Foley & Lardner Legal Memo (May 2026): How Compounders Should Read FDA's Peptide Restrictions Lifting Ahead of July 23–24 PCAC
Foley & Lardner published a May 2026 client memo translating the FDA's April 22 Category 2 removal of 12 peptides for the compounding-pharmacy audience. Key framing: the removal does not, by itself, place these substances on the 503A bulks list, and the peptides will exist in a regulatory gray zone until the PCAC meets July 23–24 to consider seven of them (BPC-157, KPV, TB-500, MOTs-C, Emideltide, Semax, Epitalon) and the FDA takes final action — which under standard rulemaking timelines could run more than a year past the meeting. The piece joins the Orrick May 2026 503B GLP-1 memo, the FDA Law Blog Pep(tide) Rally analysis (April 23), Holt Law's California Sherman-Law alert, and the Frier Levitt April peptide update as the legal cluster compounders are reading ahead of the meeting.