{ "source": "https://peptidebureau.com/peptide-law-data.html", "licence": "CC BY 4.0", "updated": "2026-10-20", "states": [ { "state": "Alabama", "abbr": "AL", "csa_citation": { "citation": "Ala. Code § 20-2-1 et seq. (Alabama Uniform Controlled Substances Act); schedules at §§ 20-2-23 to 20-2-31", "source_url": "https://codes.findlaw.com/al/title-20-food-drugs-and-cosmetics/al-code-sect-20-2-27/" }, "hgh_scheduled": { "value": false, "citation": "Ala. Admin. Code r. 420-7-2-.01 and ch. 420-7-2 Appendix (Alabama Controlled Substances List, effective 14 June 2025), Schedule III(f)", "source_url": "https://www.law.cornell.edu/regulations/alabama/Ala-Admin-Code-420-ch-420-7-2-app-Effective-6-14-2025-Controlled-Substances-List", "note": "Alabama's complete controlled substances list schedules anabolic steroids in Schedule III(f) but does not list human growth hormone, somatropin or chorionic gonadotropin anywhere in Schedules I to V, so only the federal HGH statute applies." }, "peptides_scheduled": [], "pharmacy_board_glp1": { "summary": "The Alabama Board of Pharmacy petitioned the Board of Medical Examiners for a declaratory ruling on physicians buying and compounding GLP-1s. The petition states that semaglutide salt forms and research-grade powder are not FDA approved and that only prescription-quality active ingredient may be used, and that suppliers shipping into Alabama need a Board of Pharmacy permit. The Board of Medical Examiners ruled (considered 18 July 2024) that physicians may not compound with non-prescription-quality ingredients, must buy only from Board-permitted entities, and must follow USP standards.", "date": "2024-07-18", "source_url": "https://www.albme.gov/uploads/pdfs/BOPSemaglutide.DeclaratoryRuling_.pdf" }, "medical_board_peptides": { "summary": "The Board of Medical Examiners issued an official notice on non-FDA-approved, research-grade peptides. All drugs given to patients must be prescription quality, so under no circumstances may a physician compound, administer or dispense a non-FDA-approved or research-grade peptide, or delegate that to nurse midwives, nurse practitioners or physician assistants; the bar covers advising, recommending, supplying, prescribing and administering. Patient consent forms that label a product research-grade do not remove the provider's liability, and a patient who independently acquires and self-administers such a substance carries the risk alone.", "date": "2026-05-26", "source_url": "https://www.albme.gov/press-release/board-issues-official-notice-concerning-the-prescribing-of-non-fda-approved-research-grade-peptides" }, "telehealth": { "summary": "Yes. Under Ala. Code §§ 34-24-700 to 707 no initial in-person exam is needed; if a physician treats the same patient by telehealth more than four times in twelve months for the same unresolved condition, the patient must be seen in person within twelve months or referred. The in-person rule for controlled substances does not affect GLP-1s. Out-of-state physicians need an Alabama licence unless they treat fewer than ten patients or ten days a year.", "source_url": "https://www.albme.gov/resources/licensees/telemedicine/" }, "enforcement": [ { "date": "2025-11-10", "summary": "Attorney General Steve Marshall sued Aurora IV and Wellness of Cullman under the Deceptive Trade Practices Act for injecting patients with research-use-only semaglutide and tirzepatide marketed as pharmaceutical grade, and obtained a restraining order, a closure order and an asset freeze.", "source_url": "https://www.alabamaag.gov/attorney-general-steve-marshall-files-suit-against-cullman-iv-infusion-clinic-for-administering-dangerous-unapproved-weight-loss-drugs/" }, { "date": "2026-01-12", "summary": "The Aurora IV and Wellness case settled: $17,267.50 in restitution, $7,000 in penalties, permanent closure, the owners barred from direct patient care and the nurse owner's licence surrendered.", "source_url": "https://www.alabamaag.gov/attorney-general-marshall-settles-lawsuit-with-cullman-clinic-for-administering-dangerous-unapproved-weight-loss-drugs/" } ], "possession_note": { "text": "No Alabama provision specific to possessing unscheduled research peptides was found; the federal misbranding and unapproved-drug rules bind sellers.", "source_url": "https://codes.findlaw.com/al/title-20-food-drugs-and-cosmetics/al-code-sect-20-2-27/" }, "confidence": "high", "notes": "Alabama is the clearest example of a state attorney general shutting a clinic for using research-grade GLP-1s on patients, and its Board of Medical Examiners was the first of three boards (with South Carolina and Mississippi) to bar providers from research-grade peptides in 2026. The human growth hormone finding rests on the Department of Public Health's complete controlled substances list; the text of Ala. Code § 20-2-27 itself could not be opened.", "verified": "2026-09-29" }, { "state": "Alaska", "abbr": "AK", "csa_citation": { "citation": "Alaska Stat. § 11.71.010 et seq.; schedules IA to VIA at AS 11.71.140 to 11.71.190", "source_url": "https://codes.findlaw.com/ak/title-11-criminal-law/ak-st-sect-11-71-160.html" }, "hgh_scheduled": { "value": false, "citation": "AS 11.71.160 (Schedule IIIA) and AS 11.71.180 (Schedule VA, 27 named anabolic steroids)", "source_url": "https://codes.findlaw.com/ak/title-11-criminal-law/ak-st-sect-11-71-180.html", "note": "Human growth hormone is not listed in Alaska's Schedule IIIA or Schedule VA, which names 27 anabolic steroids; only the federal HGH statute applies." }, "peptides_scheduled": [], "pharmacy_board_glp1": null, "medical_board_peptides": null, "telehealth": { "summary": "No Alaska-specific GLP-1 or in-person examination restriction was found. Physician telemedicine is governed by AS 08.64.364, and Alaska-licensed prescribers may prescribe approved drugs such as semaglutide by telehealth under the same prescription rules as in person. The statute text itself could not be opened during this check.", "source_url": "https://www.akleg.gov/basis/statutes.asp#08.64.364" }, "enforcement": [], "possession_note": { "text": "No Alaska provision specific to research peptides was found; they are absent from AS 11.71.160 and 11.71.180, so the federal rules apply.", "source_url": "https://codes.findlaw.com/ak/title-11-criminal-law/ak-st-sect-11-71-160.html" }, "confidence": "medium", "notes": "No Alaska pharmacy board or medical board statement on compounded GLP-1s or peptides was found. The telehealth statute text should be confirmed against akleg.gov." }, { "state": "Arizona", "abbr": "AZ", "csa_citation": { "citation": "A.R.S. § 36-2501 et seq. (Uniform Controlled Substances Act); criminal drug definitions and offences at A.R.S. § 13-3401 et seq.", "source_url": "https://www.azleg.gov/ars/13/03401.htm" }, "hgh_scheduled": { "value": false, "citation": "A.R.S. § 13-3401(6)(e)", "source_url": "https://www.azleg.gov/ars/13/03401.htm", "note": "Arizona defines anabolic steroids as dangerous drugs by a closed list of 23 named steroids; human growth hormone, somatropin and hCG are not on it, so only the federal HGH statute applies." }, "peptides_scheduled": [], "pharmacy_board_glp1": null, "medical_board_peptides": null, "telehealth": { "summary": "Yes. A.R.S. § 36-3606 requires telehealth prescribing to follow Arizona's standards of care and prescribing laws, with no in-person examination requirement and no audio-only ban; prescription monitoring registration applies only to controlled substances, which GLP-1s are not. A relationship is normally established by synchronous audio-video; an asynchronous questionnaire alone does not meet the standard.", "source_url": "https://www.azleg.gov/ars/36/03606.htm" }, "enforcement": [], "possession_note": { "text": "A.R.S. § 13-3406(A)(1) makes possessing a prescription-only drug without a valid prescription a class 1 misdemeanor, which reaches prescription products such as semaglutide; no Arizona provision specifically covers unscheduled research peptides such as BPC-157, so the federal rules apply there.", "source_url": "https://www.azleg.gov/ars/13/03406.htm" }, "confidence": "medium", "notes": "A 2026 Arizona bill on sourcing, testing and advertising of compounded GLP-1s was introduced but not enacted. No Arizona Board of Pharmacy GLP-1 guidance or attorney general peptide action was located with a primary source." }, { "state": "Arkansas", "abbr": "AR", "csa_citation": { "citation": "Ark. Code Ann. § 5-64-101 et seq. (Uniform Controlled Substances Act); schedules maintained by the Department of Health under §§ 5-64-201 and 5-64-216", "source_url": "https://healthy.arkansas.gov/programs-services/prevention-healthy-living/pharmacy-services-drug-control/controlled-substances/" }, "hgh_scheduled": { "value": false, "citation": "Arkansas Department of Health 2025 List of Controlled Substances, Schedule III(f)", "source_url": "https://healthy.arkansas.gov/programs-services/prevention-healthy-living/pharmacy-services-drug-control/controlled-substances/", "note": "The 2025 state list has no entry for growth hormone, somatropin or chorionic gonadotropin in any schedule; Schedule III(f) covers anabolic steroids only." }, "peptides_scheduled": [], "pharmacy_board_glp1": null, "medical_board_peptides": null, "telehealth": { "summary": "Yes, with a professional-relationship requirement. Under Ark. Code §§ 17-80-402 and 17-80-403 the relationship may be established by a prior in-person exam, an ongoing relationship, a referral, or by telemedicine only where the standard of care does not require an in-person encounter. There is no GLP-1-specific rule.", "source_url": "https://codes.findlaw.com/ar/title-17-professions-occupations-and-businesses/ar-code-sect-17-80-403.html" }, "enforcement": [], "possession_note": { "text": "No Arkansas provision specific to research peptides was found; the federal rules apply.", "source_url": "https://healthy.arkansas.gov/programs-services/prevention-healthy-living/pharmacy-services-drug-control/controlled-substances/" }, "confidence": "medium", "notes": "No Arkansas Board of Pharmacy or Medical Board guidance on compounded GLP-1s or peptides was found." }, { "state": "California", "abbr": "CA", "csa_citation": { "citation": "Cal. Health & Safety Code § 11000 et seq. (California Uniform Controlled Substances Act); Schedule III at § 11056", "source_url": "https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?sectionNum=11056&lawCode=HSC" }, "hgh_scheduled": { "value": false, "citation": "Health & Safety Code § 11056(f), as amended by AB 1152 (Stats. 2025, ch. 183), effective 1 January 2026", "source_url": "https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=202520260AB1152", "note": "Human growth hormone is not in § 11056. Human chorionic gonadotropin was Schedule III until AB 1152 removed it effective 1 January 2026; subsection (f) now reads anabolic steroids and chorionic gonadotropin except for human chorionic gonadotropin." }, "peptides_scheduled": [], "pharmacy_board_glp1": { "summary": "The Board of Pharmacy adopted revised compounding regulations on 17 June 2025 (16 CCR §§ 1735.1, 1736.1, 1735.8 and 1736.8), effective 1 October 2025: a compound with the same active ingredient as a commercial product is essentially a copy unless the pharmacist verifies and documents a clinically significant, patient-specific difference, and certificates of analysis must name the actual manufacturer of the active ingredient. The rules are aimed at compounded semaglutide and tirzepatide.", "date": "2025-10-01", "source_url": "https://www.frierlevitt.com/articles/california-board-of-pharmacys-new-essentially-a-copy-rules-what-glp-1-compounders-need-to-know/" }, "medical_board_peptides": null, "telehealth": { "summary": "Yes. Business and Professions Code § 2242 requires an appropriate prior examination before prescribing, which does not require a synchronous interaction and may be done by telehealth, including a questionnaire, if the standard of care is met. Out-of-state pharmacies shipping compounded products into California need a nonresident pharmacy permit.", "source_url": "https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?sectionNum=2242&lawCode=BPC" }, "enforcement": [ { "date": "2025-06-23", "summary": "The Board of Pharmacy issued a cease-and-desist order against Boothwyn Pharmacy LLC, a Pennsylvania nonresident sterile compounder, for shipping compounded sterile products to California before endotoxin results were in and for labelling semaglutide and tirzepatide products store frozen; the order was lifted on 10 July 2025 after a hearing.", "source_url": "https://www.pharmacy.ca.gov/enforcement/ipo/cd_boothwyn.pdf" } ], "possession_note": { "text": "Business and Professions Code § 4060 bars possession of controlled substances without a prescription; no equivalent California offence was found for possessing non-controlled, unscheduled peptides, so the federal rules, which fall on the seller, apply.", "source_url": "https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?sectionNum=4060&lawCode=BPC" }, "confidence": "high", "notes": "AB 1990 (2025 to 2026 session), which would add sourcing, certificate-of-analysis and advertising-disclosure rules for compounded weight-management drugs with penalties per dose, was still pending in the Senate as of June 2026. Older articles still call hCG Schedule III in California; that changed on 1 January 2026." }, { "state": "Colorado", "abbr": "CO", "csa_citation": { "citation": "Colo. Rev. Stat. § 18-18-101 et seq. (Uniform Controlled Substances Act of 2013); Schedule III at § 18-18-205", "source_url": "https://codes.findlaw.com/co/title-18-criminal-code/co-rev-st-sect-18-18-205/" }, "hgh_scheduled": { "value": true, "citation": "C.R.S. § 18-18-102(3)(a)(X) and (XI); § 18-18-205(2)(e)", "source_url": "https://codes.findlaw.com/co/title-18-criminal-code/co-rev-st-sect-18-18-102/", "note": "Colorado's definition of anabolic steroids expressly includes human chorionic gonadotropin and human growth hormone, and anabolic steroids are Schedule III, so unprescribed possession of HGH is a state controlled-substance offence as well as a federal one." }, "peptides_scheduled": [ { "name": "Human growth hormone and hCG (treated as anabolic steroids, Schedule III)", "citation": "C.R.S. § 18-18-102(3)(a)(X) and (XI); § 18-18-205(2)(e)", "source_url": "https://codes.findlaw.com/co/title-18-criminal-code/co-rev-st-sect-18-18-102/" } ], "pharmacy_board_glp1": null, "medical_board_peptides": null, "telehealth": { "summary": "Yes. C.R.S. § 12-240-107(1)(g) places telemedicine within the practice of medicine with no statutory in-person examination requirement. Colorado Medical Board policy holds telehealth to the in-person standard, requires Colorado licensure where the patient is located, and treats prescribing solely on an online questionnaire as unacceptable.", "source_url": "https://codes.findlaw.com/co/title-12-professions-and-occupations/co-rev-st-sect-12-240-107.html" }, "enforcement": [], "possession_note": { "text": "No Colorado provision on unscheduled research peptides was found, but human growth hormone and hCG are Schedule III in Colorado, so unprescribed possession of those is a state controlled-substance offence.", "source_url": "https://codes.findlaw.com/co/title-18-criminal-code/co-rev-st-sect-18-18-102/" }, "confidence": "medium", "notes": "SB 26-066, Regulation of Compounded Weight-Loss Medication (labelling, sourcing and per-dose fines), passed the Senate but was postponed indefinitely by the House health committee on 5 May 2026, so it is not law." }, { "state": "Connecticut", "abbr": "CT", "csa_citation": { "citation": "Conn. Gen. Stat. § 21a-240 et seq. (Dependency-Producing Drugs); schedules in Regs. Conn. State Agencies §§ 21a-243-7 to 21a-243-11; penalties at §§ 21a-277 and 21a-279", "source_url": "https://portal.ct.gov/-/media/dcp/drug_control/pdf/controlleddrugschedulesviolationspenaltiespdf.pdf" }, "hgh_scheduled": { "value": false, "citation": "Department of Consumer Protection controlled drug schedule list", "source_url": "https://portal.ct.gov/-/media/dcp/drug_control/pdf/controlleddrugschedulesviolationspenaltiespdf.pdf", "note": "Human growth hormone does not appear in Connecticut's controlled drug schedules. Chorionic gonadotropin (hCG) is listed as a Schedule III hormone, with sale under § 21a-277(b) and possession under § 21a-279(c)." }, "peptides_scheduled": [ { "name": "Chorionic gonadotropin (hCG), Schedule III", "citation": "Regs. Conn. State Agencies § 21a-243-9; possession § 21a-279(c)", "source_url": "https://portal.ct.gov/-/media/dcp/drug_control/pdf/controlleddrugschedulesviolationspenaltiespdf.pdf" } ], "pharmacy_board_glp1": null, "medical_board_peptides": null, "telehealth": { "summary": "Yes. Conn. Gen. Stat. § 19a-906 holds telehealth to the in-person standard of care and allows physical-examination elements through peripheral devices; the bar on prescribing Schedule I to III controlled substances by telehealth does not affect GLP-1s.", "source_url": "https://codes.findlaw.com/ct/title-19a-public-health-and-well-being/ct-gen-st-sect-19a-906/" }, "enforcement": [ { "date": "2025-05-21", "summary": "Attorney General William Tong sent warning letters under the Connecticut Unfair Trade Practices Act to weight-loss clinics, medspas and practices still advertising or prescribing compounded semaglutide and tirzepatide after the shortage ended.", "source_url": "https://portal.ct.gov/-/media/ag/press_releases/2025/letter-to-wt-loss-clinics--spas-52125-final.pdf" }, { "date": "2025-05-21", "summary": "The attorney general sued Florida-based Triggered Brand for selling research-grade semaglutide and tirzepatide to consumers without prescriptions, under CUTPA and the unlicensed pharmacy practice rules, and issued a civil investigative demand to the Made-in-China marketplace.", "source_url": "https://portal.ct.gov/ag/press-releases/2025-press-releases/attorney-general-tong-sues-glp-1-weight-loss-drug-distributor-triggered-brand" }, { "date": "2025-08-05", "summary": "Triggered Brand settled: all sales to cease, with a $300,000 judgment suspended after an $18,500 payment.", "source_url": "https://portal.ct.gov/ag/press-releases/2025-press-releases/bootleg-weight-loss-drug-distributor-to-cease-unlawful-sales-in-settlement-with-state" }, { "date": "2026-05-06", "summary": "The Made-in-China platform agreed to stop all research-grade GLP-1 sales into the United States and to monitor and remove listings within five days, with a $300,000 penalty suspended after $30,000.", "source_url": "https://portal.ct.gov/ag/press-releases/2026-press-releases/attorney-general-tong-announces-online-platform-to-cease-bootleg-weight-loss-drug-sales" } ], "possession_note": { "text": "No Connecticut provision on possessing unscheduled research peptides was found, so the federal rules apply; hCG is a Connecticut Schedule III drug and unprescribed possession violates § 21a-279(c).", "source_url": "https://portal.ct.gov/-/media/dcp/drug_control/pdf/controlleddrugschedulesviolationspenaltiespdf.pdf" }, "confidence": "high", "notes": "Connecticut is the most active state against research-grade GLP-1 sellers; the legal theory is consumer-protection law plus unlicensed pharmacy practice, not scheduling. A 2026 proposed regulation updating the schedules exists and could not be opened; check whether it touches hCG or peptides." }, { "state": "Delaware", "abbr": "DE", "csa_citation": { "citation": "16 Del. C. § 4701 et seq. (Uniform Controlled Substances Act); Schedule III at § 4718", "source_url": "https://delcode.delaware.gov/title16/c047/sc01/index.html" }, "hgh_scheduled": { "value": false, "citation": "16 Del. C. § 4718 (Schedule III); § 4757(a)(7)", "source_url": "https://codes.findlaw.com/de/title-16-health-and-safety/de-code-sect-16-4718.html", "note": "Neither growth hormone nor gonadotropin appears in Delaware's Schedule III or elsewhere in the schedules. Section 4701(21) oddly defines human growth hormone as synonymous with human chorionic gonadotropin, but the term is not used in any schedule. Section 4757(a)(7) bars prescribing anabolic steroids for muscle building or performance." }, "peptides_scheduled": [], "pharmacy_board_glp1": null, "medical_board_peptides": null, "telehealth": { "summary": "Yes. Under 24 Del. C. §§ 6001 to 6005 a provider must, before diagnosis or treatment, examine the patient in person, have another Delaware-licensed provider present, diagnose by audio-visual communication, or meet applicable professional-society standards; prescriptions may not be issued solely on an internet questionnaire or a phone consultation without a relationship. An interstate telehealth registration is available.", "source_url": "https://delcode.delaware.gov/title24/c060/index.html" }, "enforcement": [], "possession_note": { "text": "No Delaware provision specific to research peptides was found; the federal rules apply.", "source_url": "https://delcode.delaware.gov/title16/c047/sc01/index.html" }, "confidence": "medium", "notes": "No Delaware Board of Pharmacy or Board of Medical Licensure statement on compounded GLP-1s or peptides was found." }, { "state": "Florida", "abbr": "FL", "csa_citation": { "citation": "Fla. Stat. ch. 893 (Florida Comprehensive Drug Abuse Prevention and Control Act); schedules at § 893.03", "source_url": "https://www.flsenate.gov/Laws/Statutes/2025/893.03" }, "hgh_scheduled": { "value": false, "citation": "Fla. Stat. § 893.03; § 458.331(1)(ee)", "source_url": "https://www.leg.state.fl.us/statutes/index.cfm?App_mode=Display_Statute&URL=0400-0499/0458/Sections/0458.331.html", "note": "Growth hormone and gonadotropin do not appear in Florida's schedules. Separately, § 458.331(1)(ee) makes it a disciplinary offence for a physician to prescribe or supply growth hormones, testosterone or its analogs, hCG or other hormones for muscle building or to enhance athletic performance." }, "peptides_scheduled": [], "pharmacy_board_glp1": { "summary": "No GLP-1-specific Board of Pharmacy statement was found. Board rule 64B16-27.797 (standards of practice for compounding sterile products) was amended effective 2 February 2025 and ties Florida sterile compounding to section 503A of the federal act.", "date": "2025-02-02", "source_url": "https://www.flrules.org/gateway/ruleno.asp?id=64B16-27.797" }, "medical_board_peptides": null, "telehealth": { "summary": "Yes. Fla. Stat. § 456.47 says a telehealth provider is not required to research a patient's medical history or conduct a physical examination if the evaluation is sufficient; out-of-state providers may register to treat Florida patients by telehealth but may not open an office or see patients in person.", "source_url": "https://www.leg.state.fl.us/statutes/index.cfm?App_mode=Display_Statute&URL=0400-0499/0456/Sections/0456.47.html" }, "enforcement": [], "possession_note": { "text": "Fla. Stat. § 499.03 makes possessing any new drug or prescription drug without a valid prescription a second-degree misdemeanor (a third-degree felony with intent to sell), which can reach unapproved peptides held for human use; no scheduling applies to BPC-157 and the other research peptides.", "source_url": "https://www.leg.state.fl.us/statutes/index.cfm?App_mode=Display_Statute&URL=0400-0499/0499/Sections/0499.03.html" }, "confidence": "high", "notes": "SB 860 (2026), which would have required sourcing documentation for compounded weight-loss drugs, died in committee on 13 March 2026. Several of the 2026 FDA warning letters went to Florida-based research-peptide sellers, and Connecticut's Triggered Brand defendant was Florida-based, but no Florida attorney general or Board of Medicine action against a peptide seller was located." }, { "state": "Georgia", "abbr": "GA", "csa_citation": { "citation": "O.C.G.A. § 16-13-20 et seq. (Georgia Controlled Substances Act); Schedule III at § 16-13-27; Dangerous Drug Act at § 16-13-70 et seq.", "source_url": "https://codes.findlaw.com/ga/title-16-crimes-and-offenses/ga-code-sect-16-13-27.html" }, "hgh_scheduled": { "value": false, "citation": "O.C.G.A. § 16-13-27 (Schedule III); § 16-13-71 (dangerous drugs)", "source_url": "https://codes.findlaw.com/ga/title-16-crimes-and-offenses/ga-code-sect-16-13-71/", "note": "Human growth hormone is not in Georgia's Schedule III, which lists anabolic steroids only. Somatropin and chorionic gonadotropin are instead on the § 16-13-71 dangerous drug (prescription-only) list, alongside semaglutide, tirzepatide, liraglutide and sermorelin acetate." }, "peptides_scheduled": [ { "name": "Semaglutide, tirzepatide, liraglutide, sermorelin acetate, somatropin and hCG named as prescription-only dangerous drugs", "citation": "O.C.G.A. § 16-13-71; possession without a prescription under § 16-13-72", "source_url": "https://codes.findlaw.com/ga/title-16-crimes-and-offenses/ga-code-sect-16-13-71/" } ], "pharmacy_board_glp1": null, "medical_board_peptides": null, "telehealth": { "summary": "Yes. Georgia Composite Medical Board rule 360-3-.07 allows telemedicine where the licensee has examined the patient, acts at the request of a provider who has, or uses technology sufficient to equal an in-person exam; the licensee must make diligent efforts to have the patient seen in person at least annually, and the standard of care is the in-person standard.", "source_url": "https://www.law.cornell.edu/regulations/georgia/Ga-Comp-R-Regs-R-360-3-.07" }, "enforcement": [], "possession_note": { "text": "O.C.G.A. § 16-13-72 makes it unlawful to possess a dangerous drug without a prescription, and § 16-13-71 names semaglutide, tirzepatide, sermorelin, somatropin and hCG as dangerous drugs; unlisted research peptides such as BPC-157 fall outside both the schedules and the named list, so the federal rules apply to them.", "source_url": "https://codes.findlaw.com/ga/title-16-crimes-and-offenses/ga-code-sect-16-13-72/" }, "confidence": "high", "notes": "Georgia is unusual in naming the GLP-1 peptides and sermorelin in statute as prescription-only dangerous drugs, so holding those without a prescription is a misdemeanor under state law. No Georgia Board of Pharmacy, Composite Medical Board or attorney general statement on compounded GLP-1s or research peptides was found." }, { "state": "Hawaii", "abbr": "HI", "csa_citation": { "citation": "Hawaii Revised Statutes Chapter 329, Uniform Controlled Substances Act; schedules at HRS 329-14 to 329-22, Schedule III at HRS 329-18", "source_url": "https://files.hawaii.gov/dcca/pvl/pvl/hrs/hrs_pvl_329.pdf" }, "hgh_scheduled": { "value": false, "citation": "HRS 329-18(g) (Schedule III, anabolic steroids)", "source_url": "https://files.hawaii.gov/dcca/pvl/pvl/hrs/hrs_pvl_329.pdf", "note": "HRS 329-18(g) schedules anabolic steroids related to testosterone; the chapter does not list human growth hormone, somatropin or chorionic gonadotropin, so Hawaii does not restrict HGH beyond federal law." }, "peptides_scheduled": [], "pharmacy_board_glp1": null, "medical_board_peptides": null, "telehealth": { "summary": "Yes. HRS 453-1.3 lets a physician prescribe by telehealth to the same standard of care as an in-person encounter, but says issuing a prescription based solely on an online questionnaire does not constitute an acceptable standard of care; an in-person consultation is required only for opiates and medical cannabis, so a GLP-1 can be prescribed after a real telehealth evaluation.", "source_url": "https://www.cchpca.org/hawaii/?category=professional-requirements&topic=online-prescribing" }, "enforcement": [ { "date": "2025-02-19", "summary": "Hawaii's attorney general signed the 38-state letter urging the FDA to act against counterfeit GLP-1 drugs and online sellers of research-purposes-only GLP-1 active ingredients.", "source_url": "https://www.naag.org/press-releases/state-and-territory-attorneys-general-urge-fda-to-take-action-against-counterfeit-and-illegally-sold-glp-1-drugs/" } ], "possession_note": { "text": "No Hawaii offence was found for an individual merely possessing an unscheduled research peptide: HRS 328-16 regulates the dispenser rather than the patient, and the possession offences in HRS 329 reach only scheduled substances, so the federal rules bind sellers rather than buyers.", "source_url": "https://codes.findlaw.com/hi/division-1-government/hi-rev-st-sect-328-16/" }, "confidence": "medium", "notes": "The HRS 329 text was read from a DCCA compilation whose edition date is not printed; the legislature's site blocked automated access. No Hawaii Board of Pharmacy, Medical Board or attorney general statement specific to compounded GLP-1s or peptides was found." }, { "state": "Idaho", "abbr": "ID", "csa_citation": { "citation": "Idaho Code Title 37, Chapter 27, Uniform Controlled Substances Act; Schedule III at Idaho Code § 37-2709", "source_url": "https://codes.findlaw.com/id/title-37-food-drugs-and-oil/id-st-sect-37-2709/" }, "hgh_scheduled": { "value": true, "citation": "Idaho Code § 37-2709(f)(38), Schedule III", "source_url": "https://codes.findlaw.com/id/title-37-food-drugs-and-oil/id-st-sect-37-2709/", "note": "Idaho goes beyond federal law: human growth hormones are listed by name as a Schedule III controlled substance in § 37-2709(f)(38), alongside the anabolic steroid list. Possession without a valid prescription is therefore a controlled-substance offence under Idaho Code § 37-2732." }, "peptides_scheduled": [ { "name": "Human growth hormones, Schedule III", "citation": "Idaho Code § 37-2709(f)(38)", "source_url": "https://codes.findlaw.com/id/title-37-food-drugs-and-oil/id-st-sect-37-2709/" } ], "pharmacy_board_glp1": { "summary": "The Idaho Board of Pharmacy newsletter (September 2023) relayed the FDA notice on compounded semaglutide: the approved active ingredient is semaglutide base, the FDA is not aware of any basis for compounding with the salt forms (semaglutide sodium and acetate), and compounded versions are not reviewed for safety, effectiveness or quality. No Idaho-specific rule beyond the FDA relay was found.", "date": "2023-09", "source_url": "https://nabp.pharmacy/wp-content/uploads/2023/09/September-2023-Idaho-State-Newsletter.pdf" }, "medical_board_peptides": null, "telehealth": { "summary": "Yes. Under the Idaho Telehealth Access Act a provider-patient relationship may be established through virtual care technologies if the Idaho community standard of care is satisfied (Idaho Code § 54-5705), and a provider with that relationship may issue prescription drug orders within the scope of their licence (§ 54-5707); no in-person exam is required for a non-controlled drug such as semaglutide.", "source_url": "https://codes.findlaw.com/id/title-54-professions-vocations-and-businesses/id-st-sect-54-5707/" }, "enforcement": [], "possession_note": { "text": "Idaho is stricter than most states: Idaho Code § 54-1732(3)(c) makes possession or use of a legend drug by any person who did not obtain it on a practitioner's prescription a misdemeanor, which reaches prescription-only peptides such as semaglutide even though they are unscheduled, while HGH possession falls under the controlled-substance offence in § 37-2732.", "source_url": "https://codes.findlaw.com/id/title-54-professions-vocations-and-businesses/id-st-sect-54-1732/" }, "confidence": "medium", "notes": "Idaho did not sign the February 2025 multistate letter and no Idaho attorney general or licensing enforcement action on peptides or GLP-1s was found. A search snippet suggested chorionic gonadotropin may also appear in § 37-2709(f); the text opened (current to January 2024) shows only human growth hormones, so check the official statute before stating hCG is scheduled." }, { "state": "Illinois", "abbr": "IL", "csa_citation": { "citation": "Illinois Controlled Substances Act, 720 ILCS 570; Schedule III at 720 ILCS 570/208", "source_url": "https://codes.findlaw.com/il/chapter-720-criminal-offenses/il-st-sect-720-570-208.html" }, "hgh_scheduled": { "value": false, "citation": "720 ILCS 570/208(f) (Schedule III, anabolic steroids)", "source_url": "https://codes.findlaw.com/il/chapter-720-criminal-offenses/il-st-sect-720-570-208.html", "note": "Section 208(f) schedules anabolic steroids and contains no reference to human growth hormone, somatropin or chorionic gonadotropin, so Illinois does not restrict HGH beyond federal law." }, "peptides_scheduled": [], "pharmacy_board_glp1": { "summary": "The Department of Financial and Professional Regulation's pharmacy page posts the FDA's 16 July 2024 letter on injectable compounded semaglutide and tirzepatide: the products are not FDA approved, and the FDA received adverse-event reports tied to starting doses two to four times the approved dose and to overly fast titration. No Illinois-authored rule on salt forms or 503A copies was found.", "date": "2024-07-25", "source_url": "https://idfpr.illinois.gov/profs/pharm.html" }, "medical_board_peptides": null, "telehealth": { "summary": "Yes. Illinois has no initial in-person examination requirement; telemedicine is held to the same standard of care under the Medical Practice Act (225 ILCS 60/49.5) and the Telehealth Act, and a physician or advanced practice nurse may establish the relationship and prescribe a non-controlled drug such as semaglutide by a real-time audiovisual or audio visit. Whether a questionnaire-only intake suffices is unsettled and the statute text could not be opened.", "source_url": "https://www.clyr.health/journal/semaglutide-illinois/" }, "enforcement": [ { "date": "2025-01-03", "summary": "Attorney General Kwame Raoul's updated consumer alert says his office issued cease and desist letters to five medspas over misleading GLP-1 advertising and warns that research-only GLP-1 products should never be used by humans.", "source_url": "https://illinoisattorneygeneral.gov/news/story/updated-consumer-alertattorney-general-raoul-reminds-illinois-residents-to-be-vigilant-when-seeking-glp-1-drugs-for-weight-loss" }, { "date": "2025-02-19", "summary": "Illinois co-led, with Colorado, South Carolina and Tennessee, the 38-attorney-general letter urging the FDA to act against counterfeit GLP-1s and online sellers of research-purposes-only GLP-1 active ingredients.", "source_url": "https://www.illinoisattorneygeneral.gov/news/story/attorney-general-raoul-co-leads-bipartisan-coalition-calling-for-fda-action-against-makers-of-counterfeit-weight-loss-drugs" } ], "possession_note": { "text": "Illinois' possession offence, 720 ILCS 570/402, reaches only a controlled or counterfeit substance or analog, so an individual holding an unscheduled research peptide commits no state possession offence; no general legend-drug possession crime was found, and the federal rules bind sellers.", "source_url": "https://codes.findlaw.com/il/chapter-720-criminal-offenses/il-st-sect-720-570-402/" }, "confidence": "medium", "notes": "The five cease and desist letters were reportedly sent to Chicago-area medspas in December 2024; the alert page itself does not date them. No medical board statement on BPC-157 or peptide clinics was found." }, { "state": "Indiana", "abbr": "IN", "csa_citation": { "citation": "Indiana Code Title 35, Article 48 (Controlled Substances); schedules at IC 35-48-2, Schedule III at IC 35-48-2-8", "source_url": "https://codes.findlaw.com/in/title-35-criminal-law-and-procedure/in-code-sect-35-48-2-8/" }, "hgh_scheduled": { "value": false, "citation": "IC 35-48-2-8 (Schedule III)", "source_url": "https://codes.findlaw.com/in/title-35-criminal-law-and-procedure/in-code-sect-35-48-2-8/", "note": "Indiana's Schedule III adopts the federal anabolic steroid definition and does not list human growth hormone, somatropin or chorionic gonadotropin, so HGH is a prescription-only legend drug in Indiana rather than a state controlled substance." }, "peptides_scheduled": [], "pharmacy_board_glp1": null, "medical_board_peptides": null, "telehealth": { "summary": "Yes. IC 25-1-9.5-8 lets a prescriber issue a prescription by telehealth to a patient never examined in person if the standard of care is met and the drug is within scope and is not an opioid or abortion-inducing drug; the real-time two-way audiovisual requirement applies to controlled substances, so a non-controlled GLP-1 can be prescribed after an audio or video telehealth visit. The statute contains no express questionnaire ban.", "source_url": "https://codes.findlaw.com/in/title-25-professions-and-occupations/in-code-sect-25-1-9-5-8/" }, "enforcement": [ { "date": "2025-02-19", "summary": "Attorney General Todd Rokita signed the 38-state letter urging the FDA to act against counterfeit GLP-1s and online research-purposes-only sellers.", "source_url": "https://www.naag.org/press-releases/state-and-territory-attorneys-general-urge-fda-to-take-action-against-counterfeit-and-illegally-sold-glp-1-drugs/" } ], "possession_note": { "text": "Indiana is stricter than most states: the Indiana Legend Drug Act, IC 16-42-19-13, says a person may not possess or use a legend drug unless obtained on a practitioner's prescription, and a knowing violation is a Level 6 felony under IC 16-42-19-27, so possessing a prescription-only peptide such as semaglutide or HGH without a prescription is a state offence even though it is unscheduled; unapproved research peptides that are not legend drugs fall outside this section.", "source_url": "https://codes.findlaw.com/in/title-16-health/in-code-sect-16-42-19-13/" }, "confidence": "medium", "notes": "SB 282 (2026), which would have the Board of Pharmacy enforce federal compounding compliance for GLP-1s and require medspas distributing GLP-1s to register with the Medical Licensing Board, had passed the Senate and a House committee by late February 2026; its final status is unverified. No Indiana attorney general lawsuit or Board of Pharmacy GLP-1 statement specific to Indiana was found." }, { "state": "Iowa", "abbr": "IA", "csa_citation": { "citation": "Iowa Code chapter 124 (Uniform Controlled Substances Act); schedules at §§ 124.204, 124.206, 124.208, 124.210 and 124.212", "source_url": "https://www.legis.iowa.gov/docs/code/2024/124.html" }, "hgh_scheduled": { "value": false, "citation": "Iowa Code § 124.208 (Schedule III)", "source_url": "https://www.legis.iowa.gov/docs/code/124.208.pdf", "note": "Schedule III lists anabolic steroids only; the section contains no reference to human growth hormone, somatropin or chorionic gonadotropin. HGH is an ordinary prescription drug under Iowa Code chapter 155A, with the federal HGH statute on top." }, "peptides_scheduled": [], "pharmacy_board_glp1": { "summary": "Board of Pharmacy rule 481 IAC 552.22(2) prohibits compounding a preparation that is essentially a copy of an FDA-approved drug unless the prescriber documents a clinically significant difference for the individual patient or the approved product is on the FDA shortage list, and the prescription must document the change. It applies to semaglutide and tirzepatide copies without naming them. No separate Iowa statement on salt forms was found.", "date": "2025-08", "source_url": "https://www.legis.iowa.gov/docs/iac/rule/481.552.22.pdf" }, "medical_board_peptides": null, "telehealth": { "summary": "Yes. Board of Medicine rule 481 IAC 655.9 lets a valid physician-patient relationship be formed through a telemedicine encounter and waives the in-person interview and examination when the technology is sufficient to reach an informed diagnosis; it prohibits prescribing based solely on an internet request or a static internet questionnaire (an adaptive, interactive online interview is allowed) and prescribing on a phone call alone without an existing relationship.", "source_url": "https://www.legis.iowa.gov/docs/iac/rule/06-11-2025.481.655.9.pdf" }, "enforcement": [ { "date": "2025-02-19", "summary": "Iowa's attorney general signed the 38-state letter urging the FDA to act against counterfeit and research-only GLP-1 sales.", "source_url": "https://www.naag.org/press-releases/state-and-territory-attorneys-general-urge-fda-to-take-action-against-counterfeit-and-illegally-sold-glp-1-drugs/" } ], "possession_note": { "text": "Iowa's stand-alone offence for possessing a prescription drug without a prescription (Iowa Code § 155A.21) was repealed in 2024, so an individual holding an unscheduled research peptide commits no Iowa offence; § 155A.24 still makes selling, giving away or administering a non-controlled prescription drug outside the chapter a serious misdemeanor, so the exposure sits with sellers.", "source_url": "https://www.legis.iowa.gov/docs/code/155A.21.pdf" }, "confidence": "medium", "notes": "HSB 591, which would put medspas that dispense compounded GLP-1s under Board of Pharmacy licensing, had only cleared a House subcommittee as of February 2026. No Iowa attorney general or board enforcement against peptide sellers or medspas was found." }, { "state": "Kansas", "abbr": "KS", "csa_citation": { "citation": "Kansas Uniform Controlled Substances Act, K.S.A. 65-4101 et seq.; schedules at K.S.A. 65-4105 through 65-4113", "source_url": "https://ksrevisor.gov/statutes/chapters/ch65/065_041_0001.html" }, "hgh_scheduled": { "value": false, "citation": "K.S.A. 65-4109 (Schedule III), as amended by 2026 Session Laws of Kansas ch. 133 (HB 2365)", "source_url": "https://sos.ks.gov/publications/sessionlaws/2026/Chapter-133-HB-2365.html", "note": "The 2026 rewrite of Kansas's Schedule III expands the anabolic steroid list to 86 named steroids plus their salts and esters; there is still no human growth hormone, somatropin or chorionic gonadotropin entry. Kansas does not restrict HGH beyond prescription-only status and federal law." }, "peptides_scheduled": [], "pharmacy_board_glp1": { "summary": "The Kansas Board of Pharmacy's statement on compounding and dispensing compounded GLP-1 and GIP receptor agonists (approved 25 April 2024 and 17 April 2025) bars compounding essential copies unless the drug is on the FDA shortage list or a patient-specific clinically significant change is documented, bars semaglutide and tirzepatide salt forms, and requires pharmaceutical-grade ingredient, not \"research use\", investigational, food or supplement grade, with a certificate of analysis from an FDA-registered manufacturer. Dispensing a non-compliant compounded product is prohibited even if it was lawfully purchased.", "date": "2025-04-16", "source_url": "https://web.archive.org/web/2026id_/https://www.pharmacy.ks.gov/home/showpublisheddocument/9120/638804875360800000" }, "medical_board_peptides": null, "telehealth": { "summary": "Yes. The Kansas Telemedicine Act, K.S.A. 40-2,212(b), says telemedicine may be used to establish a valid provider-patient relationship, and providers are held to the same standards as in-person care; the Act contains no in-person examination prerequisite and no questionnaire ban for non-controlled drugs such as GLP-1s.", "source_url": "https://ksrevisor.gov/statutes/chapters/ch40/040_002_0212.html" }, "enforcement": [], "possession_note": { "text": "No Kansas offence was located for an individual possessing an unscheduled research peptide; the controlled-substance possession offences reach only scheduled substances, and no general prescription-only-drug possession provision was located in the Kansas Pharmacy Act within this check, so sellers rather than possessors carry the state exposure.", "source_url": "https://ksrevisor.gov/statutes/chapters/ch65/065_041_0001.html" }, "confidence": "high", "notes": "Kansas is not on the February 2025 multistate letter. No Kansas attorney general or Board of Healing Arts action or statement on peptides, medspas or compounded GLP-1s was found.", "verified": "2026-09-29" }, { "state": "Kentucky", "abbr": "KY", "csa_citation": { "citation": "KRS Chapter 218A (Controlled Substances); the schedules now sit in 902 KAR 55:015, since the statutory Schedule III (KRS 218A.090) was repealed in 2017", "source_url": "https://apps.legislature.ky.gov/law/statutes/chapter.aspx?id=38267" }, "hgh_scheduled": { "value": false, "citation": "902 KAR 55:015, Section 3 (Schedule III)", "source_url": "https://www.law.cornell.edu/regulations/kentucky/902-KAR-55-015", "note": "Kentucky's consolidated schedules list anabolic steroids in Schedule III but contain no human growth hormone, somatropin, hCG or other peptide entry." }, "peptides_scheduled": [], "pharmacy_board_glp1": { "summary": "The Board of Pharmacy's Important Update on compounding semaglutide and tirzepatide (2025) says compounding pharmacies generally may not compound either because both are commercially available, that 201 KAR 2:076 bars essential copies except as federal law allows, that a prescription naming only patient and formulation does not establish the clinical-difference exception and lower price never does. Its Compliance Alert of 14 November 2025 adds that 503B outsourcing facilities cannot rely on the clinical-difference exception, that neither drug is on the 503B bulks list, the Category 1 list or the shortage list, so 503B compounding of them is generally unlawful, and that pharmacies must source only from lawfully compounding facilities.", "date": "2025-11-14", "source_url": "https://pharmacy.ky.gov/professionals/Documents/GLP-1%20Compounding%20Guidance%202025.pdf" }, "medical_board_peptides": null, "telehealth": { "summary": "Yes. KRS 311.5975 requires the treating physician to obtain informed consent and keep telehealth records confidential and directs the Board of Medical Licensure to regulate telehealth; no Kentucky statute or board rule requiring an in-person exam before prescribing a non-controlled drug such as a GLP-1, or banning questionnaire-based prescribing, was located.", "source_url": "https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=30539" }, "enforcement": [ { "date": "2025-02-19", "summary": "Kentucky's attorney general signed the 38-state letter urging the FDA to act against counterfeit and research-only GLP-1 sales.", "source_url": "https://www.naag.org/press-releases/state-and-territory-attorneys-general-urge-fda-to-take-action-against-counterfeit-and-illegally-sold-glp-1-drugs/" } ], "possession_note": { "text": "Unscheduled research peptides are not controlled substances in Kentucky, but KRS 217.182 makes possession of any legend (prescription-only) drug other than as authorised a Class B misdemeanor, with a patient holding a prescription protected, so a person holding semaglutide or another prescription-only peptide without a prescription can be charged, while peptides that are not approved prescription drugs fall outside both regimes.", "source_url": "https://apps.legislature.ky.gov/law/statutes/statute.aspx?id=9310" }, "confidence": "medium", "notes": "HB 729 (2026 session), which would license and inspect compounders of GLP-1 injectables, was not enacted. A federal guilty plea by an Ashland doctor over misbranded semaglutide was reported but the Department of Justice page could not be opened, so it is omitted." }, { "state": "Louisiana", "abbr": "LA", "csa_citation": { "citation": "Louisiana Uniform Controlled Dangerous Substances Law, La. R.S. 40:961 et seq.; schedules at R.S. 40:964", "source_url": "https://codes.findlaw.com/la/revised-statutes/la-rev-stat-tit-40-sect-964/" }, "hgh_scheduled": { "value": false, "citation": "La. R.S. 40:964, Schedule III(E)", "source_url": "https://codes.findlaw.com/la/revised-statutes/la-rev-stat-tit-40-sect-964/", "note": "None of the five schedules in R.S. 40:964 names human growth hormone, somatropin, hCG or any peptide; Schedule III(E) covers testosterone-related anabolic steroids only." }, "peptides_scheduled": [], "pharmacy_board_glp1": { "summary": "In spring 2023 the Louisiana Board of Pharmacy warned in-state compounders, and out-of-state pharmacies shipping into Louisiana, to stop compounding with unapproved forms of semaglutide, specifically semaglutide sodium salt, which its executive director described as a cheaper research-grade form not intended for human use; pharmacies may compound only with bulk substances that comply with FDA rules, and the warning was not a ban on compounding semaglutide base. No formal board rule or order was located; the position rests on a contemporaneous NBC News report quoting the board.", "date": "2023-05", "source_url": "https://www.nbcnews.com/health/health-news/ozempic-wegovy-weight-loss-compounded-crackdowns-rcna82405" }, "medical_board_peptides": null, "telehealth": { "summary": "Restricted for weight loss. The Louisiana State Board of Medical Examiners' telemedicine rule (LAC 46:XLV.7513(C)) says a physician shall not use telemedicine to treat obesity under the board's weight-control medication rules, nor chronic non-cancer pain, and may prescribe controlled substances by telemedicine only after an in-person visit within the past year. A Louisiana physician therefore cannot prescribe a GLP-1 for obesity by telemedicine under the board's rule; diabetes prescribing is not covered by the prohibition. The rule text should be checked against the board's current version.", "source_url": "https://www.law.cornell.edu/regulations/louisiana/La-Admin-Code-tit-46-SS-XLV-7513" }, "enforcement": [ { "date": "2025-02-19", "summary": "Louisiana's attorney general signed the 38-state letter urging the FDA to act against counterfeit and research-only GLP-1 sales.", "source_url": "https://www.naag.org/press-releases/state-and-territory-attorneys-general-urge-fda-to-take-action-against-counterfeit-and-illegally-sold-glp-1-drugs/" } ], "possession_note": { "text": "Unscheduled research peptides are not controlled dangerous substances, but La. R.S. 40:1060.13 makes it unlawful to sell, deliver or possess any legend drug except on a practitioner's prescription, a misdemeanor, so possessing a prescription-only peptide such as semaglutide without a prescription is a state offence while peptides that are not prescription drugs fall outside it.", "source_url": "https://codes.findlaw.com/la/revised-statutes/la-rev-stat-tit-40-sect-1060-13/" }, "confidence": "medium", "notes": "The board's semaglutide-salt position could not be opened as a primary letter or order; the pharmacy board's site refused connections. The telemedicine obesity prohibition text is a 2017 version and should be confirmed against the current rules." }, { "state": "Maine", "abbr": "ME", "csa_citation": { "citation": "Maine Criminal Code, 17-A M.R.S. ch. 45 (§ 1101 et seq.); drug schedules W, X, Y and Z at 17-A M.R.S. § 1102", "source_url": "https://legislature.maine.gov/statutes/17-A/title17-Asec1102.html" }, "hgh_scheduled": { "value": false, "citation": "17-A M.R.S. § 1102 (Schedules W, X, Y and Z)", "source_url": "https://legislature.maine.gov/statutes/17-A/title17-Asec1102.html", "note": "Maine's own schedules do not name human growth hormone, somatropin, anabolic steroids or any peptide. HGH is restricted in Maine only through federal law and its prescription-only status." }, "peptides_scheduled": [], "pharmacy_board_glp1": { "summary": "No Maine Board of Pharmacy rule or statement on compounded semaglutide or tirzepatide was found. The only board-level item located is a correspondence entry on the 1 August 2024 meeting agenda, a request from Novo Nordisk to take action on compounded semaglutide; no resulting board action was found.", "date": "2024-08-01", "source_url": "https://www.maine.gov/pfr/professionallicensing/sites/maine.gov.pfr.professionallicensing/files/inline-files/DRAFT%5FAgenda_Pharmacy_08_01_2024.pdf" }, "medical_board_peptides": null, "telehealth": { "summary": "Yes. Under the Board of Licensure in Medicine's telemedicine rule (02-373 C.M.R. ch. 6, § 3) a physician-patient relationship may be formed through telemedicine if the standard of care does not require an in-person encounter, and telemedicine prescriptions carry the same accountability as in-person ones. Prescribing based solely on an internet request or a static internet questionnaire is prohibited; the interview must be adaptive and interactive, and the prescriber must hold a Maine licence.", "source_url": "https://www.law.cornell.edu/regulations/maine/02-373-C-M-R-ch-6-SS-3" }, "enforcement": [ { "date": "2025-02-19", "summary": "Maine'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.", "source_url": "https://www.naag.org/press-releases/state-and-territory-attorneys-general-urge-fda-to-take-action-against-counterfeit-and-illegally-sold-glp-1-drugs/" } ], "possession_note": { "text": "Maine's possession offence (17-A M.R.S. § 1107-A) applies only to drugs on schedules W to Z, so holding unscheduled research peptides is no Maine drug offence; no general offence for possessing a non-controlled prescription drug without a prescription was found, and the federal rules bind sellers rather than end users.", "source_url": "https://legislature.maine.gov/statutes/17-A/title17-Asec1107-A.html" }, "confidence": "medium", "notes": "A joint Boards of Medicine, Osteopathic Medicine and Nursing rule on IV therapy and medspa practice took effect in July 2026 (reported by AmSpa); it covers compounding standards but does not mention peptides or GLP-1s. No Maine action against peptide sellers or GLP-1 clinics was found." }, { "state": "Maryland", "abbr": "MD", "csa_citation": { "citation": "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", "source_url": "https://mgaleg.maryland.gov/mgawebsite/Laws/StatuteText?article=gcr§ion=5-404&enactments=false" }, "hgh_scheduled": { "value": false, "citation": "Md. Code, Crim. Law § 5-404 (Schedule III) and § 5-202", "source_url": "https://mgaleg.maryland.gov/mgawebsite/Laws/StatuteText?article=gcr§ion=5-404&enactments=false", "note": "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." }, "peptides_scheduled": [], "pharmacy_board_glp1": null, "medical_board_peptides": null, "telehealth": { "summary": "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.", "source_url": "https://www.law.cornell.edu/regulations/maryland/COMAR-10-32-05-05" }, "enforcement": [ { "date": "2025-02-19", "summary": "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.", "source_url": "https://www.naag.org/press-releases/state-and-territory-attorneys-general-urge-fda-to-take-action-against-counterfeit-and-illegally-sold-glp-1-drugs/" } ], "possession_note": { "text": "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.", "source_url": "https://mgaleg.maryland.gov/mgawebsite/Laws/StatuteText?article=gcr§ion=5-601&enactments=false" }, "confidence": "medium", "notes": "No Maryland Board of Pharmacy or Board of Physicians statement on compounded GLP-1s or peptides was found within the search budget." }, { "state": "Massachusetts", "abbr": "MA", "csa_citation": { "citation": "Massachusetts Controlled Substances Act, M.G.L. c. 94C (classes A to E at § 31); Department of Public Health schedules at 105 CMR 700.002, which adopt the federal Schedules I to V and define Schedule VI (Class E) as every prescription drug not in another schedule", "source_url": "https://www.law.cornell.edu/regulations/massachusetts/105-CMR-700-002" }, "hgh_scheduled": { "value": true, "citation": "M.G.L. c. 94C § 31, Class E(b) (prescription drugs not in another class), implemented by 105 CMR 700.002 (Schedule VI); possession at c. 94C § 34", "source_url": "https://web.archive.org/web/2026/https://malegislature.gov/Laws/GeneralLaws/PartI/TitleXV/Chapter94C/Section31", "note": "Massachusetts does not name HGH, but unlike most states it treats every prescription drug not in Schedules I to V as a Schedule VI (Class E) controlled substance, so somatropin, semaglutide, tirzepatide and other prescription peptides are Class E in Massachusetts. This is a catch-all for all prescription drugs, not a peptide-specific restriction." }, "peptides_scheduled": [], "pharmacy_board_glp1": null, "medical_board_peptides": null, "telehealth": { "summary": "Yes. Board of Registration in Medicine Policy 2020-01 (amended 3 February 2022) says the practice of medicine does not require a face-to-face encounter before care via telemedicine and that the standard of care is the same as in person; M.G.L. c. 112 § 5O defines telehealth to include online adaptive interviews for prescribing. No questionnaire-specific ban was found in the policy.", "source_url": "https://archives.lib.state.ma.us/server/api/core/bitstreams/690ed11c-b9e9-40b9-a267-be50e2fcd745/content" }, "enforcement": [ { "date": "2025-02-19", "summary": "Massachusetts' attorney general joined the 38-state letter urging the FDA to act against counterfeit and illegally sold GLP-1 drugs, including research-only sales.", "source_url": "https://www.naag.org/press-releases/state-and-territory-attorneys-general-urge-fda-to-take-action-against-counterfeit-and-illegally-sold-glp-1-drugs/" } ], "possession_note": { "text": "Because 105 CMR 700.002 makes all prescription drugs Class E controlled substances, possessing a prescription-only peptide such as semaglutide or HGH without a prescription can be charged as Class E possession under M.G.L. c. 94C § 34, whereas a substance that is not an approved prescription drug and is not federally scheduled, such as BPC-157 or TB-500 sold as a research chemical, falls in no Massachusetts class and its possession is not a state drug offence; the federal rules bind sellers.", "source_url": "https://www.law.cornell.edu/regulations/massachusetts/105-CMR-700-002" }, "confidence": "high", "notes": "The Massachusetts legislature's site refused connections, so M.G.L. c. 94C §§ 31 and 34 were read from archived copies captured in April and May 2026. Chapter 94C defines a prescription drug by the federal prescription-only legend, which is why unapproved research peptides fall outside Class E. Board of Registration in Pharmacy Policy 2020-02 on compounding copies of commercially available drugs could not be opened.", "verified": "2026-09-29" }, { "state": "Michigan", "abbr": "MI", "csa_citation": { "citation": "Michigan Public Health Code, Article 7 (Controlled Substances), MCL 333.7101 et seq.; schedules 1 to 5 at MCL 333.7212 to 333.7220", "source_url": "https://codes.findlaw.com/mi/chapter-333-health/mi-comp-laws-333-7216.html" }, "hgh_scheduled": { "value": false, "citation": "MCL 333.7214 (schedule 2), 333.7216 (schedule 3), 333.7218 (schedule 4)", "source_url": "https://codes.findlaw.com/mi/chapter-333-health/mi-comp-laws-333-7216.html", "note": "Schedules 2, 3 and 4 do not list human growth hormone, somatropin, anabolic steroids, chorionic gonadotropin or any peptide. Michigan restricts HGH only through federal law and prescription-only status." }, "peptides_scheduled": [], "pharmacy_board_glp1": null, "medical_board_peptides": null, "telehealth": { "summary": "Yes. MCL 333.16285 lets a health professional providing a telehealth service prescribe a drug within scope of practice, must offer a geographically accessible referral if medically necessary and make follow-up care available. The statute imposes no physical-examination requirement and no questionnaire ban.", "source_url": "https://codes.findlaw.com/mi/chapter-333-health/mi-comp-laws-333-16285.html" }, "enforcement": [ { "date": "2025-02-19", "summary": "Michigan Attorney General Dana Nessel joined the 38-state letter urging the FDA to act against counterfeit and illegally sold GLP-1 drugs, including research-only sales.", "source_url": "https://www.naag.org/press-releases/state-and-territory-attorneys-general-urge-fda-to-take-action-against-counterfeit-and-illegally-sold-glp-1-drugs/" } ], "possession_note": { "text": "Michigan's possession offence (MCL 333.7403) reaches only controlled substances, analogues and prescription forms of them, so possessing unscheduled research peptides is not a state drug offence; the separate misdemeanor in MCL 333.17766 covers obtaining a drug by prescription for other than a legitimate therapeutic purpose, which does not fit research-chemical purchases, and the federal rules bind sellers.", "source_url": "https://codes.findlaw.com/mi/chapter-333-health/mi-comp-laws-333-7403.html" }, "confidence": "medium", "notes": "Michigan statutes were read on a mirror because the legislature's site blocked fetches. A telehealth vendor blog claims Michigan issued 2026 GLP-1 compounding guidance, but no LARA or Board of Pharmacy document was found; treat as unverified." }, { "state": "Minnesota", "abbr": "MN", "csa_citation": { "citation": "Minnesota Statutes chapter 152 (Drugs; Controlled Substances); schedules at Minn. Stat. § 152.02", "source_url": "https://www.revisor.mn.gov/statutes/cite/152.02" }, "hgh_scheduled": { "value": true, "citation": "Minn. Stat. § 152.02, subd. 3(f)(2)", "source_url": "https://www.revisor.mn.gov/statutes/cite/152.02", "note": "Minnesota lists human growth hormones as a Schedule III controlled substance in its own statute, alongside anabolic steroids and chorionic gonadotropin. This goes beyond federal law, where HGH is not scheduled." }, "peptides_scheduled": [ { "name": "Human growth hormones, Schedule III", "citation": "Minn. Stat. § 152.02, subd. 3(f)(2)", "source_url": "https://www.revisor.mn.gov/statutes/cite/152.02" }, { "name": "Chorionic gonadotropin (hCG), Schedule III", "citation": "Minn. Stat. § 152.02, subd. 3(f)(3), except approved veterinary products", "source_url": "https://www.revisor.mn.gov/statutes/cite/152.02" } ], "pharmacy_board_glp1": { "summary": "The Board of Pharmacy's January 2026 newsletter says the Board is aware of multiple reports of potentially inappropriate use or distribution of semaglutide and tirzepatide injectables, that compounded GLP-1s and unapproved compounded combinations continue to be an issue including professionals prescribing outside their scope, and that any medication dispensed through a medspa or lifestyle clinic must carry a patient-specific label with the same information as a pharmacy label. No standalone Minnesota statement on semaglutide salt forms was found.", "date": "2026-01", "source_url": "https://mn.gov/boards/assets/4_Minnesota_SNL_Jan2026_V3_tcm21-718754.pdf" }, "medical_board_peptides": null, "telehealth": { "summary": "Yes. Minn. Stat. § 147.033 says a physician-patient relationship may be established through telehealth and holds telehealth to the same standard of care as in-person care, with no in-person examination requirement. The documented-evaluation rule in § 151.37 applies to controlled substances and a few named drug classes, not to GLP-1 drugs.", "source_url": "https://www.revisor.mn.gov/statutes/cite/147.033" }, "enforcement": [ { "date": "2025-02-19", "summary": "Minnesota's attorney general signed the 38-state letter urging the FDA to act against counterfeit and research-only GLP-1 sales.", "source_url": "https://www.naag.org/press-releases/state-and-territory-attorneys-general-urge-fda-to-take-action-against-counterfeit-and-illegally-sold-glp-1-drugs/" } ], "possession_note": { "text": "Possessing an unscheduled research peptide is not a controlled-substance offence in Minnesota, but Minn. Stat. § 151.37, subd. 1 makes it unlawful to possess, sell or distribute a legend (prescription-only) drug except as the chapter allows, so possessing a prescription-only peptide such as semaglutide without a prescription can itself be an offence, and hCG and HGH are Schedule III under § 152.02.", "source_url": "https://www.revisor.mn.gov/statutes/cite/151.37" }, "confidence": "medium", "notes": "Blog claims that a 2025 bill gave the boards new medspa audit powers are wrong; that bill concerns health care entity ownership reporting and was still in committee in February 2026. No Minnesota attorney general or medical board action specific to peptides or compounded GLP-1s was found." }, { "state": "Mississippi", "abbr": "MS", "csa_citation": { "citation": "Miss. Code Ann. § 41-29-101 et seq. (Uniform Controlled Substances Law); Schedule III at § 41-29-117", "source_url": "https://codes.findlaw.com/ms/title-41-public-health/ms-code-sect-41-29-101.html" }, "hgh_scheduled": { "value": false, "citation": "Miss. Code Ann. § 41-29-117 (Schedule III)", "source_url": "https://codes.findlaw.com/ms/title-41-public-health/ms-code-sect-41-29-117.html", "note": "Mississippi's Schedule III lists 65 named anabolic steroids but not human growth hormone, somatropin or chorionic gonadotropin, so only the federal HGH statute applies." }, "peptides_scheduled": [], "pharmacy_board_glp1": { "summary": "The Board of Pharmacy's compounding memo (April 2023, emailed to all medical licensees) states that semaglutide base is in an FDA-approved product but semaglutide sodium, semaglutide acetate and other salt forms are not, that the FDA had stated compounding with semaglutide salts does not meet the 503A bulk substance requirement, and that compounding in this manner may result in enforcement action by the FDA or the Board. It also warns that invoiced bulk substances may be research grade rather than pharmaceutical grade.", "date": "2023-04", "source_url": "https://www.mbp.ms.gov/sites/default/files/inline-images/Semaglutide.compoundguidance%20%28002%29.pdf" }, "medical_board_peptides": { "summary": "A joint statement of the State Board of Medical Licensure, the Board of Nursing and the Board of Pharmacy (19 August 2026) says that under no circumstances may a healthcare provider compound, administer, dispense, advise, recommend, supply or prescribe a non-FDA-approved or research-grade peptide to a patient; that providers must buy all prescription products and ingredients from an entity permitted by the Board of Pharmacy; that consent forms labelling a product research-grade do not reduce liability; and that where a patient independently acquires and self-administers such substances the risk rests solely with the patient, while any professional involvement is the practice of medicine and prohibited. Earlier guidance (August 2023) told licensees to stop prescribing compounded semaglutide, and a 2024 order created a limited waiver for compounded GLP-1s only for a documented clinical need or during a shortage, with certificate-of-analysis and ingredient verification required.", "date": "2026-08-19", "source_url": "https://www.msbml.ms.gov/peptide-statement" }, "telehealth": { "summary": "Yes for a non-controlled GLP-1, with conditions. Medical board rules (Title 30, Part 2635, Rules 5.4 and 5.5) require a valid physician-patient relationship with an appropriate history and examination; the exam need not be in person if the technology is sufficient, and a simple questionnaire without an appropriate exam violates the policy and may bring discipline. The 30-day in-person re-evaluation rule applies only when controlled substances are used for weight loss.", "source_url": "https://www.msbml.ms.gov/sites/default/files/Rules_Laws_Policies/07-2023Administrative%20Code.pdf" }, "enforcement": [ { "date": "2023-05-18", "summary": "The State Board of Medical Licensure suspended a physician's licence for three months for prescribing Ozempic through an instant-messaging telehealth platform with a questionnaire in place of an examination.", "source_url": "https://www.goodwinlaw.com/en/insights/publications/2024/03/alerts-lifesciences-hltc-changing-regulatory-reimbursement-weight-loss-drugs" }, { "date": "2025-02-19", "summary": "Mississippi's attorney general signed the 38-state letter urging the FDA to act against counterfeit and research-only GLP-1 sales.", "source_url": "https://www.naag.org/press-releases/state-and-territory-attorneys-general-urge-fda-to-take-action-against-counterfeit-and-illegally-sold-glp-1-drugs/" }, { "date": "2025-05-06", "summary": "Attorney General Lynn Fitch issued a consumer alert warning about unapproved and compounded semaglutide and tirzepatide sold by compounders, medspas, online retailers and social media sellers. An alert, not a lawsuit.", "source_url": "https://www.wtok.com/2025/05/06/ms-attorney-general-warns-mississippians-dangers-unapproved-weight-loss-medication/" }, { "date": "2026-08-19", "summary": "The medical, nursing and pharmacy boards jointly barred all licensed providers from compounding, administering, dispensing, prescribing or recommending research-grade peptides, and told licensees to report unlicensed entities shipping prescription products into the state.", "source_url": "https://www.msbml.ms.gov/sites/default/files/Documents/Peptide_Statement_MSBML_BON_BOP_Signed.pdf" } ], "possession_note": { "text": "Miss. Code Ann. § 41-29-139(c) criminalises knowing possession of a controlled substance without a valid prescription; unscheduled research peptides are outside it, and the boards' 2026 statement expressly says a patient who independently acquires and self-administers such substances bears the risk alone, while any licensed provider's involvement is prohibited.", "source_url": "https://codes.findlaw.com/ms/title-41-public-health/ms-code-sect-41-29-139.html" }, "confidence": "high", "notes": "Mississippi is the clearest state position on research peptides in the country: the boards do not restrict the buyer but prohibit every form of professional involvement. The medical board also bars off-label hCG solely for weight loss under Rule 1.5(F)." }, { "state": "Missouri", "abbr": "MO", "csa_citation": { "citation": "RSMo chapters 195 and 579, the Comprehensive Drug Control Act; schedules at RSMo § 195.017", "source_url": "https://revisor.mo.gov/main/OneSection.aspx?section=195.005" }, "hgh_scheduled": { "value": false, "citation": "RSMo § 195.017 (Schedule III)", "source_url": "https://revisor.mo.gov/main/OneSection.aspx?section=195.017", "note": "Missouri's schedules list anabolic steroids related to testosterone; human growth hormone, somatropin and chorionic gonadotropin do not appear in any schedule, so only the federal HGH statute applies." }, "peptides_scheduled": [], "pharmacy_board_glp1": { "summary": "No GLP-1-specific statement from the Missouri Board of Pharmacy was found. Its 2025 Pharmacy Practice Guide restates the general rules: Missouri law prohibits compounding preparations that are commercially available or essentially copies of them, and a bulk drug substance without a USP or NF monograph that is not a component of an approved drug cannot be used unless it is on the FDA 503A bulks list.", "date": "2025", "source_url": "https://pr.mo.gov/boards/pharmacy/practiceguide.pdf" }, "medical_board_peptides": null, "telehealth": { "summary": "Yes, with statutory conditions. RSMo § 191.1146 lets a physician-patient relationship be established by telemedicine if the standard of care does not require an in-person encounter, and requires any online questionnaire to be reviewed by the treating professional and to contain enough to substitute for an in-person evaluation. RSMo § 334.108 requires a reliable history and, where the standard of care requires, a physical examination before prescribing by telemedicine or the internet. Both sections were amended with effect from 28 August 2026, so check the current text.", "source_url": "https://revisor.mo.gov/main/OneSection.aspx?section=334.108" }, "enforcement": [], "possession_note": { "text": "RSMo § 579.015 criminalises knowing possession of a controlled substance only; no Missouri offence for an individual possessing an unscheduled research peptide was found, and the compounding and bulk-substance rules bind pharmacies and prescribers rather than consumers.", "source_url": "https://revisor.mo.gov/main/OneSection.aspx?section=579.015" }, "confidence": "medium", "notes": "Missouri is not on the February 2025 multistate letter; in September 2026 its attorney general joined a 20-state letter to the National Security Council about Chinese-sourced GLP-1 ingredients, which is advocacy rather than enforcement. No healing arts board guidance on peptides or medspas was found." }, { "state": "Montana", "abbr": "MT", "csa_citation": { "citation": "Mont. Code Ann. Title 50, chapter 32 (Controlled Substances), Part 2; Schedule III at MCA § 50-32-226", "source_url": "https://mca.legmt.gov/bills/mca/title_0500/chapter_0320/parts_index.html" }, "hgh_scheduled": { "value": false, "citation": "MCA § 50-32-226", "source_url": "https://mca.legmt.gov/bills/mca/title_0500/chapter_0320/part_0020/section_0260/0500-0320-0020-0260.html", "note": "Montana's Schedule III covers anabolic steroids but does not list human growth hormone, somatropin or chorionic gonadotropin, so only the federal HGH statute applies." }, "peptides_scheduled": [], "pharmacy_board_glp1": null, "medical_board_peptides": null, "telehealth": { "summary": "Yes. Board of Medical Examiners rule ARM 24.156.813 (amended February 2024) holds telemedicine to the in-person standard of care and allows the provider-patient relationship to be established through telemedicine if the standard of care does not require an in-person encounter; the licensee must obtain a medical history sufficient for diagnosis before prescribing. There is no explicit in-person examination mandate or questionnaire ban for non-controlled drugs such as GLP-1s.", "source_url": "https://www.law.cornell.edu/regulations/montana/Mont-Admin-r-24.156.813" }, "enforcement": [], "possession_note": { "text": "MCA § 45-9-102 (criminal possession of dangerous drugs) reaches only scheduled substances, so an individual possessing an unscheduled research peptide commits no Montana drug offence; the federal rules bind the sellers.", "source_url": "https://mca.legmt.gov/bills/mca/title_0450/chapter_0090/part_0010/section_0020/0450-0090-0010-0020.html" }, "confidence": "medium", "notes": "No Montana Board of Pharmacy, Board of Medical Examiners or attorney general statement on compounded GLP-1s or research peptides was found, and Montana is not on the February 2025 multistate letter. Treat the empty board fields as nothing found, not as confirmation that nothing exists." }, { "state": "Nebraska", "abbr": "NE", "csa_citation": { "citation": "Neb. Rev. Stat. § 28-401 et seq. (Uniform Controlled Substances Act); schedules at § 28-405", "source_url": "https://codes.findlaw.com/ne/chapter-28-crimes-and-punishments/ne-rev-st-sect-28-405.html" }, "hgh_scheduled": { "value": false, "citation": "Neb. Rev. Stat. § 28-405", "source_url": "https://codes.findlaw.com/ne/chapter-28-crimes-and-punishments/ne-rev-st-sect-28-405.html", "note": "The state schedules in § 28-405 enumerate anabolic steroids but do not list human growth hormone, somatropin, hCG or any peptide, so Nebraska does not restrict HGH beyond federal law." }, "peptides_scheduled": [], "pharmacy_board_glp1": null, "medical_board_peptides": null, "telehealth": { "summary": "Yes. Under Neb. Rev. Stat. § 38-1,143 any credential holder may establish a provider-patient relationship through telehealth and may prescribe during a telehealth service if authorised to prescribe under state and federal law; the statute imposes no in-person examination requirement and no questionnaire ban for non-controlled drugs such as semaglutide or tirzepatide.", "source_url": "https://codes.findlaw.com/ne/chapter-38-health-occupations-and-professions/ne-rev-st-sect-38-1-143.html" }, "enforcement": [], "possession_note": { "text": "Nebraska's possession offence, § 28-416(3), applies only to substances on the state schedules, so an individual holding unscheduled research peptides commits no offence under it; no general Nebraska offence for possessing a non-controlled prescription drug without a prescription was located.", "source_url": "https://codes.findlaw.com/ne/chapter-28-crimes-and-punishments/ne-rev-st-sect-28-416.html" }, "confidence": "medium", "notes": "Nebraska's state servers refused connections during this check, so no Board of Pharmacy or Board of Medicine and Surgery statement on GLP-1s or peptides could be checked. Nebraska did not sign the February 2025 multistate letter." }, { "state": "Nevada", "abbr": "NV", "csa_citation": { "citation": "Nev. Rev. Stat. Chapter 453, Uniform Controlled Substances Act (NRS 453.011 et seq.); schedules adopted by the State Board of Pharmacy by regulation at NAC 453.510 to 453.550", "source_url": "https://nevada.public.law/statutes/nrs_453.011" }, "hgh_scheduled": { "value": true, "citation": "NAC 453.530(13)", "source_url": "https://www.law.cornell.edu/regulations/nevada/NAC-453-530", "note": "Nevada goes beyond federal law: the Board of Pharmacy has placed human growth hormone on state Schedule III by regulation (NAC 453.530(13)). Possession without a prescription therefore falls under NRS 453.336." }, "peptides_scheduled": [ { "name": "Human growth hormone (somatropin), Schedule III", "citation": "NAC 453.530(13)", "source_url": "https://www.law.cornell.edu/regulations/nevada/NAC-453-530" }, { "name": "Chorionic gonadotropin (hCG), Schedule III", "citation": "NAC 453.530(7)(h) and (8)", "source_url": "https://www.law.cornell.edu/regulations/nevada/NAC-453-530" } ], "pharmacy_board_glp1": { "summary": "A State Board of Pharmacy licensee notice (2 June 2025) relayed the FDA's declaratory orders: 503A and 503B pharmacies may no longer compound, distribute or dispense compounded tirzepatide injections, and 503A pharmacies may no longer compound semaglutide injections (503B facilities from 22 May 2025). It reminds 503A pharmacies they may not sell compounded drugs to practitioners, points to the NAC 639.757 compounding limits, and warns that continued compounding or wholesaling of federally restricted drugs violates Nevada pharmacy law with citations and fines under NRS 639.2895.", "date": "2025-06-02", "source_url": "https://bop.nv.gov/uploadedFiles/bopnvgov/content/Resources/ALL/Notice%20to%20Compound%20Pharm%20re%20Tirzepatide%20semaglutide%20FINAL.pdf" }, "medical_board_peptides": null, "telehealth": { "summary": "Yes. NRS 629.515 requires the distant-site provider to hold a Nevada licence and allows a relationship to be established by telehealth when clinically appropriate; there is no in-person examination requirement and no questionnaire ban for non-controlled drugs, but the provider must meet the same standard of care as in person.", "source_url": "https://codes.findlaw.com/nv/title-54-professions-occupations-and-businesses/nv-rev-st-629-515/" }, "enforcement": [ { "date": "2023-06-09", "summary": "The State Board of Pharmacy confirmed several open investigations into sales of substances marketed as semaglutide for weight loss, working with the FDA on salt-form and legitimacy concerns.", "source_url": "https://www.8newsnow.com/investigators/nevada-pharmacy-board-investigating-possible-sales-of-drugs-like-ozempic/" }, { "date": "2024-09-12", "summary": "The Board of Pharmacy issued a cease and desist, a citation and a $655,000 fine to Texas-based Nova Specialty Pharmacy for dispensing more than 100 prescriptions, including compounded semaglutide, to Nevadans without a Nevada licence.", "source_url": "https://www.reviewjournal.com/news/politics-and-government/nevada/stop-dispensing-prescriptions-to-nevadans-state-regulators-tell-pharmacy-3168580/" }, { "date": "2025-02-19", "summary": "Nevada's attorney general signed the 38-state letter urging the FDA to act against counterfeit and illegally sold GLP-1 drugs, including research-only labelled product.", "source_url": "https://www.naag.org/press-releases/state-and-territory-attorneys-general-urge-fda-to-take-action-against-counterfeit-and-illegally-sold-glp-1-drugs/" }, { "date": "2025-06-02", "summary": "The Board of Pharmacy ordered all Nevada-licensed pharmacies to cease compounding, distributing and dispensing compounded tirzepatide and semaglutide injections, with fines for non-compliance.", "source_url": "https://bop.nv.gov/uploadedFiles/bopnvgov/content/Resources/ALL/Notice%20to%20Compound%20Pharm%20re%20Tirzepatide%20semaglutide%20FINAL.pdf" } ], "possession_note": { "text": "Possessing HGH or hCG without a prescription is a controlled-substance offence in Nevada (NRS 453.336) because both are on state Schedule III; unscheduled peptides such as BPC-157 or TB-500 are not covered by that section, but NRS 454.316 separately makes possession of any prescription-only dangerous drug without a prescription a gross misdemeanor, so a compounded or prescription-only peptide held without a prescription can still be charged.", "source_url": "https://nevada.public.law/statutes/nrs_454.316" }, "confidence": "high", "notes": "Nevada is one of the few states that schedules both HGH and hCG at state level. No Board of Medical Examiners statement on research peptides, BPC-157 or medspas was found; enforcement to date has come from the Board of Pharmacy." }, { "state": "New Hampshire", "abbr": "NH", "csa_citation": { "citation": "N.H. Rev. Stat. Ann. ch. 318-B, Controlled Drug Act (RSA 318-B:1 et seq.); schedules by rule under RSA 318-B:1-a and N.H. Admin. R. He-C 501", "source_url": "https://web.archive.org/web/2025/https://www.gencourt.state.nh.us/rsa/html/XXX/318-B/318-B-1.htm" }, "hgh_scheduled": { "value": false, "citation": "RSA 318-B:1, VI and 318-B:1-a; N.H. Admin. R. He-C 501.03(a)", "source_url": "https://web.archive.org/web/2025/https://gc.nh.gov/rules/state_agencies/he-c500.html", "note": "New Hampshire's controlled drugs are the substances in the federal schedules (21 CFR 1308.11 to 1308.15), adopted by rule, plus any the commissioner adds after a hearing. Human growth hormone is not in the federal schedules, no state addition appears in He-C 501, and the statute's own anabolic steroid definition lists 16 steroids and no HGH or hCG, so only the federal HGH statute applies." }, "peptides_scheduled": [], "pharmacy_board_glp1": null, "medical_board_peptides": null, "telehealth": { "summary": "Yes for non-controlled drugs such as semaglutide and tirzepatide. Under RSA 329:1-d a physician may establish the physician-patient relationship by telemedicine by verifying identity, disclosing credentials, obtaining consent and meeting the standard of care; the annual in-person examination requirement applies only to Schedule II to IV controlled drugs. Summary from a secondary policy compilation, as the statute itself could not be opened.", "source_url": "https://cchpca.org/telehealth-policy/current-state-laws-and-reimbursement-policies/new-hampshire-professional-regulationhealth-safety-online-prescribing" }, "enforcement": [], "possession_note": { "text": "RSA 318-B:2 makes it unlawful to possess a controlled drug without lawful authority, so an individual holding unscheduled research peptides commits no offence under the Controlled Drug Act unless the substance has been scheduled; whether New Hampshire has a separate offence for possessing a non-controlled prescription drug without a prescription was not verified because the primary sources were unreachable.", "source_url": "https://www.cchpca.org/new-hampshire/" }, "confidence": "medium", "notes": "New Hampshire's statute and rules sites blocked direct requests, so RSA 318-B:1, RSA 318-B:1-a and He-C 500 were read from archived copies (2024 and 2025). The health department's published schedule itself could not be opened. New Hampshire did not sign the February 2025 multistate letter.", "verified": "2026-09-29" }, { "state": "New Jersey", "abbr": "NJ", "csa_citation": { "citation": "N.J.S.A. 24:21-1 et seq., New Jersey Controlled Dangerous Substances Act; schedules at N.J.S.A. 24:21-5 to 24:21-8.1, supplemented by N.J.A.C. 13:45H-10.1", "source_url": "https://www.njconsumeraffairs.gov/statutes/new-jersey-controlled-dangerous-substances-act.pdf" }, "hgh_scheduled": { "value": false, "citation": "N.J.S.A. 24:21-7 (Schedule III) and N.J.A.C. 13:45H-10.1", "source_url": "https://www.law.cornell.edu/regulations/new-jersey/N-J-A-C-13-45H-10-1", "note": "The statutory schedules do not mention human growth hormone, somatropin or hCG, and N.J.A.C. 13:45H-10.1 incorporates the federal schedules by reference; HGH is not in the federal schedules, so New Jersey does not restrict it beyond federal law." }, "peptides_scheduled": [], "pharmacy_board_glp1": { "summary": "The Board of Pharmacy's Statement Concerning Semaglutide Compounding says compounding semaglutide is generally prohibited as an essential copy of a commercially available drug except while the FDA lists it in shortage or where a prescriber documents a patient-specific significant difference; only semaglutide base is a component of an FDA-approved drug and semaglutide is not on the bulks list, so no salt form (sodium or acetate) may be used; any base active ingredient must be pharmaceutical grade, carry a certificate of analysis and come from an FDA-registered establishment. Adding other ingredients does not avoid the essential-copy rule. It predates the end of the shortage, so read it as the standing sourcing rule rather than permission to compound now.", "date": "2023-11-06", "source_url": "https://www.njconsumeraffairs.gov/phar/Documents/Semaglutide-Compounding-Statement-04282023.pdf" }, "medical_board_peptides": null, "telehealth": { "summary": "Yes. N.J.S.A. 45:1-62(a) lets a provider who establishes a proper relationship treat and prescribe remotely to the in-person standard of care; subsection (d)(2) bars issuing a prescription based solely on the responses to an online static questionnaire absent an established relationship; the in-person examination and three-monthly visit rules apply only to Schedule II drugs, which GLP-1s are not.", "source_url": "https://codes.findlaw.com/nj/title-45-professions-and-occupations/nj-st-sect-45-1-62/" }, "enforcement": [], "possession_note": { "text": "Unscheduled research peptides are outside the Controlled Dangerous Substances Act, but N.J.S.A. 2C:35-10.5 makes it a disorderly persons offence to possess four or fewer dosage units of a prescription legend drug without a valid prescription and a fourth-degree crime to possess five or more, so a prescription-only peptide such as compounded semaglutide held without a prescription can be charged in New Jersey.", "source_url": "https://codes.findlaw.com/nj/title-2c-the-new-jersey-code-of-criminal-justice/nj-st-sect-2c-35-10-5.html" }, "confidence": "medium", "notes": "No New Jersey attorney general or Board of Medical Examiners action against peptide sellers or medspas was found, and New Jersey did not sign the February 2025 multistate letter." }, { "state": "New Mexico", "abbr": "NM", "csa_citation": { "citation": "Controlled Substances Act, NMSA 1978, Sections 30-31-1 to 30-31-41; schedules at 30-31-6 to 30-31-10, supplemented by Board of Pharmacy rule 16.19.20 NMAC", "source_url": "https://codes.findlaw.com/nm/chapter-30-criminal-offenses/nm-st-sect-30-31-1/" }, "hgh_scheduled": { "value": false, "citation": "NMSA 1978, Section 30-31-8 (Schedule III) and 16.19.20.67 NMAC", "source_url": "https://www.law.cornell.edu/regulations/new-mexico/N-M-Admin-Code-SS-16.19.20.67", "note": "Neither the statutory Schedule III nor the Board of Pharmacy's Schedule III rule lists human growth hormone, somatropin or chorionic gonadotropin; the anabolic steroid entry covers testosterone-related steroids only. HGH is a prescription-only dangerous drug in New Mexico, restricted no further than federal law." }, "peptides_scheduled": [], "pharmacy_board_glp1": null, "medical_board_peptides": null, "telehealth": { "summary": "Yes. The Medical Board's ethics rule (16.10.8.8(L) NMAC) permits treatment during a face-to-face telehealth encounter by videoconference where history, informed consent and a medical record are obtained and a physical exam is recorded or properly waived; prescribing based solely on an online questionnaire is listed as unprofessional conduct. No in-person visit is required before a non-controlled GLP-1 prescription.", "source_url": "https://www.srca.nm.gov/parts/title16/16.010.0008.html" }, "enforcement": [ { "date": "2025-02-19", "summary": "New Mexico's attorney general signed the 38-state letter urging the FDA to act against counterfeit and research-only GLP-1 sales.", "source_url": "https://www.naag.org/press-releases/state-and-territory-attorneys-general-urge-fda-to-take-action-against-counterfeit-and-illegally-sold-glp-1-drugs/" }, { "date": "2025-10-31", "summary": "The New Mexico Department of Justice issued a consumer alert warning that unapproved, compounded or counterfeit GLP-1 weight-loss drugs were being sold by medspas, wellness clinics and online sellers, asking residents to use licensed prescribers and pharmacies and to report sellers to its Consumer Protection Division. A warning, not a case against a named defendant.", "source_url": "https://nmdoj.gov/press-release/media-alert-the-new-mexico-department-of-justice-urges-community-members-to-be-vigilant-when-seeking-weight-loss-medications/" } ], "possession_note": { "text": "Unscheduled research peptides are not controlled substances, so the possession offence in NMSA 30-31-23 does not reach them; NMSA 26-1-16(E) does make it unlawful to possess any prescription-only dangerous drug that was not dispensed by a practitioner or on a prescription, which could apply to injectable peptides sold as prescription drugs, while research-only vials are mainly a seller-side federal issue.", "source_url": "https://codes.findlaw.com/nm/chapter-26-drugs-and-cosmetics/nm-st-sect-26-1-16/" }, "confidence": "medium", "notes": "No New Mexico Board of Pharmacy or Medical Board statement on compounded GLP-1s or research peptides was found. The telehealth rule text dates from 2009 and should be read alongside the newer New Mexico Telehealth Act." }, { "state": "New York", "abbr": "NY", "csa_citation": { "citation": "N.Y. Public Health Law Article 33 (Sections 3300 et seq.); schedules at Public Health Law Section 3306; criminal offences in Penal Law Article 220", "source_url": "https://www.nysenate.gov/legislation/laws/PBH/3306" }, "hgh_scheduled": { "value": false, "citation": "N.Y. Public Health Law Section 3306", "source_url": "https://www.nysenate.gov/legislation/laws/PBH/3306", "note": "Human growth hormone and somatropin do not appear in any of New York's five schedules; the anabolic steroid entry covers testosterone-related substances only. HGH is a prescription drug in New York with no state scheduling beyond federal law." }, "peptides_scheduled": [ { "name": "Chorionic gonadotropin (hCG), Schedule III", "citation": "N.Y. Public Health Law Section 3306, Schedule III(g)(1)", "source_url": "https://www.nysenate.gov/legislation/laws/PBH/3306" } ], "pharmacy_board_glp1": null, "medical_board_peptides": null, "telehealth": { "summary": "Yes. Public Health Law 2999-cc defines telehealth to include assessment, diagnosis and treatment by electronic means, including audio-only telephone, and imposes no in-person visit before treatment or prescribing a non-controlled drug such as semaglutide. Prescribers are expected to establish the relationship by a real-time audio-visual or audio contact; a questionnaire-only intake is not accepted practice, though no statutory questionnaire ban was located.", "source_url": "https://www.nysenate.gov/legislation/laws/PBH/2999-CC" }, "enforcement": [ { "date": "2025-02-19", "summary": "New York's attorney general signed the 38-state letter urging the FDA to act against counterfeit and research-only GLP-1 sales.", "source_url": "https://www.naag.org/press-releases/state-and-territory-attorneys-general-urge-fda-to-take-action-against-counterfeit-and-illegally-sold-glp-1-drugs/" } ], "possession_note": { "text": "Possessing an unscheduled research peptide is not a New York controlled-substance offence, since Penal Law Article 220 reaches only substances scheduled in Public Health Law 3306, where hCG is the one peptide listed; Education Law 6811 makes selling or holding for sale misbranded drugs a class A misdemeanor, which targets sellers and contains no offence for simple personal possession of a non-controlled prescription drug.", "source_url": "https://www.nysenate.gov/legislation/laws/EDN/6811" }, "confidence": "medium", "notes": "No New York attorney general release on compounded or counterfeit GLP-1s, peptides or medspas was found for 2023 to 2026, and no state pharmacy guidance on compounded semaglutide was located." }, { "state": "North Carolina", "abbr": "NC", "csa_citation": { "citation": "North Carolina Controlled Substances Act, N.C. Gen. Stat. Chapter 90, Article 5, Sections 90-86 et seq.; schedules at G.S. 90-89 to 90-94", "source_url": "https://codes.findlaw.com/nc/chapter-90-medicine-and-allied-occupations/nc-gen-st-sect-90-86/" }, "hgh_scheduled": { "value": false, "citation": "N.C. Gen. Stat. 90-91 (Schedule III)", "source_url": "https://codes.findlaw.com/nc/chapter-90-medicine-and-allied-occupations/nc-gen-st-sect-90-91/", "note": "Human growth hormone and somatropin are not listed in North Carolina's Schedule III or elsewhere in the state schedules; only chorionic gonadotropin is swept into the anabolic steroid subdivision. HGH is prescription-only in North Carolina with no state restriction beyond federal law." }, "peptides_scheduled": [ { "name": "Chorionic gonadotropin (hCG), Schedule III", "citation": "N.C. Gen. Stat. 90-91(k), item 7 of the anabolic steroid list, excepting veterinary use", "source_url": "https://codes.findlaw.com/nc/chapter-90-medicine-and-allied-occupations/nc-gen-st-sect-90-91/" } ], "pharmacy_board_glp1": { "summary": "The Board of Pharmacy's July 2023 newsletter (item 2465) applied the federal essentially-a-copy rules to compounding semaglutide, taking the position that only semaglutide base is a component of an FDA-approved drug and that salt forms such as semaglutide sodium and semaglutide acetate are research-use-only substances not appropriate for compounding. The Board's PDF blocks automated fetches, so the salt-form wording is confirmed through law-firm summaries of it.", "date": "2023-07", "source_url": "https://www.ncbop.org/downloads/July2023.pdf" }, "medical_board_peptides": null, "telehealth": { "summary": "Yes. The Medical Board's position statement on telemedicine (last amended March 2024) says the pre-prescribing evaluation need not be in person if the technology meets the standard of care, but that diagnosing or prescribing based solely on static online questionnaires is not acceptable; questionnaires must allow follow-up questions. GLP-1s are non-controlled, so a video or equivalent telehealth visit suffices.", "source_url": "https://www.ncmedboard.org/resources-information/professional-resources/laws-rules-position-statements/position-statements/telemedicine" }, "enforcement": [ { "date": "2025-02-19", "summary": "North Carolina's attorney general signed the 38-state letter urging the FDA to act against counterfeit and research-only GLP-1 sales.", "source_url": "https://www.naag.org/press-releases/state-and-territory-attorneys-general-urge-fda-to-take-action-against-counterfeit-and-illegally-sold-glp-1-drugs/" } ], "possession_note": { "text": "G.S. 90-95(a)(3) criminalises possession of a controlled substance only, so possessing an unscheduled research peptide is not a state drug offence; hCG is Schedule III in North Carolina and possessing it without a prescription is one. No general North Carolina offence for possessing a non-controlled prescription drug was identified.", "source_url": "https://codes.findlaw.com/nc/chapter-90-medicine-and-allied-occupations/nc-gen-st-sect-90-95/" }, "confidence": "medium", "notes": "An editor should open the Board of Pharmacy's July 2023 PDF directly before quoting its salt-form wording. No Medical Board statement on research peptides, BPC-157 or peptide clinics was found." }, { "state": "North Dakota", "abbr": "ND", "csa_citation": { "citation": "Uniform Controlled Substances Act, N.D. Cent. Code Chapter 19-03.1; schedules at 19-03.1-05 to 19-03.1-13", "source_url": "https://ndlegis.gov/cencode/t19c03-1.html" }, "hgh_scheduled": { "value": false, "citation": "N.D. Cent. Code 19-03.1-09 (Schedule III)", "source_url": "https://codes.findlaw.com/nd/title-19-foods-drugs-oils-and-compounds/nd-cent-code-sect-19-03-1-09/", "note": "North Dakota's Schedule III lists specific anabolic steroid molecules but no human growth hormone, somatropin, chorionic gonadotropin or other peptide. HGH is a prescription drug in North Dakota with no state restriction beyond federal law." }, "peptides_scheduled": [], "pharmacy_board_glp1": null, "medical_board_peptides": null, "telehealth": { "summary": "Yes, after a real examination. N.D. Cent. Code 43-17-44 requires an examination before initially diagnosing or treating, which may be done by secure videoconferencing, store-and-forward technology or through an intervening licensed provider, and says an evaluation consisting only of a static online questionnaire or an audio conversation does not meet the standard of care. After a compliant exam the licensee may prescribe non-controlled drugs such as GLP-1s.", "source_url": "https://codes.findlaw.com/nd/title-43-occupations-and-professions/nd-cent-code-sect-43-17-44/" }, "enforcement": [ { "date": "2025-02-19", "summary": "North Dakota's attorney general signed the 38-state letter urging the FDA to act against counterfeit and research-only GLP-1 sales.", "source_url": "https://www.naag.org/press-releases/state-and-territory-attorneys-general-urge-fda-to-take-action-against-counterfeit-and-illegally-sold-glp-1-drugs/" } ], "possession_note": { "text": "N.D. Cent. Code 19-03.1-23(7) makes it unlawful to wilfully possess a controlled substance without a valid prescription, so holding unscheduled research peptides is no state controlled-substance offence; no separate North Dakota offence for possessing a non-controlled prescription drug was found in the chapter.", "source_url": "https://codes.findlaw.com/nd/title-19-foods-drugs-oils-and-compounds/nd-cent-code-sect-19-03-1-23/" }, "confidence": "medium", "notes": "No North Dakota Board of Pharmacy, Board of Medicine or attorney general statement on compounded GLP-1s, peptides or medspas was found; board items are absent rather than confirmed absent." }, { "state": "Ohio", "abbr": "OH", "csa_citation": { "citation": "Ohio Revised Code Chapter 3719 (Controlled Substances); schedules at ORC 3719.41 as amended by Board of Pharmacy rule (Ohio Adm. Code 4729:9-1-01 to 4729:9-1-05)", "source_url": "https://law.onecle.com/ohio/title-37/3719.41.html" }, "hgh_scheduled": { "value": false, "citation": "Ohio Adm. Code 4729:9-1-03 (Schedule III); ORC 3719.41", "source_url": "https://www.law.cornell.edu/regulations/ohio/Ohio-Admin-Code-4729-9-1-03", "note": "Ohio's Schedule III, including its anabolic steroid section, does not list human growth hormone, somatropin, hCG or any peptide. Separately, State Medical Board rule 4731-11-03(A)(1) bars physicians from prescribing growth hormone, testosterone or analogs to enhance athletic ability." }, "peptides_scheduled": [], "pharmacy_board_glp1": { "summary": "The Board of Pharmacy's guidance Compounding of GLP-1 Drug Products in Ohio (17 July 2025) says that after the FDA removed semaglutide and tirzepatide from the shortage list, compounded copies are essentially copies and may only be made where the drug is commercially unavailable or the prescriber documents a significant difference for the individual patient, and that active ingredient must be bought from an Ohio-licensed drug distributor. A later Board compliance alert (reported April 2026) says retatrutide is not FDA approved, semaglutide and BPC-157 cannot currently be compounded, and the Board has revoked or suspended several medspa terminal distributor licences for buying from unlicensed sellers or using research-use-only products. The Board's own PDFs block automated fetches, so both are confirmed through law-firm summaries.", "date": "2025-07-17", "source_url": "https://www.foley.com/insights/publications/2025/08/glp-1-drugs-ohio-board-pharmacy-issues-faqs-compounders/" }, "medical_board_peptides": { "summary": "No State Medical Board statement on research peptides or BPC-157 was found; Ohio's peptide positions come from the Board of Pharmacy, whose compliance material says BPC-157 cannot be compounded and lists buying research-use-only or unlicensed-source peptides among the common prescriber clinic and medspa violations that cost licences.", "date": "2026-04", "source_url": "https://www.bmdllc.com/resources/blog/ohio-med-spas-peptide-dos-and-do-nots/" }, "telehealth": { "summary": "Yes. ORC 4743.09 authorises telehealth by physicians and other prescribers, and Medical Board rule 4731-11-09 requires an in-person examination of a new patient only before prescribing a Schedule II controlled substance; semaglutide and tirzepatide are non-controlled, so no in-person rule applies, though the prescriber must meet the standard of care. No express Ohio ban on questionnaire-only prescribing was found.", "source_url": "https://www.law.cornell.edu/regulations/ohio/Ohio-Admin-Code-4731-11-09" }, "enforcement": [ { "date": "2025-02-19", "summary": "Attorney General Dave Yost signed the 38-state letter urging the FDA to act against counterfeit and research-only GLP-1 sales.", "source_url": "https://www.naag.org/press-releases/state-and-territory-attorneys-general-urge-fda-to-take-action-against-counterfeit-and-illegally-sold-glp-1-drugs/" }, { "date": "2025-04-16", "summary": "Attorney General Yost sent warning letters to 14 Ohio medspas for advertising compounded semaglutide and tirzepatide as FDA approved or equivalent to the brand drugs.", "source_url": "https://spectrumnews1.com/oh/columbus/news/2025/04/16/attorney-general-sends-warnings-to-med-spas-for-weight-loss-drugs" }, { "date": "2026-04-29", "summary": "The Board of Pharmacy has revoked or suspended several medspa terminal distributor of dangerous drugs licences for purchasing from unlicensed sellers and using research-purposes-only, unapproved or foreign drugs, per a law-firm summary of the Board's compliance alert; individual orders were not opened.", "source_url": "https://www.bmdllc.com/resources/blog/ohio-med-spas-peptide-dos-and-do-nots/" } ], "possession_note": { "text": "Possessing an unscheduled research peptide is not a controlled-substance offence in Ohio; ORC 2925.11(A) reaches only scheduled drugs, so it would apply to a peptide only if Ohio scheduled it, and the federal rules bind the seller.", "source_url": "https://law.onecle.com/ohio/title-29/2925.11.html" }, "confidence": "medium", "notes": "The Board of Pharmacy's GLP-1 and peptide documents and the attorney general's April 2025 release are confirmed through secondary summaries because the state sites block automated fetches; an editor should open them directly. Ohio is one of the more active states against medspas using research-grade product." }, { "state": "Oklahoma", "abbr": "OK", "csa_citation": { "citation": "Uniform Controlled Dangerous Substances Act, 63 O.S. § 2-101 et seq.; Schedule III at 63 O.S. § 2-208", "source_url": "https://www.oklegislature.gov/OK_Statutes/CompleteTitles/os63.rtf" }, "hgh_scheduled": { "value": false, "citation": "63 O.S. § 2-208(A)(2); 63 O.S. § 2-312.1", "source_url": "https://www.oklegislature.gov/OK_Statutes/CompleteTitles/os63.rtf", "note": "Oklahoma's Schedule III names 27 anabolic steroids and no growth hormone, hCG or peptide. Separately, 63 O.S. § 2-312.1 (as amended effective 1 January 2026) bars practitioners from prescribing, dispensing or administering human growth hormone or anabolic steroids for bodybuilding, muscle enhancement or strength in a healthy person; its felony and licence penalties are written for anabolic steroids." }, "peptides_scheduled": [], "pharmacy_board_glp1": null, "medical_board_peptides": null, "telehealth": { "summary": "Yes. GLP-1 drugs are non-controlled and Oklahoma has no in-person requirement for them. Board of Medical Licensure rule OAC 435:10-7-13 lets a physician establish the relationship by telemedicine if the information available is equivalent to a face-to-face encounter and meets the standard of care, with a documented history, examination, diagnosis and treatment plan.", "source_url": "https://www.cchpca.org/oklahoma/?category=professional-requirements&topic=online-prescribing" }, "enforcement": [ { "date": "2025-02-26", "summary": "Attorney General Gentner Drummond announced he had joined 37 other attorneys general in the letter urging the FDA to act on counterfeit GLP-1s and online sellers marketing active ingredient for research purposes only.", "source_url": "https://oklahoma.gov/oag/news/newsroom/2025/february/drummond-calls-on-fda-to-take-action-against-counterfeit-weight-loss-drug-makers.html" } ], "possession_note": { "text": "Unscheduled research peptides are outside the Uniform Controlled Dangerous Substances Act, so an individual holding them commits no state controlled-substance offence; possession of a Schedule III substance without a prescription is a misdemeanor, and the distribution provisions in 63 O.S. § 2-401 target sellers rather than personal possession.", "source_url": "https://www.edgecriminaldefense.com/oklahoma-schedule-iii-drugs" }, "confidence": "high", "notes": "Checked against the official Title 63 file on the Oklahoma legislature's site, which includes the 2025 session amendments. No Oklahoma Board of Pharmacy, Medical Board or Osteopathic Board statement on GLP-1s or peptides was found.", "verified": "2026-09-29" }, { "state": "Oregon", "abbr": "OR", "csa_citation": { "citation": "ORS Chapter 475 (Controlled Substances), ORS 475.005 and 475.035; schedules adopted by the State Board of Pharmacy in OAR 855-080", "source_url": "https://oregon.public.law/statutes/ors_475.035" }, "hgh_scheduled": { "value": false, "citation": "OAR 855-080-0023 (Schedule III incorporates 21 CFR 1308.13)", "source_url": "https://oregon.public.law/rules/oar_855-080-0023", "note": "Oregon incorporates the federal Schedule III by reference, and the federal schedule does not list human growth hormone, somatropin or chorionic gonadotropin, so HGH is not a controlled substance in Oregon; it remains a prescription drug restricted by the federal HGH statute." }, "peptides_scheduled": [], "pharmacy_board_glp1": { "summary": "The Board of Pharmacy's Semaglutide Position Statement (adopted 6 February 2025) says compounding is barred where the product is an essential copy of a commercially available drug; that a prescription showing only a patient name and formulation does not invoke the patient-specific exception and lower price is never a justification; that only semaglutide base is a component of an approved drug, semaglutide is not on the 503A bulks list and no salt form may be used; that active ingredient must be pharmaceutical grade with a certificate of analysis from an FDA-registered establishment; and that research-use-only products may not be used for compounding in any circumstance.", "date": "2025-02-06", "source_url": "https://www.oregon.gov/pharmacy/Documents/OBOP_Semalgutide_Position_Statement_v.2-2025.pdf" }, "medical_board_peptides": { "summary": "The Oregon Medical Board's prescribing topics page carries the Board of Pharmacy's GLP-1 language (compounded versions sold online are not FDA approved; active ingredient must be pharmaceutical grade from an FDA-registered source) and relays the FDA's recommendation that consumers not buy unapproved products containing the investigational peptide retatrutide. No statement on BPC-157, research peptides generally or peptide clinics.", "date": "2025", "source_url": "https://www.oregon.gov/omb/topics-of-interest/pages/prescribing.aspx" }, "telehealth": { "summary": "Yes. The Oregon Medical Board's Statement of Philosophy on Telemedicine (last amended 4 April 2024) applies the same standard of care as in-person care and states that treatment based solely on an online questionnaire without individualised review and assessment does not constitute an acceptable standard of care; there is no in-person examination mandate for non-controlled drugs such as GLP-1s.", "source_url": "https://www.oregon.gov/omb/board/philosophy/pages/telemedicine.aspx" }, "enforcement": [ { "date": "2025-02-19", "summary": "Oregon's attorney general is on the signatory list of the 38-state letter urging the FDA to act against counterfeit and research-only GLP-1 sales.", "source_url": "https://www.naag.org/press-releases/state-and-territory-attorneys-general-urge-fda-to-take-action-against-counterfeit-and-illegally-sold-glp-1-drugs/" } ], "possession_note": { "text": "ORS 475.752(3) makes it unlawful to knowingly possess a controlled substance without a valid prescription, so possessing an unscheduled research peptide is not a state offence; the compounding and research-use-only restrictions in the Board's position statement bind pharmacies and sellers, not individual buyers.", "source_url": "https://oregon.public.law/statutes/ors_475.752" }, "confidence": "high", "notes": "No Oregon attorney general or board action against a specific peptide seller or medspa was found." }, { "state": "Pennsylvania", "abbr": "PA", "csa_citation": { "citation": "The Controlled Substance, Drug, Device and Cosmetic Act, 35 P.S. § 780-101 et seq.; schedules at 35 P.S. § 780-104", "source_url": "https://codes.findlaw.com/pa/title-35-ps-health-and-safety/pa-st-sect-35-780-104/" }, "hgh_scheduled": { "value": false, "citation": "35 P.S. § 780-104(3)(vii)", "source_url": "https://codes.findlaw.com/pa/title-35-ps-health-and-safety/pa-st-sect-35-780-104/", "note": "Pennsylvania expressly carves human growth hormone out of its Schedule III anabolic steroid listing (the section says HGH shall not be included as an anabolic steroid under the act), so HGH is a prescription drug but not a state controlled substance." }, "peptides_scheduled": [ { "name": "Chorionic gonadotropin (hCG), Schedule III", "citation": "35 P.S. § 780-104(3)(vii)(1), except approved veterinary use", "source_url": "https://codes.findlaw.com/pa/title-35-ps-health-and-safety/pa-st-sect-35-780-104/" } ], "pharmacy_board_glp1": null, "medical_board_peptides": null, "telehealth": { "summary": "Yes. The Department of State's telemedicine FAQs say nothing prohibits licensees from using telemedicine so long as it meets the prevailing standard of care. Board of Medicine rule 49 Pa. Code § 16.92(a)(1) requires an initial history and physical examination only before prescribing controlled substances, which GLP-1s are not; hCG is Schedule III in Pennsylvania, so that rule does apply to it. No questionnaire-only ban was found.", "source_url": "https://www.pa.gov/agencies/dos/resources/professional-licensing-resources/telemedicine-faqs" }, "enforcement": [ { "date": "2025-02-19", "summary": "Pennsylvania's attorney general is on the signatory list of the 38-state letter urging the FDA to act against counterfeit and research-only GLP-1 sales.", "source_url": "https://www.naag.org/press-releases/state-and-territory-attorneys-general-urge-fda-to-take-action-against-counterfeit-and-illegally-sold-glp-1-drugs/" }, { "date": "2025-05", "summary": "Attorney General Dave Sunday issued a consumer warning about counterfeit GLP-1 drugs with foreign contents, urging purchase only from licensed pharmacies and asking the FDA to step up enforcement. An advisory, not an enforcement action.", "source_url": "https://natlawreview.com/article/federal-and-state-agencies-ramp-scrutiny-glp-1-drug-market" } ], "possession_note": { "text": "35 P.S. § 780-113(a)(16) prohibits knowingly possessing a controlled substance without a valid prescription, so possessing an unscheduled research peptide is not a state offence; hCG is Schedule III in Pennsylvania and possessing it without a prescription is an offence under that subsection.", "source_url": "https://codes.findlaw.com/pa/title-35-ps-health-and-safety/pa-st-sect-35-780-113/" }, "confidence": "medium", "notes": "No Pennsylvania Board of Pharmacy or Board of Medicine statement on compounded GLP-1s or research peptides was found. The attorney general warning date is approximate." }, { "state": "Rhode Island", "abbr": "RI", "csa_citation": { "citation": "R.I. Gen. Laws Title 21, Chapter 21-28 (Uniform Controlled Substances Act); possession offences at § 21-28-4.01", "source_url": "https://web.archive.org/web/20241122001720id_/http://webserver.rilin.state.ri.us/Statutes/TITLE21/21-28/21-28-4.01.HTM" }, "hgh_scheduled": { "value": false, "citation": "P.L. 2024, ch. 390 (identical ch. 391), amending R.I. Gen. Laws § 21-28-2.01 and repealing §§ 21-28-2.08 to 2.10, effective 1 February 2025", "source_url": "https://web.archive.org/web/2025/https://webserver.rilegislature.gov/PublicLaws/law24/law24390.htm", "note": "Until 1 February 2025 Rhode Island's own Schedule III (former § 21-28-2.08) expressly listed human growth hormone and chorionic gonadotropin alongside anabolic steroids. P.L. 2024 ch. 390 repealed the state schedule text and made Rhode Island's controlled substances those in the current federal schedules (21 C.F.R.), which do not include HGH or hCG, plus any the Director of Health adds by rule; no such addition was found. Only the federal HGH statute applies now." }, "peptides_scheduled": [], "pharmacy_board_glp1": null, "medical_board_peptides": null, "telehealth": { "summary": "Yes. Board of Medical Licensure rule 216-RICR-40-05-1 § 1.5.9(H) holds telemedicine prescribing to the in-person standard and says treatment, including a prescription, based solely on an online questionnaire without an appropriate evaluation is not an acceptable standard of care and is unprofessional conduct; no in-person examination is required for non-controlled drugs such as semaglutide.", "source_url": "https://www.law.cornell.edu/regulations/rhode-island/216-RICR-40-05-1.5" }, "enforcement": [ { "date": "2025-02-19", "summary": "Attorney General Peter Neronha signed the 38-state letter urging the FDA to act against counterfeit GLP-1s and online sellers of research-purposes-only semaglutide and tirzepatide.", "source_url": "https://www.tn.gov/content/dam/tn/attorneygeneral/documents/pr/2025/2025-2-glp1-letter.pdf" } ], "possession_note": { "text": "Rhode Island has no offence for possessing a research peptide that is not a scheduled controlled substance; § 21-28-4.01(c)(1) makes it unlawful to knowingly possess a controlled substance without a valid prescription, and no general offence for possessing a non-controlled prescription drug was found.", "source_url": "https://web.archive.org/web/20241122001720id_/http://webserver.rilin.state.ri.us/Statutes/TITLE21/21-28/21-28-4.01.HTM" }, "confidence": "high", "notes": "The state legislature and health department sites were unreachable during this check, so the statute text comes from archived captures. No Board of Pharmacy or Board of Medical Licensure statement on compounded GLP-1s or peptides was found.", "verified": "2026-09-29" }, { "state": "South Carolina", "abbr": "SC", "csa_citation": { "citation": "S.C. Code Ann. § 44-53-110 et seq. (Narcotics and Controlled Substances Act); Schedule III at § 44-53-230; anabolic steroids separately in Article 14, §§ 44-53-1510 to 44-53-1530", "source_url": "https://www.scstatehouse.gov/code/t44c053.php" }, "hgh_scheduled": { "value": false, "citation": "S.C. Code Ann. § 44-53-230 and Article 14, § 44-53-1510 et seq.", "source_url": "https://www.scstatehouse.gov/code/t44c053.php", "note": "The full text of Title 44 Chapter 53 contains no reference to human growth hormone, somatropin or chorionic gonadotropin; the state's own anabolic-steroid article lists 16 named steroids only. The Department of Public Health can add substances by schedule notice and that page could not be opened, so a departmental addition cannot be fully excluded." }, "peptides_scheduled": [], "pharmacy_board_glp1": null, "medical_board_peptides": { "summary": "The Board of Medical Examiners posted a \"Notice Concerning the Prescribing of Non-FDA Approved (Research-Grade) Peptides\" as an alert on its home page in August 2026 (it appears on the page as captured on 15 August 2026). The notice itself could not be opened; a law-firm summary (LumaLex Law, 3 September 2026) reports that it bars licensees, and the APRNs and PAs they supervise, from prescribing, administering, dispensing or recommending research-grade peptides, in line with Alabama's and Mississippi's statements.", "date": "2026-08", "source_url": "https://web.archive.org/web/20260815042027/https://llr.sc.gov/med/" }, "telehealth": { "summary": "Yes. S.C. Code § 40-47-37(C) lets a physician establish the relationship and treat solely by telemedicine after an appropriate evaluation that need not be done in person, bars telemedicine prescribing when an in-person physical examination is necessary for diagnosis, and § 40-47-113(C) says prescribing to individuals the licensee has never personally examined based solely on answers to a set of questions is unprofessional. Non-controlled GLP-1s can be prescribed by telehealth after a real evaluation, not a questionnaire alone.", "source_url": "https://www.scstatehouse.gov/code/t40c047.php" }, "enforcement": [ { "date": "2025-01-03", "summary": "Attorney General Alan Wilson issued a consumer alert on unapproved and compounded tirzepatide and semaglutide, warning against sellers offering them without a prescription, in drops or nasal-spray forms, or as research-only products that people should never put into their bodies.", "source_url": "https://www.scag.gov/about-the-office/news/consumer-alert-attorney-general-alan-wilson-warns-consumers-to-be-cautious-when-purchasing-unapproved-and-compounded-weight-loss-medications/" }, { "date": "2025-02-19", "summary": "Attorney General Wilson co-led, with Tennessee, Colorado and Illinois, the 38-state letter urging the FDA to act against counterfeit GLP-1s and online retailers selling active ingredients for research purposes only.", "source_url": "https://www.scag.gov/about-the-office/news/attorney-general-alan-wilson-calls-for-action-against-counterfeit-weight-loss-drug-makers/" } ], "possession_note": { "text": "No South Carolina offence covers possession of an unscheduled research peptide; § 44-53-370(c) criminalises knowing possession of a controlled substance without a valid prescription, and § 44-53-1530 separately makes possession of anabolic steroids without a prescription unlawful, but neither reaches non-scheduled peptides.", "source_url": "https://www.scstatehouse.gov/code/t44c053.php" }, "confidence": "medium", "notes": "The Board of Pharmacy and Board of Medical Examiners sites refused connections, so an August 2025 Board of Pharmacy newsletter that surfaced in a GLP-1 compounding search could not be read; check it before stating the board has no position.", "verified": "2026-09-29" }, { "state": "South Dakota", "abbr": "SD", "csa_citation": { "citation": "S.D. Codified Laws ch. 34-20B (Drugs and Substances Control); schedules in §§ 34-20B-11 to 34-20B-26; possession offence at SDCL § 22-42-5", "source_url": "https://sdlegislature.gov/api/Statutes/34-20B-3.html" }, "hgh_scheduled": { "value": false, "citation": "SDCL § 34-20B-22(3) and § 34-20B-4.1", "source_url": "https://sdlegislature.gov/api/Statutes/34-20B-22.html", "note": "South Dakota's Schedule III lists a few named drugs and the anabolic steroids defined in § 34-20B-4.1 (80 named steroids); neither section mentions human growth hormone, somatropin or chorionic gonadotropin, so HGH is governed only by federal law." }, "peptides_scheduled": [], "pharmacy_board_glp1": { "summary": "The Board of Pharmacy's January 2024 newsletter told licensees that 503A and 503B pharmacies may compound shortage-list GLP-1s only if the active ingredient is not a salt or other form of the drug (semaglutide may only be compounded with semaglutide base), noted that most spas and wellness centres dispense non-FDA-approved compounded product, reported one South Dakota adverse event from a tenfold dosing error, and flagged counterfeit semaglutide reports.", "date": "2024-01", "source_url": "https://doh.sd.gov/media/5urllipf/january-2024-south-dakota-state-news.pdf" }, "medical_board_peptides": null, "telehealth": { "summary": "Yes. SDCL § 34-52-3 requires a proper provider-patient relationship via telehealth, with identity verification, consent, a diagnosis through acceptable medical practice including history and examination, and follow-up; § 34-52-5 requires an appropriate face-to-face examination using real-time audio and visual technology before diagnosis and treatment whenever an in-person encounter would otherwise be required. There is no in-person visit requirement for non-controlled drugs such as semaglutide, but a questionnaire-only model would not meet the statute.", "source_url": "https://sdlegislature.gov/api/Statutes/34-52-3.html" }, "enforcement": [], "possession_note": { "text": "South Dakota has no offence for possessing an unscheduled research peptide; SDCL § 22-42-5 makes knowing possession of a controlled substance without a valid prescription a felony, which reaches anabolic steroids but not peptides such as BPC-157 or semaglutide.", "source_url": "https://sdlegislature.gov/api/Statutes/22-42-5.html" }, "confidence": "high", "notes": "South Dakota did not sign the February 2025 multistate letter, and no state attorney general or board enforcement action on peptides or compounded GLP-1s was found." }, { "state": "Tennessee", "abbr": "TN", "csa_citation": { "citation": "Tenn. Code Ann. § 39-17-401 et seq. (Tennessee Drug Control Act); Schedule III at § 39-17-410 and Tenn. Comp. R. & Regs. 0940-06-01-.03; simple possession at § 39-17-418", "source_url": "https://www.law.cornell.edu/regulations/tennessee/Tenn-Comp-R-Regs-0940-06-01-.03" }, "hgh_scheduled": { "value": false, "citation": "Tenn. Code Ann. § 39-17-410(f); Tenn. Comp. R. & Regs. 0940-06-01-.03(6)", "source_url": "https://www.law.cornell.edu/regulations/tennessee/Tenn-Comp-R-Regs-0940-06-01-.03", "note": "Tennessee's Schedule III lists anabolic steroids mirroring the federal list; neither the statute nor the current regulation mentions human growth hormone, somatropin or chorionic gonadotropin, so HGH is restricted only by federal law in Tennessee." }, "peptides_scheduled": [], "pharmacy_board_glp1": null, "medical_board_peptides": null, "telehealth": { "summary": "Yes. Tenn. Code Ann. § 63-1-155 holds telehealth providers to the same standard as in-person care and lets the provider-patient relationship form without an in-person visit; the Board of Medical Examiners' telemedicine FAQ confirms this, while Rule 0880-02-.14 still requires an appropriate history and physical examination, diagnosis and plan before prescribing any drug by any means. Chronic pain management by telehealth is prohibited; no questionnaire-specific ban was located.", "source_url": "https://www.tn.gov/content/dam/tn/health/documents/Telemedicine_FAQs.pdf" }, "enforcement": [ { "date": "2025-02-20", "summary": "Attorney General Jonathan Skrmetti led the 38-state letter urging the FDA to act against counterfeit GLP-1s and online retailers selling semaglutide and tirzepatide for research purposes only or not for human consumption.", "source_url": "https://www.tn.gov/attorneygeneral/news/2025/2/20/pr25-9.html" }, { "date": "2025-02", "summary": "The attorney general's Consumer Protection Division published a warning listing red flags for buying semaglutide or tirzepatide from medspas, wellness centres or online sellers, including research-grade product, sale without a prescription and being encouraged to reconstitute powders.", "source_url": "https://www.tn.gov/content/dam/tn/attorneygeneral/documents/pr/2025/CPD_GLP1_Warning.pdf" }, { "date": "2026-09-23", "summary": "Attorney General Skrmetti joined a 20-state letter to the Secretary of State warning that Chinese companies which manufacture fentanyl precursors are now selling weight-loss and other peptides and that mislabelled GLP-1 injections are being imported.", "source_url": "https://www.tn.gov/attorneygeneral/news/2026/9/23/pr26-38.html" } ], "possession_note": { "text": "Tennessee has no offence for possessing an unscheduled research peptide; § 39-17-418(a) makes it a Class A misdemeanor to knowingly possess a controlled substance without a valid prescription, which covers anabolic steroids and other scheduled drugs but not peptides such as BPC-157 or semaglutide.", "source_url": "https://web.archive.org/web/20250721185844id_/https://law.justia.com/codes/tennessee/title-39/chapter-17/part-4/section-39-17-418/" }, "confidence": "medium", "notes": "No Tennessee Board of Pharmacy or Board of Medical Examiners statement specific to compounded GLP-1s or research peptides was found; the attorney general's actions are letters and consumer warnings, not lawsuits against a named Tennessee seller." }, { "state": "Texas", "abbr": "TX", "csa_citation": { "citation": "Texas Controlled Substances Act, Tex. Health & Safety Code ch. 481", "source_url": "https://tcss.legis.texas.gov/resources/HS/htm/HS.481.htm" }, "hgh_scheduled": { "value": false, "citation": "Texas Schedules of Controlled Substances (health commissioner, 2023 and 2025 republications), Schedule III anabolic steroids and hormones; Tex. Health & Safety Code § 481.071(b) and (c)", "source_url": "https://www.dshs.texas.gov/sites/default/files/drugs/PDF/controlled%20substances/Republication%202023%20Final.pdf", "note": "Section 481.071 limits prescribing an anabolic steroid or human growth hormone \"listed in Schedule III\" to a valid medical purpose and says bodybuilding in a healthy person is not one, but the Schedule III the health commissioner publishes lists testosterone-related anabolic steroids only, with no human growth hormone, somatropin or hCG. HGH is therefore not a Texas controlled substance and is in no penalty group; in Texas it is restricted through the federal statute (21 U.S.C. § 333(e)) and its prescription-only status." }, "peptides_scheduled": [], "pharmacy_board_glp1": null, "medical_board_peptides": null, "telehealth": { "summary": "Yes. Tex. Occ. Code § 111.005 recognises a valid practitioner-patient relationship for telemedicine prescribing when the practitioner uses synchronous audiovisual interaction, store-and-forward technology with images or clinical records, or other audiovisual technology that meets the standard of care, with follow-up guidance. There is no statutory in-person examination requirement; a bare questionnaire does not satisfy the section.", "source_url": "https://statutes.capitol.texas.gov/Docs/OC/htm/OC.111.htm" }, "enforcement": [ { "date": "2026-08-12", "summary": "Eli Lilly filed six federal lawsuits over retatrutide sales, five of them against Texas sellers: Astra Peptides, Legendary Peptides, Striker Pharmacy, Texas Peptides and Lone Star Peptide. Private litigation by the manufacturer, not a state action.", "source_url": "https://www.healio.com/news/endocrinology/20260814/eli-lilly-files-lawsuits-against-six-companies-for-allegedly-selling-retatrutide" }, { "date": "2026-08-24", "summary": "The FDA's 24 August 2026 warning letters to online peptide sellers included TXP Innovations LLC, trading as Tex Peptides of Dallas, for marketing semaglutide, tirzepatide, retatrutide and other peptides as unapproved new drugs; and its 18 September 2026 letter went to Empower Pharmacy of Houston over compounded semaglutide and tirzepatide. Federal actions against Texas businesses.", "source_url": "https://peptidebureau.com/peptide-enforcement-tracker.html" } ], "possession_note": { "text": "Possessing human growth hormone or an unscheduled research peptide such as BPC-157 is not a Texas Controlled Substances Act offence: possession offences attach to penalty-group substances and, under § 481.119(b), to substances the commissioner has scheduled but not penalty-grouped, and neither HGH nor any research peptide is on those lists.", "source_url": "https://tcss.legis.texas.gov/resources/HS/htm/HS.481.htm" }, "confidence": "high", "notes": "Texas is not among the signatories of the February 2025 multistate letter to the FDA. No Texas State Board of Pharmacy or Texas Medical Board statement on compounded GLP-1s or peptides, and no Texas attorney general action against GLP-1 or peptide sellers, was found within the search budget.", "verified": "2026-09-29" }, { "state": "Utah", "abbr": "UT", "csa_citation": { "citation": "Utah Controlled Substances Act, Utah Code Title 58, Chapter 37; schedules at Utah Code 58-37-108 (formerly 58-37-4, recodified 6 May 2026)", "source_url": "https://le.utah.gov/xcode/Title58/Chapter37/C58-37-S108_2026050620260506.html" }, "hgh_scheduled": { "value": false, "citation": "Utah Code 58-37-108(2)(c), Schedule III", "source_url": "https://le.utah.gov/xcode/Title58/Chapter37/C58-37-S108_2026050620260506.html", "note": "Growth hormone, somatropin and gonadotropin do not appear anywhere in Utah's schedules; Schedule III lists 27 named anabolic steroids. Utah also treats anything on the federal schedules as controlled, and HGH is not on those either, so only the federal HGH statute applies." }, "peptides_scheduled": [], "pharmacy_board_glp1": { "summary": "The Utah Board of Pharmacy newsletter of May 2024 reported that the Division of Professional Licensing had issued citations for medspas dispensing compounded semaglutide in individual syringes, for dispensing practitioners acting out of scope, for compounding with semaglutide salts (not allowed by the FDA) and for 503A pharmacies compounding for office use, which requires a 503B outsourcing facility. It stated that compounding was legal only while the approved drugs were on the FDA shortage list. The May 2025 newsletter added no new rule.", "date": "2024-05", "source_url": "https://nabp.pharmacy/wp-content/uploads/2024/05/May-2024-Utah-State-Newsletter.pdf" }, "medical_board_peptides": null, "telehealth": { "summary": "Under the Utah Telehealth Act (Utah Code 26B-4-704) a telehealth provider is held to the same standards as in-person care, must establish a provider-patient relationship during the encounter, and must establish a diagnosis and identify contraindications from a documented clinical history before prescribing. There is no statutory in-person examination requirement, but a prescription based solely on an online questionnaire does not meet the standard. GLP-1 pens are prescribable by a Utah-licensed telehealth prescriber on that basis.", "source_url": "https://le.utah.gov/xcode/Title26B/Chapter4/C26B-4-S704_2023050320230503.html" }, "enforcement": [ { "date": "2026-04-01", "summary": "A federal grand jury indicted Justin Bradley Watkins, a licensed osteopathic physician of Pleasant View, for receiving and selling misbranded drugs: peptides bought from China between February 2024 and April 2025, including tirzepatide, semaglutide, retatrutide, cagrilintide, BPC-157, TB-500, ipamorelin, CJC-1295, GHK-Cu and NAD+, relabelled and sold to more than 200 patients. The case was investigated by FDA criminal investigators together with Utah's Division of Professional Licensing. An indictment is an allegation.", "source_url": "https://www.justice.gov/usao-ut/pr/utah-licensed-osteopathic-physician-indicted-allegedly-receiving-misbranded-drugs-china" }, { "date": "2025-02-19", "summary": "Utah's attorney general joined the multistate letter urging the FDA to act against counterfeit and illegally sold GLP-1 drugs and the compounding pharmacies supplying that market.", "source_url": "https://www.naag.org/press-releases/state-and-territory-attorneys-general-urge-fda-to-take-action-against-counterfeit-and-illegally-sold-glp-1-drugs/" }, { "date": "2024-05", "summary": "The Division of Professional Licensing issued citations (no names published) for medspas dispensing compounded semaglutide, out-of-scope dispensing, semaglutide salt compounding and 503A office-use compounding, per the Board of Pharmacy newsletter.", "source_url": "https://nabp.pharmacy/wp-content/uploads/2024/05/May-2024-Utah-State-Newsletter.pdf" } ], "possession_note": { "text": "No Utah provision on research peptides or HGH was found; unless a substance is in Utah's schedules or the federal schedules, Utah's possession offences do not reach it and the federal FDCA rules, which fall on the seller, apply.", "source_url": "https://le.utah.gov/xcode/Title58/Chapter37/C58-37-S108_2026050620260506.html" }, "confidence": "high", "notes": "The controlled-substances chapter was renumbered in 2026 (58-37-4 became 58-37-108); older sources cite the old number. Utah is the one state so far where a peptide-prescribing physician faces federal charges brought with the state licensing division's help." }, { "state": "Vermont", "abbr": "VT", "csa_citation": { "citation": "18 V.S.A. chapter 84, Possession and Control of Regulated Drugs (18 V.S.A. § 4201 et seq.); specific substances designated by the Department of Health's Regulated Drug Rule under § 4202", "source_url": "https://legislature.vermont.gov/statutes/fullchapter/18/084" }, "hgh_scheduled": { "value": false, "citation": "18 V.S.A. § 4201; Vermont Regulated Drug Rule", "source_url": "https://www.healthvermont.gov/sites/default/files/document/reg-regulated-drugs.pdf", "note": "Vermont does not use Schedules I to V. Its Regulated Drug Rule lists stimulant, depressant, narcotic and hallucinogenic drugs; the full text contains no growth hormone, somatropin, anabolic steroid or peptide entry. The 2019 version of the rule was the latest the Bureau could open." }, "peptides_scheduled": [], "pharmacy_board_glp1": null, "medical_board_peptides": { "summary": "A joint statement from the Office of Professional Regulation and the Boards of Medical Practice, Nursing, Osteopathic Medicine and Pharmacy (approved 5 June 2024) says Vermont has no laws specific to IV therapy clinics and medical spas, that prescribing or administering drugs is the practice of medicine, that only MDs, DOs, PAs, APRNs and endorsed NDs may prescribe, that a valid prescription needs a practitioner-patient relationship, evaluation, diagnosis and documentation, that standing orders from a medical director are not valid prescriptions, and that compounding can never take place under a standing order because a compounding prescription must name an individual patient. Weight loss is named as a marketed medspa use. It does not mention peptides by name.", "date": "2024-06-05", "source_url": "https://www.healthvermont.gov/sites/default/files/document/bmp-joint-statement-regarding-IV-therapy-clinics-2024-06-05-approvedbyBMPBOMBOPBON%20%2812%29_0.pdf" }, "telehealth": { "summary": "18 V.S.A. § 9361 holds telemedicine treatment and prescribing to the same standard as in-person care and allows treatment after an appropriate examination in person, by telemedicine or by transmitted diagnostic equipment; there is no in-person examination prerequisite. Out-of-state prescribers use the Office of Professional Regulation's telehealth registration, which proposed rules would cap at a small number of Vermont patients per period. GLP-1 pens are prescribable by telehealth on that basis.", "source_url": "https://legislature.vermont.gov/statutes/section/18/219/09361" }, "enforcement": [ { "date": "2025-02-19", "summary": "Vermont's attorney general joined the multistate letter urging the FDA to increase enforcement against counterfeit and illegally sold GLP-1 drugs. No Vermont-specific action involving peptides or GLP-1 sellers was found.", "source_url": "https://www.naag.org/press-releases/state-and-territory-attorneys-general-urge-fda-to-take-action-against-counterfeit-and-illegally-sold-glp-1-drugs/" } ], "possession_note": { "text": "HGH and research peptides are not regulated drugs under 18 V.S.A. § 4201 or the Regulated Drug Rule, so Vermont's chapter 84 possession offences do not apply and the federal rules govern.", "source_url": "https://legislature.vermont.gov/statutes/section/18/084/04201" }, "confidence": "medium", "notes": "The Board of Pharmacy's compounding rules could not be opened during this check, so no statement on compounded semaglutide is recorded; that is an absence of a located statement, not a finding that none exists." }, { "state": "Virginia", "abbr": "VA", "csa_citation": { "citation": "Virginia Drug Control Act, Va. Code Title 54.1, Ch. 34 (§ 54.1-3400 et seq.); controlled substance schedules in Article 5 (§§ 54.1-3443 to 54.1-3456.1); Schedule III at § 54.1-3450", "source_url": "https://law.lis.virginia.gov/vacode/title54.1/chapter34/section54.1-3450/" }, "hgh_scheduled": { "value": false, "citation": "Va. Code § 54.1-3450 (Schedule III) and Article 5 generally; § 18.2-248.5", "source_url": "https://law.lis.virginia.gov/vacodefull/title54.1/chapter34/article5/", "note": "The full text of § 54.1-3450 and the rest of Article 5 (Schedules I to VI) contains no mention of growth hormone, somatropin or any peptide; subsection 6 covers anabolic steroids only, and § 18.2-248.5 criminalises anabolic steroids and caffeine or ephedrine combinations without mentioning HGH. HGH is not a Virginia-scheduled substance; the federal statute applies." }, "peptides_scheduled": [], "pharmacy_board_glp1": { "summary": "No Virginia Board of Pharmacy guidance specific to semaglutide, tirzepatide or peptides. The Board's compounding guidance (document 110-36, effective 6 June 2024) requires compliance with USP 795, 797 and 800, allows only nonresident pharmacies and outsourcing facilities registered with the Virginia Board to ship compounded sterile products into Virginia, and limits distribution of compounded products to prescribers to emergency use or as federal law allows. It does not mention semaglutide, GLP-1s or 503A copies.", "date": "2024-06-06", "source_url": "https://www.dhp.virginia.gov/media/dhpweb/docs/pharmacy/guidance/110-36.pdf" }, "medical_board_peptides": null, "telehealth": { "summary": "Va. Code § 54.1-3303 requires a bona fide practitioner-patient relationship before any prescription: a medical history, a discussion of benefits and risks, an appropriate examination (in person or by diagnostic equipment) and follow-up. The relationship may be established by telemedicine when those conditions are met and the prescriber holds a Virginia licence. Board of Medicine guidance 85-12 adds that a prescription based solely on an online questionnaire does not meet the standard of care. GLP-1 pens are prescribable by a Virginia-licensed telehealth prescriber on that basis.", "source_url": "https://law.lis.virginia.gov/vacode/title54.1/chapter33/section54.1-3303/" }, "enforcement": [ { "date": "2025-02-19", "summary": "Virginia Attorney General Jason Miyares signed the bipartisan letter of 38 state and territory attorneys general urging the FDA to act against counterfeit GLP-1 drugs and against online sellers offering semaglutide and tirzepatide labelled for research purposes only. No Virginia-specific enforcement action on peptides or GLP-1s was found.", "source_url": "https://www.naag.org/press-releases/state-and-territory-attorneys-general-urge-fda-to-take-action-against-counterfeit-and-illegally-sold-glp-1-drugs/" } ], "possession_note": { "text": "Virginia has no possession provision specific to HGH or research peptides because neither is on the state schedules; simple possession of a Schedule III substance such as an anabolic steroid is a Class 1 misdemeanor under Va. Code § 18.2-250, and otherwise the federal rules apply.", "source_url": "https://law.lis.virginia.gov/vacode/title18.2/chapter7/section18.2-250/" }, "confidence": "medium", "notes": "A 2026 session bill, HB917, appeared in search results as adding restrictions on bulk drug substances in compounding (withdrawn drugs, unapproved substances, essentially copies of commercial drugs); its text and status could not be opened and are unverified. No Board of Medicine statement on peptides or BPC-157 was found." }, { "state": "Washington", "abbr": "WA", "csa_citation": { "citation": "Uniform Controlled Substances Act, RCW 69.50; Schedule III at RCW 69.50.208, supplemented by Pharmacy Quality Assurance Commission rule WAC 246-945-054", "source_url": "https://app.leg.wa.gov/RCW/default.aspx?cite=69.50.208" }, "hgh_scheduled": { "value": false, "citation": "RCW 69.50.208 and WAC 246-945-054 (Schedule III); see also WAC 246-853-220", "source_url": "https://app.leg.wa.gov/wac/default.aspx?cite=246-945-054", "note": "Neither RCW 69.50.208 nor WAC 246-945-054 mentions growth hormone, somatropin or any peptide; both list anabolic steroids only. Separately, WAC 246-853-220 (a Board of Osteopathic Medicine rule) prohibits an osteopathic physician from prescribing anabolic steroids, growth hormones, testosterone, HCG or other hormones to enhance athletic ability or for nontherapeutic cosmetic purposes. That is a prescriber-conduct rule, not scheduling." }, "peptides_scheduled": [], "pharmacy_board_glp1": { "summary": "The Pharmacy Quality Assurance Commission's Statement on Compounding Semaglutide (approved 22 August 2024) says semaglutide may be compounded only when the drug is discontinued, on the FDA shortage list, or a specific patient's needs cannot be met by the commercial product; that salt forms are different active ingredients that do not meet FD&C Act requirements and may not be used; that any semaglutide base must be pharmaceutical grade (not research use only), with a valid certificate of analysis, from an FDA-registered and Washington-licensed source; and that non-compliance may bring disciplinary or enforcement action. A 28 March 2025 reminder extended the statement to all GLP-1s and noted the end of FDA enforcement discretion for tirzepatide and semaglutide compounding.", "date": "2024-08-27", "source_url": "https://content.govdelivery.com/accounts/WADOH/bulletins/3b13be6" }, "medical_board_peptides": { "summary": "The Washington Medical Commission's Statement of Compounding Semaglutide (22 August 2024) mirrors the pharmacy commission: compounding only under the shortage, discontinued or patient-specific exceptions; no salt form of semaglutide may be used because semaglutide is not on the FDA bulks list; the active ingredient must be pharmaceutical grade rather than research-use, with a certificate of analysis from FDA-registered and Washington-licensed sources. It also warns patients that these medications are legitimately available by prescription only. No commission statement on BPC-157 or peptide therapy generally was found.", "date": "2024-08-22", "source_url": "https://wmc.wa.gov/news/statement-compounding-semaglutide" }, "telehealth": { "summary": "Washington's Uniform Telehealth Act, chapter 18.134 RCW (effective 12 June 2024), holds a telehealth practitioner to the same professional standards as comparable in-person care, expressly including the standards and law on prescribing (RCW 18.134.040). There is no explicit in-person examination prerequisite for prescribing non-controlled drugs such as GLP-1s. The Medical Commission's telemedicine policy applies the same standard of care and ethics as in-person care.", "source_url": "https://app.leg.wa.gov/rcw/default.aspx?cite=18.134&full=true" }, "enforcement": [ { "date": "2025-03-13", "summary": "The Pharmacy Quality Assurance Commission issued an immediate Limited Stop Service order against Aequita Pharmacy LLC of Kirkland, a compounder of GLP-1s including semaglutide and tirzepatide, barring it from compounding and dispensing in Washington for letting untrained staff perform sterile compounding, failing to supervise, not following sterile procedures and failing to implement an approved corrective action plan.", "source_url": "https://doh.wa.gov/newsroom/pharmacy-quality-assurance-commission-issues-limited-stop-service-license-pharmacy" } ], "possession_note": { "text": "No Washington provision specific to HGH or research peptides was found because neither is on the state schedules; knowing possession of a scheduled controlled substance without a valid prescription is a gross misdemeanor under RCW 69.50.4013, and otherwise the federal rules apply.", "source_url": "https://app.leg.wa.gov/RCW/default.aspx?cite=69.50.4013" }, "confidence": "medium", "notes": "Washington's attorney general did not sign the February 2025 38-state letter to the FDA on GLP-1 sales, and no Washington AG action on peptides was found. Pending: HB 2613 (2026), establishing safety and regulatory requirements for compounded medications, was still in the House Health Care and Wellness committee on 28 September 2026; its GLP-1 or peptide content is unverified." }, { "state": "West Virginia", "abbr": "WV", "csa_citation": { "citation": "West Virginia Uniform Controlled Substances Act, W. Va. Code ch. 60A (§ 60A-1-101 et seq.)", "source_url": "https://code.wvlegislature.gov/60A-1-101/" }, "hgh_scheduled": { "value": true, "citation": "W. Va. Code § 60A-2-208(g)", "source_url": "https://code.wvlegislature.gov/60A-2-208/", "note": "West Virginia's own Schedule III lists human growth hormones at § 60A-2-208(g), directly after anabolic steroids, so HGH is a state Schedule III controlled substance, which goes beyond federal law." }, "peptides_scheduled": [ { "name": "Human growth hormone, Schedule III", "citation": "W. Va. Code § 60A-2-208(g)", "source_url": "https://code.wvlegislature.gov/60A-2-208/" }, { "name": "Human chorionic gonadotropin (hCG), Schedule III", "citation": "W. Va. Code § 60A-2-208(i), except approved veterinary use", "source_url": "https://code.wvlegislature.gov/60A-2-208/" } ], "pharmacy_board_glp1": { "summary": "The Board of Pharmacy's Statement Concerning Semaglutide Compounding (April 2023, updated 1 May 2023) says compounding semaglutide is generally prohibited as a copy of a commercially available drug and allowed only while the drug is on the FDA shortage list or with a documented patient-specific change; that no salt form of semaglutide (sodium or acetate) may be used because only the base is a component of an approved drug and semaglutide is not on the 503A bulks list; that the active ingredient must be pharmaceutical grade from an FDA-registered establishment; and that research-use-only products may not be used for compounding in any circumstance.", "date": "2023-05-01", "source_url": "https://www.wvbop.com/admin/attachment/FINALSemaglutideCompoundingStatementUpdated01MAY2023WVBoPFV1.pdf" }, "medical_board_peptides": null, "telehealth": { "summary": "Yes, by real-time audio-video or audio-only telemedicine. W. Va. Code § 30-3-13a bars establishing the physician-patient relationship through email, internet questionnaires or text, says a prescription based solely on an online questionnaire is not an acceptable standard of care, and requires an in-person visit with a practitioner within twelve months of the first telemedicine service for the service to continue.", "source_url": "https://code.wvlegislature.gov/30-3-13A/" }, "enforcement": [ { "date": "2025-02-19", "summary": "Attorney General JB McCuskey joined the multistate letter urging the FDA to act against counterfeit GLP-1s and online sellers of research-purposes-only GLP-1 active ingredients.", "source_url": "https://ago.wv.gov/article/attorney-general-mccuskey-calls-action-against-counterfeit-weight-loss-drug-makers" } ], "possession_note": { "text": "Possessing an unscheduled research peptide is not an offence under West Virginia's controlled substances act, but HGH and hCG are state Schedule III substances, and knowing possession of any controlled substance without a valid prescription is a misdemeanor under W. Va. Code § 60A-4-401(c).", "source_url": "https://code.wvlegislature.gov/60A-4-401/" }, "confidence": "high", "notes": "The Board of Pharmacy site was unreachable directly, so its statement was read from an archived copy. No Board of Medicine statement on peptides or medspas and no disciplinary action tied to GLP-1s or peptides was found." }, { "state": "Wisconsin", "abbr": "WI", "csa_citation": { "citation": "Wisconsin Uniform Controlled Substances Act, Wis. Stat. ch. 961", "source_url": "https://docs.legis.wisconsin.gov/statutes/statutes/961/II/18" }, "hgh_scheduled": { "value": false, "citation": "Wis. Stat. § 961.18 (Schedule III), anabolic steroids at § 961.18(7)", "source_url": "https://docs.legis.wisconsin.gov/statutes/statutes/961/II/18", "note": "Wisconsin's Schedule III lists anabolic steroids but contains no entry for human growth hormone, somatropin or chorionic gonadotropin, so HGH is governed by the federal rules only." }, "peptides_scheduled": [], "pharmacy_board_glp1": null, "medical_board_peptides": null, "telehealth": { "summary": "Yes. Under Medical Examining Board rule Med 24.07 a physician may prescribe to a Wisconsin patient over the internet only if Wisconsin-licensed, identified to the patient, with informed consent, a documented evaluation and a health care record; the rule states that a prescription based only on a static electronic questionnaire does not meet the standard of minimally competent practice. There is no in-person examination requirement.", "source_url": "https://docs.legis.wisconsin.gov/code/admin_code/med/24/07" }, "enforcement": [ { "date": "2025-02-19", "summary": "Wisconsin is among the signatories of the multistate letter urging the FDA to act against counterfeit GLP-1s and research-purposes-only online sellers.", "source_url": "https://www.naag.org/press-releases/state-and-territory-attorneys-general-urge-fda-to-take-action-against-counterfeit-and-illegally-sold-glp-1-drugs/" } ], "possession_note": { "text": "Because no research peptide, HGH or hCG appears in Wisconsin's schedules, possessing unscheduled peptides is not a chapter 961 controlled-substance offence; Wisconsin's separate prescription-drug rule in Wis. Stat. § 450.11 was not verified in this check.", "source_url": "https://docs.legis.wisconsin.gov/statutes/statutes/961/II/18" }, "confidence": "medium", "notes": "The Pharmacy Examining Board scheduled guidance on compounding pharmacies and semaglutide and tirzepatide production for its 18 December 2025 meeting, but the packet could not be opened, so any Wisconsin GLP-1 compounding guidance is unverified." }, { "state": "Wyoming", "abbr": "WY", "csa_citation": { "citation": "Wyoming Controlled Substances Act of 1971, Wyo. Stat. § 35-7-1001 et seq.", "source_url": "https://wyoleg.gov/statutes/compress/title35.pdf" }, "hgh_scheduled": { "value": false, "citation": "Wyo. Stat. § 35-7-1018 (Schedule III), anabolic steroids at § 35-7-1018(g)", "source_url": "https://wyoleg.gov/statutes/compress/title35.pdf", "note": "The full Title 35 text contains no reference to human growth hormone, somatropin or chorionic gonadotropin; Schedule III covers anabolic steroids only. No state restriction on HGH beyond federal law was found." }, "peptides_scheduled": [], "pharmacy_board_glp1": null, "medical_board_peptides": null, "telehealth": { "summary": "Yes. Wyoming Board of Medicine rules allow the physician-patient relationship to be established by telemedicine under in-person standards of care; the only internet-prescribing prohibition in statute, Wyo. Stat. § 33-26-402(a)(xxxiii), covers initially prescribing a controlled substance over the internet without a documented relationship, which does not reach non-controlled GLP-1s. No questionnaire ban or in-person exam rule for non-controlled drugs was found.", "source_url": "https://www.cchpca.org/wyoming/?category=professional-requirements&topic=online-prescribing" }, "enforcement": [], "possession_note": { "text": "Possessing an unscheduled research peptide is not an offence under the Wyoming Controlled Substances Act; knowing possession of a scheduled substance without a valid prescription is an offence under Wyo. Stat. § 35-7-1031(c).", "source_url": "https://wyoleg.gov/statutes/compress/title35.pdf" }, "confidence": "medium", "notes": "Wyoming is not on the February 2025 multistate letter, and no Wyoming attorney general, Board of Pharmacy or Board of Medicine statement or action on compounded GLP-1s, peptides or medspas was found. The telehealth summary rests on a secondary policy compilation." } ] }