken off before the cap, so a seller with blends always ranks below an otherwise equal seller without them.
- An FDA warning letter dated on or after October 29, 2023 caps the score at 40.
- Ties are ordered by the score before penalties and caps (more disclosure first), then by name.
- No seller pays to be listed or to rank. We take no payment from these pharmacies.
What we could not check
- Home-state licenses for out-of-state pharmacies. We used the Texas board's non-resident records and, for one pharmacy, Michigan's.
- Checkouts behind an account wall, a bot check or a site outage. These stay unknown.
- LegitScript status. Its public lookup is behind a captcha, so seals on seller sites count as claims only.
- PCAB and ACHC. We found no public pharmacy directory.
- Ingredient makers. No seller named one, so the FDA registration check is unknown for everyone.
- Which pharmacy fills orders for most clinics. Most do not name it.
- Court records. Our search is not complete, so “none found” is not scored as a pass for most sellers.