Explainer
What do FDA's compounding categories 1, 2 and 3 mean?
Short answer · as of 2026-10-05
FDA sorted bulk drug substances nominated for compounding into three interim categories while it decides whether to list them. Category 1: nominated with enough information and may be eligible, with enforcement discretion under conditions. Category 2: FDA identified significant safety risks and says it would consider taking action. Category 3: nominated without enough information for FDA to evaluate. As of Jan. 7, 2025, FDA no longer places newly nominated substances in these categories.
By Peptide Industry Gossip · Published · General explanation, not legal or medical advice. Disclaimer.
Category 1
Substances nominated with sufficient supporting information that may be eligible for the list and do not appear on another list. FDA says it does not intend to take action against compounders using them, provided specified conditions are met. FDA's 503B page adds that no safety concerns have been identified for them.
Category 2
Substances where FDA identified significant safety risks in using them for compounding. FDA's 503A page says it would consider taking action against a compounder who uses them. The 503B page says Category 1 protections do not extend to them and that FDA may enforce.
Category 3
Substances nominated without enough supporting information for FDA to evaluate them. They do not get Category 1 protections. FDA's 503B page says compounders must re-nominate with complete data.
What changed in 2025, and what “withdrawn” means
FDA's 503A page says the interim categories remain in effect, and that as of Jan. 7, 2025 the agency does not intend to place substances nominated on or after that date into them.
FDA's page on substances that may present significant safety risks has a table headed “bulk drug substances nominated but withdrawn.” BPC-157 and six other peptides are listed there with FDA's safety concerns. We did not find FDA's own definition of that heading on the pages we read, so we do not say what it means for current status.
What a category does not mean
- A category describes FDA's enforcement stance toward compounding under its interim policy. It is not a ruling on any one product.
- Categories sort nominated substances. They are not approvals, and FDA says compounded drugs are not FDA-approved.
- There are separate versions for 503A pharmacies and 503B outsourcing facilities. See our comparison.
Sources
- FDA, Bulk Drug Substances Used in Compounding Under Section 503A of the FD&C Act (updated May 14, 2026) · captured 2026-10-05 · tier 1
- FDA, Bulk Drug Substances Used in Compounding Under Section 503B of the FD&C Act (updated Jan. 7, 2025) · captured 2026-10-05 · tier 1
- FDA, Certain Bulk Drug Substances for Use in Compounding that May Present Significant Safety Risks (updated Apr. 22, 2026) · captured 2026-10-05 · tier 1
Quotes are from the FDA documents above, retrieved Oct. 5, 2026. FDA can revise those pages. See something wrong? Request a correction.