Orrick Client Memo: 'FDA Moves to Shut the Door on Large-Scale Compounding of GLP-1 Drugs' Translates the 503B Proposal for Outsourcing Facilities and Telehealth
Orrick published a May 2026 client memo walking through the FDA's April 30 proposal to formally exclude semaglutide (Ozempic, Wegovy), tirzepatide (Mounjaro, Zepbound), and liraglutide (Victoza, Saxenda) from the 503B outsourcing-facility bulk drug substances list. The memo flags that the FDA declared the tirzepatide shortage resolved in October 2024 and the semaglutide shortage resolved in February 2025, removing the two legal pathways that previously enabled large-scale compounding. Orrick advises weight-loss clinics, medical spas, and telehealth platforms still relying on compounded GLP-1 products to consult counsel ahead of the June 29 comment deadline.