Peptifact

FDA's Category 2 List, Indexed: Every Substance, Every Section, Every Date

FDA's list of bulk drug substances that may present significant safety risks holds fourteen entries. Five are peptide-class, four of those are growth hormone secretagogues, and six of the fourteen were added on a single day in 2023. Here is the whole record, dated.

Robert F · Edited by Caroline S · Published 2026-09-13

Illustration: Precision scale with a clear glass vial containing lyophilized powder on a cool grey lab bench.
Illustration

FDA maintains one table of bulk drug substances it has identified as presenting significant safety risks in compounding. It is cited constantly in writing about peptides, usually second-hand and almost never in full. This page indexes it: every substance, which statutory section it falls under, and the date it was added, read directly from FDA's page on 13 September 2026.

What the two sections mean, and why the same substance can carry different answers under each, is set out in our explainer on 503A and 503B compounding. This page does not repeat that argument. It publishes the record.

The whole category 2 table

Fourteen substances, as the page stood when read. FDA's page content is marked current as of 22 April 2026.

# Substance Section Date added
1 Domperidone 503A 27 October 2015
2 Germanium sesquioxide 503A 9 June 2016
3 Quinacrine hydrochloride (intrauterine) 503A 9 June 2016
4 Cesium chloride 503A 30 July 2018
5 Quinacrine hydrochloride (intrauterine) 503B 7 June 2021
6 Chloral hydrate 503B 5 October 2022
7 Edetate disodium (except ophthalmic) 503B 12 October 2022
8 Neomycin sulfate (parenteral, non-ophthalmic/otic) 503B 12 October 2022
9 Ibutamoren mesylate 503B 29 December 2022
10 Diethylstilbestrol 503B 21 August 2023
11 GHRP-2 (injectable/nasal) 503B 29 September 2023
12 GHRP-6 503B 29 September 2023
13 Ipamorelin acetate 503B 29 September 2023
14 Kisspeptin-10 503A 29 September 2023
15 Ibutamoren mesylate 503A 29 September 2023
16 Tranilast 503B 29 September 2023

Sixteen rows, fourteen substances: quinacrine and ibutamoren each appear twice, once under each section. Peptide-class entries are in bold.

FDA's stated grounds vary by substance and are summarised on the page itself. For the peptide entries they cluster on immunogenicity — the risk that an injected peptide provokes an immune response — together with insufficient safety data, and for the secretagogues, endocrine effects. Both grounds are prospective rather than retrospective, which they had to be: when we counted the reports FDA actually holds for these compounds, ipamorelin returned eleven and kisspeptin none, which is far too little to reason from. The empty adverse-event column is not for want of clinical study — the published human record for kisspeptin runs to dozens of supervised infusion protocols with doses stated to two decimal places. For the small molecules they are conventional and severe: cardiac arrhythmia and sudden death for domperidone, nephrotoxicity for germanium sesquioxide, carcinogenicity for diethylstilbestrol, confusion between two similarly named chelating agents for edetate disodium.

Three things the dates say

Nearly half the list arrived on one day, and that day was about peptides. Six of the fourteen substances carry the date 29 September 2023. Five of those six are the peptide-class entries; the sixth is tranilast. Before that day the table held eight substances and one peptide. After it, it held fourteen and five.

The peptide entries are recent, and the list is not. Domperidone has been on it since October 2015 — almost eight years before any peptide joined it. A reader arriving at this table from a peptide article will naturally read it as a peptide list. It is not one, and never was: nine of the fourteen entries are conventional small molecules, several with decades of clinical history behind the concern.

Nothing gets added to both sections at once. The two substances that carry entries under both — ibutamoren mesylate and quinacrine hydrochloride — acquired them nine months and just under five years apart respectively. That is the clearest available evidence that these are two processes rather than one: a single decision applied to both sections would produce a single date, and it never has.

Four of the five peptides are the same kind of thing

Read as a class rather than a list, the September 2023 action narrows further. GHRP-2 and GHRP-6 are growth hormone releasing peptides. Ipamorelin is a growth hormone secretagogue. Ibutamoren — sold in the research market as MK-677, and not a peptide at all but a spiroindane small molecule — is an orally active agonist at the same receptor. Four of the five peptide-class entries act on one axis.

Kisspeptin-10 is the exception, and it is also the only peptide entry placed under 503A rather than 503B.

That matters for anyone reading the table to work out what FDA thinks about peptides generally. On this record the agency has not acted against peptides as a category. It has acted against growth hormone secretagogues, plus one reproductive-axis peptide, in a single 2023 action, under whichever section each was nominated.

The withdrawn list is the one the research market should read

Lower on the same FDA page sits a separate section for substances nominated for use in compounding whose nominations were later withdrawn. Sixteen substances are listed, and this is the finding worth the page:

Substance Also known as
AOD-9604 hGH fragment 176-191
BPC-157 body protection compound 157
Cathelicidin LL-37 LL-37
CJC-1295
Dihexa acetate
Emideltide DSIP, delta sleep-inducing peptide
Epitalon epithalon, AEDG
GHK-Cu (injectable routes) copper tripeptide-1
KPV α-MSH 11-13
Mechano growth factor pegylated PEG-MGF
Melanotan II
MOTS-c
Selank acetate TP-7
Semax heptapeptide
Thymosin alpha 1 Tα1, thymalfasin
Thymosin beta-4 fragment TB-500

Every one of the sixteen is a peptide. Where category 2 is five peptides out of fourteen entries, the withdrawn section is sixteen out of sixteen — and the substances in it are, close to item for item, the catalogue a research supplier sells. Thirteen of the sixteen carry a dosage reference on this site, which is a reasonable proxy for how much search demand each one draws; the three without one are dihexa acetate, PEG-MGF and cathelicidin LL-37.

Seven of the sixteen are under active reconsideration. On 23-24 July 2026 FDA's Pharmacy Compounding Advisory Committee considered BPC-157, KPV, TB-500, MOTS-c, emideltide (DSIP), semax and epitalon for the 503A bulks list — the list that would permit compounding from them. It recommended six and voted against emideltide, with semax passing 8-5, epitalon 7-5 with one abstention, TB-500 8-6 against FDA staff's own position, and emideltide failing 6-7 with one abstention. Those votes are advisory, FDA has not acted on them, and none of them changes the table above. What they do establish is that the withdrawn section is not a closed record. The vote and its limits are covered on our page on cognitive peptides.

A withdrawn nomination is a procedural status and nothing more. It means the process that would have produced a listing did not run to completion. It is not a safety finding, it is not a clearance, and it is misreported in both directions — sellers cite the absence of a restriction as though FDA had looked and approved, and critics cite the withdrawal as though FDA had looked and refused. Neither happened. What we can say about the regulatory position of these substances is set out in our page on what the rules actually say about peptides.

What this table cannot tell you

It says nothing about a vial bought from a research supplier. Both sections describe compounding — a pharmacist, physician or registered facility making a drug for human use under defined conditions. Material shipped under the caution labelling of 21 CFR 312.160 sits elsewhere in the framework entirely, which is the distinction FDA's own enforcement correspondence turns on in the letters we track on the FDA warning letter tracker.

It says nothing about what is in any particular vial. A substance's listing status is a fact about the substance; what a seller shipped is a question answered by testing it, which is why a certificate of analysis is read the way our guide to reading a COA describes and a listing status is not a substitute for one.

And it says nothing about legality for any specific person, product or transaction. That is a legal question, and this is a publication rather than a law firm.

How to check this yourself

The table lives on one FDA page and takes about two minutes to verify. Open Certain Bulk Drug Substances for Use in Compounding That May Present Significant Safety Risks on fda.gov, count the rows, and check the "Content current as of" date at the foot of the page against the date on this one. If they differ, FDA's page is right and this one is stale — we re-check it on the same monthly cycle as the warning-letter tracker.

The one thing worth doing while you are there is reading which section each entry sits under, because that column is the one most often dropped when the table is quoted second-hand, and dropping it is what turns "restricted under 503B" into "restricted".

Sources and dates

  • FDA, Certain Bulk Drug Substances for Use in Compounding That May Present Significant Safety Risks. Page content current as of 22 April 2026; read 13 September 2026. Both the category 2 table and the nominated-but-withdrawn section were read from this page.
  • 21 U.S.C. § 353a (FD&C Act section 503A) and 21 U.S.C. § 353b (section 503B), for the statutory framework the categories operate under. Read 13 September 2026.
  • Substance identities and synonyms cross-checked against PubChem records, read 13 September 2026.

This page is journalism about a public regulatory record. It is not legal advice, and it cannot tell any reader where a particular product or transaction sits.

Frequently asked questions

What is FDA's category 2 list?

It is FDA's table of bulk drug substances that the agency has identified as presenting significant safety risks when used in compounding, maintained under its interim policies for sections 503A and 503B of the Federal Food, Drug, and Cosmetic Act. When read on 13 September 2026 it held fourteen substances, with the page content marked current as of 22 April 2026. Category 2 sits alongside category 1, substances FDA does not intend to take action against while it evaluates them, and category 3, substances nominated without adequate supporting information.

Which peptides are on FDA's category 2 list?

Five: GHRP-2, GHRP-6 and ipamorelin acetate under section 503B; kisspeptin-10 under section 503A; and ibutamoren mesylate under both. All five carry the date 29 September 2023, except the 503B entry for ibutamoren mesylate, which was added on 29 December 2022. Four of the five act on the growth hormone axis, which makes the 2023 action look less like five separate decisions than one decision about a class.

Is BPC-157 on FDA's category 2 list?

No. BPC-157 appears in a different section of the same FDA page, the list of substances nominated for use in compounding and subsequently withdrawn. A withdrawn nomination is not a restriction and it is not a clearance — it means the nomination process that would have placed the substance on a list was not completed. Fifteen other peptides sit in the same position, including CJC-1295, TB-500, AOD-9604, melanotan II, MOTS-c, semax, selank, KPV and epitalon.

Does category 2 mean a peptide is banned?

No. Category 2 is a classification within FDA's compounding framework: it describes bulk substances the agency has identified as raising significant safety risks in compounding, pending further evaluation. It is not a controlled-substance schedule, it does not create a possession offence, and it is not a determination about any particular finished product, seller or transaction. What it does do is close off a route — a substance in category 2 is one FDA has signalled it may act against if a compounder uses it.

Why is ipamorelin restricted under 503B but not 503A?

Because the two lists are compiled from separate nomination streams. A nomination is submitted under one section or the other, evaluated on that section's terms and acted on separately, so a substance nobody nominated under section 503A does not acquire a 503A entry regardless of what FDA has concluded about it under 503B. The consequence is the one worth carrying: absence from a section's list is not a clearance under that section. Of the fourteen substances on the table, only two carry entries under both.

How many substances are on FDA's category 2 list?

Fourteen, read on 13 September 2026 against a page whose content is marked current as of 22 April 2026. That is smaller than the list is usually assumed to be. Nine of the fourteen are conventional small molecules — cesium chloride, chloral hydrate, diethylstilbestrol, domperidone, edetate disodium, germanium sesquioxide, neomycin sulfate, quinacrine hydrochloride and tranilast — and five are peptide-class.

What does 'nominated but withdrawn' mean on the FDA list?

It means a substance was put forward for inclusion on a bulk drug substances list and the nomination was later withdrawn, so no evaluation produced a listing either way. It is a procedural status, not a safety finding in either direction, and it is frequently misreported in both — as though withdrawal were an FDA clearance, or as though it were a rejection. All sixteen substances currently in that position are peptides.