Are Peptides Legal in Maryland? (2026)

The federal rules that apply in Maryland, as everywhere

Federal law is the same in every state, and it is where almost all of the legal weight sits. Under the Federal Food, Drug, and Cosmetic Act a product intended to treat a condition or change how the body works is a drug, and an unapproved new drug cannot be introduced into interstate commerce. That rule binds the seller, not the buyer. The FDA's 2026 warning letters to research-peptide vendors say the same thing eleven times over: a "research use only" label does not help when the website, the bundled bacteriostatic water or a dosing calculator shows the product is meant for human use. The Bureau's enforcement tracker lists every letter, case and lawsuit with its source.

Three federal points matter for a reader in Maryland:

• Human growth hormone is the exception. 21 U.S.C. § 333(e) makes it a federal offence to distribute or possess somatropin for any use not approved by the Secretary of HHS. That statute covers HGH itself, not the secretagogues (sermorelin, ipamorelin, CJC-1295) that prompt the body's own release.
• Compounding is a separate track. A licensed pharmacy may only compound from bulk substances on the FDA's 503A list. BPC-157, TB-500, MOTS-c, KPV, Semax and Epitalon were moved to Category 2 in September 2023, removed from it in April 2026, and recommended for the list by the FDA's advisory committee on 23 and 24 July 2026. No rule has followed as of September 2026, so they still cannot be legally compounded anywhere, including Maryland. The PCAC vote page has every tally.
• GLP-1 compounding is closing, not opening. The FDA has declared the semaglutide and tirzepatide shortages over, proposed in April 2026 to keep both off the 503B bulks list, and sent batches of letters to telehealth sellers in March and June 2026. Vials sold as "GLP-1 S" or "GLP-3 R" for research are unapproved new drugs in the FDA's view wherever the buyer lives.

What Maryland law adds

Maryland's controlled-substances law (Maryland Controlled Dangerous Substances Act, Md. Code, Crim. Law Title 5 (§ 5-101 et seq.); schedules at §§ 5-402 to 5-406, populated by Department of Health designation under § 5-202 and by federal scheduling) decides whether possessing a compound is a state offence. Peptides only become a state-law problem if they appear in those schedules or in a specific state ban. (mgaleg.maryland.gov)

The Bureau found no research peptide (BPC-157, TB-500, ipamorelin, sermorelin, semaglutide, tirzepatide, retatrutide or the others covered on this site) on Maryland's schedules or in a Maryland-specific ban as of September 2026. That is the position in most states.

Human growth hormone

Maryland's Schedule III consists only of substances added by the Department of Health or scheduled federally; HGH is not federally scheduled and no Maryland designation was found, so Maryland does not restrict HGH beyond federal law. (Md. Code, Crim. Law § 5-404 (Schedule III) and § 5-202) (mgaleg.maryland.gov)

Compounded semaglutide and tirzepatide

No Maryland Board of Pharmacy statement specific to compounded GLP-1 drugs was located. Licensed Maryland pharmacies follow the federal 503A and 503B rules, under which the shortage exception for semaglutide and tirzepatide has ended.

Clinics, medspas and prescribers

No Maryland medical board guidance specific to peptide therapy was located. A Maryland prescriber who administers BPC-157 or another unapproved peptide is exposed under the state's medical practice act and, since the FDA's 2026 letters, under federal law; the July 2026 advisory vote has not changed that yet.

Buying, possessing and using research peptides in Maryland

Maryland's possession offence (Crim. Law § 5-601) covers only controlled dangerous substances obtained without a prescription, so possessing unscheduled research peptides is not a state drug offence; the statute does not reach non-controlled prescription drugs, and the federal rules bind sellers rather than end users. (mgaleg.maryland.gov)

Ordering from a vendor in another state. Almost every research-peptide order into Maryland is interstate commerce, which is exactly what the FDCA governs. The risk sits with the vendor: the FDA's letters name the seller, and Eli Lilly said in August 2026 it had referred more than 200 sellers to the FDA, the DOJ, state attorneys general and licensing boards. Connecticut's attorney general has already used state consumer-protection law against a "research grade" GLP-1 seller (2025), which is the template other states can copy. The Bureau's vendor scorecard notes which vendors publish batch testing; none of the scored vendors appears in the tracker as of September 2026.

GLP-1 drugs by prescription. Yes, under a stricter rule than most states. COMAR 10.32.05.05 requires a telehealth practitioner to perform a synchronous audiovisual evaluation adequate to establish a diagnosis and identify contraindications before prescribing (asynchronous follow-up is allowed for established patients), and COMAR 10.32.05.06 says a practitioner may not treat or prescribe based solely on an online questionnaire and must meet the in-person standard of care. (law.cornell.edu) The branded pens are the only fully approved route; compounded versions are now on the wrong side of the FDA's shortage rules.

Sports and employment testing are not a Maryland law question. Growth hormone secretagogues and GHRH analogues are on the WADA Prohibited List everywhere; a standard workplace panel does not screen for peptides. The national legal guide covers both.

Enforcement in Maryland

• 2025-02-19. Maryland's attorney general joined the 38-state letter urging the FDA to act against counterfeit and illegally sold GLP-1 drugs, including research-only sales. (naag.org)

A warning letter, lawsuit or board complaint is an allegation by the body that issued it, not a court finding, unless the entry says otherwise.

Editor's note. No Maryland Board of Pharmacy or Board of Physicians statement on compounded GLP-1s or peptides was found within the search budget.

Frequently asked questions

Is BPC-157 legal in Maryland?

Maryland has not scheduled BPC-157, so possessing it is not a Maryland offence. Federally it is an unapproved new drug: selling it for human use is a violation by the seller, and licensed pharmacies cannot compound it because it is not on the 503A bulks list, despite the advisory committee's July 2026 recommendation. Research vendors sell it under a research-use-only label, which the FDA's 2026 letters treat as no defence when the site shows human use.

Can I get semaglutide or tirzepatide by telehealth in Maryland?

Yes, under a stricter rule than most states. COMAR 10.32.05.05 requires a telehealth practitioner to perform a synchronous audiovisual evaluation adequate to establish a diagnosis and identify contraindications before prescribing (asynchronous follow-up is allowed for established patients), and COMAR 10.32.05.06 says a practitioner may not treat or prescribe based solely on an online questionnaire and must meet the in-person standard of care. Compounded versions are no longer covered by the FDA's shortage exception, and the FDA has proposed keeping semaglutide and tirzepatide off the 503B bulks list, so expect availability of compounded product to keep shrinking.

Is HGH legal in Maryland?

Only with a valid prescription for an approved use. Maryland does not schedule it separately, but federal law, 21 U.S.C. section 333(e), makes distribution or possession for any non-approved use a federal offence. Sermorelin, ipamorelin and CJC-1295 are not HGH and fall under the general unapproved-drug rules instead.

Sources

• https://mgaleg.maryland.gov/mgawebsite/Laws/StatuteText?article=gcr&section=5-404&enactments=false
• https://www.law.cornell.edu/regulations/maryland/COMAR-10-32-05-05
• https://mgaleg.maryland.gov/mgawebsite/Laws/StatuteText?article=gcr&section=5-601&enactments=false
• https://www.naag.org/press-releases/state-and-territory-attorneys-general-urge-fda-to-take-action-against-counterfeit-and-illegally-sold-glp-1-drugs/

Every Maryland fact above was checked against the linked source on 28 September 2026. If a statute or board position has changed, email [email protected] with the link and the page will be corrected and dated.