FDA and state rules, for what you actually buy.
Search a drug, ingredient or device for its live FDA record, or pick your state and a category to see the federal rules and what your state adds — each answer with its citation and source.


503A compounded (patient-specific)
FDA pathway: Compounded 503A
Lawful federally only as patient-specific compounding by a state-licensed pharmacist or physician using eligible bulk ingredients; not FDA-approved; no federal office-use stock.
On MedGrid as: Other Prescriptions
The federal rules
Patient-specific prescription; limited anticipatory compounding503A compounding must be for an identified patient on a valid prescription; compounding ahead is limited to about a 30-day supply based on the compounder's own prescription history.
FDA's final guidance (Dec 2016) says a 503A compounder may hold no more than a 30-day supply of a compounded drug to fill valid prescriptions it has not yet received, sized from the most prescriptions it received in a 30-day period over the past year. Office stock for administering to walk-in patients is directed to 503B outsourcing facilities.
- Prescription Requirement Under Section 503A of the FD&C Act — Guidance for Industry — FDA/CDER, 2016-12-01
Eligible bulk ingredients onlyThe active ingredient must have a USP/NF monograph, be a component of an FDA-approved drug, or be on the 503A bulks list; FDA currently tolerates 'Category 1' substances pending review.
FDA's category list (updated May 14, 2026) sorts nominated substances: Category 1 (under evaluation; FDA does not intend to act if conditions are met), Category 2 (significant safety risks; FDA may act), Category 3 (nominated without adequate support). Substances in no category and not otherwise eligible do not get enforcement discretion.
No copies of commercially available drugs without a documented significant differenceSame API, similar strength and usable route as a marketed drug is 'essentially a copy' unless the prescriber documents a patient-specific significant difference; more than four such prescriptions a month counts as 'regularly'.
A drug that is discontinued or in 'currently in shortage' status is not commercially available. Price is not a significant difference. The prescription must state the change and the resulting difference for that patient.
Biologics are outside 503ALicensed biologics (e.g., hCG, hyaluronidase, somatropin, tesamorelin) cannot be compounded under 503A.
Since March 23, 2020, products that transitioned to BLAs are 'not eligible for the exemptions for compounded drugs under sections 503A and 503B'.
Interstate shipping: 5% limit not enforced; MOU suspendedFDA is not enforcing the 5% out-of-state limit while it writes a new rule; state nonresident-pharmacy licensing still controls who may ship into a state.
The October 2020 standard MOU is suspended after a 2021 court remand. FDA's Fall 2025 agenda projects a proposed rule in November 2026.
- Memorandum of Understanding Addressing Certain Distributions of Compounded Drugs — FDA, 2022-10-20
- Unified Agenda, RIN 0910-AI71 (Fall 2025) — OMB/OIRA, 2025-10-01
Quality of ingredients and FDA risk alertsFDA holds compounders responsible for using ingredients suitable for the route; in Aug 2026 it warned against dietary-supplement-grade glutathione in injectables after at least 30 patients had reactions.
FDA's Compounding Risk Alerts page collects these alerts (e.g., topical finasteride, glutathione, semaglutide dosing errors, sulfite-containing compounded drugs). 503A pharmacies are not required to report adverse events to FDA, so events may be under-reported.
- FDA reminds compounders not to use dietary supplement grade glutathione for injectables — FDA, 2026-08-27
- Compounding Risk Alerts — FDA, 2026-09-23
Changing now
- FDA proposed rule on 503A interstate distribution and a new standard MOU, projected for November 2026. — Unified Agenda, RIN 0910-AI71 (Fall 2025)
- FDA decisions and rulemaking on peptides recommended by PCAC in July 2026, and a further PCAC meeting before end of Feb 2027. — Bulk-list bound? PCAC backs majority of peptides
What Georgia adds
Out-of-state pharmacies shipping into the stateAn out-of-state pharmacy must hold a Georgia nonresident pharmacy permit, or a Georgia pharmacy license, to ship prescriptions into Georgia.License required
Must a pharmacy located in another state hold a license/registration from this state to ship prescriptions (including patient-specific 503A compounded preparations) to patients or practitioners here?
O.C.G.A. §26-4-114.1 makes it unlawful for a pharmacy located outside Georgia without a nonresident pharmacy permit to ship, mail or deliver prescription drug orders into the state; Board Rule 480-6-.02 implements the permit. The pharmacist-in-charge who dispenses to Georgia residents must be licensed and in good standing in the pharmacy's home state; a Georgia-licensed PIC is not required. Pharmacies that compound must submit a USP-compliance inspection report. The statute sets it at no more than 6 months before initial registration or 2 years before renewal, and the Board's Feb. 2026 application asks for a report under 2 years old from the home-state regulator or a Board-approved inspection. The Georgia Drugs and Narcotics Agency (GDNA) does not inspect out-of-state facilities. Permit holders must run a toll-free counseling line at least 6 days and 60 hours a week, and the application fee is $1,000.
The statute text was read on FindLaw (Justia blocked fetching). The Board's April 22, 2026 rule-hearing notice proposed repealing Chapter 480-48 (delivery by mail) and amending Rule 480-11-.04 and hospital rules; whether and when these were adopted was not confirmed. The nonresident application still refers to pharmacies compounding 'for practitioners to use in patient care in the practitioner's office', which conflicts with Rule 480-11-.02's ban on office-use distribution by 503A pharmacies (see office_use_503a).
O.C.G.A. §26-4-114.1; Ga. Comp. R. & Regs. 480-6-.02
- O.C.G.A. §26-4-114.1 Nonresident pharmacy permits — FindLaw (Georgia Code, current as of 2024-03-28), 2024-03-28
- Ga. Comp. R. & Regs. R. 480-6-.02 Nonresident Pharmacy Permit — Legal Information Institute (Georgia rules), 2024-08-13
- Application for Non-Resident Pharmacy Permit (February 24, 2026) — Georgia State Board of Pharmacy, 2026-02-24
Office-use compounding from 503A pharmaciesGeorgia bans 503A pharmacies from distributing non-patient-specific compounded preparations to practitioners for office use (veterinarians excepted); office stock must come from a 503B outsourcing facility.Not allowed
May a 503A (traditional) pharmacy dispense or distribute compounded preparations to a practitioner for office use (administration in the office, not patient-specific)? The federal position is that 503A requires patient-specific prescriptions; this is what the state pharmacy act and board rules allow.
Board Rule 480-11-.02 says: 'The distribution of non-patient specific compounded preparations for office use by a practitioner, excluding veterinarians, is prohibited.' It adds that this does not affect 503B outsourcing facilities' ability to supply office use. Veterinary office or emergency supply is capped at 5% of a pharmacy's yearly compounding production; above 5% counts as manufacturing and needs a manufacturer license. Pharmacists may compound ahead of orders only based on a history of valid prescriptions within an established pharmacist/patient/prescriber relationship. GDNA's Jan. 2016 letter told in-state and nonresident pharmacies they may no longer compound for office use unless registered with FDA as 503B outsourcing facilities, which matches FDA's view.
The rule was last amended effective 5/24/2023, more than 2 years ago; no later amendment to the office-use sentence was found. The 2016 GDNA letter is possibly stale but agrees with the rule. The Board's Feb. 2026 nonresident application still asks for an inspection report from pharmacies compounding 'for practitioners to use in patient care in the practitioner's office', which looks like legacy wording.
Ga. Comp. R. & Regs. 480-11-.02
- Ga. Comp. R. & Regs. R. 480-11-.02 Compounded Drug Preparations — Legal Information Institute (Georgia rules), 2023-05-24
- GDNA letter: Georgia State Board of Pharmacy Requirements for Office Use Drug Compounding (Jan. 20, 2016) — Georgia Drugs and Narcotics Agency / Georgia Board of Pharmacy, 2016-01-20
FDA compounding MOUGeorgia has not signed FDA's standard compounding MOU, so under the statute its 503A pharmacies are limited to 5% out-of-state distribution, although FDA is not enforcing that limit while it rewrites the MOU.Not signed
Has the state signed FDA's standard Memorandum of Understanding Addressing Certain Distributions of Compounded Human Drug Products (October 2020)? If not, FD&C Act §503A limits its 503A pharmacies' out-of-state distribution to 5% of total prescription orders (currently not enforced by FDA pending rulemaking).
Signing the standard MOU means the state board agrees to investigate complaints about compounded drugs its 503A pharmacies ship out of state and to identify and report to FDA pharmacies that distribute "inordinate amounts" interstate (more than 50% of their compounded prescriptions); in exchange, the statutory 5% out-of-state cap in FD&C Act §503A(b)(3)(B) does not apply to that state's pharmacies. FDA lists only Colorado, Kentucky and New Hampshire as signatories; Georgia is not among them. For a non-signing state, FD&C Act §503A(b)(3)(B)(ii) caps a 503A pharmacy's out-of-state distribution of compounded drugs at 5% of its total prescription orders. FDA now considers the October 2020 standard MOU suspended (it does not expect signatory states to carry out MOU activities and will not sign new ones) and is not enforcing the 5% limit until a final rule and an updated MOU are published; FDA's rulemaking (RIN 0910-AI71) listed a proposed rule for 11/2026 in the Fall 2025 Unified Agenda.
The FDA list of signed MOUs (current as of 2023-01-23) is older than 2 years, but FDA stopped entering new agreements under the 2020 MOU in October 2022, so no state can have signed since. The FDA "Compounding Information for States" page (current as of 2026-08-28) still describes the MOU as awaiting rulemaking. Pending: FDA proposed rule on 503A distribution (RIN 0910-AI71, NPRM projected 11/2026); H.R. 5316 (introduced 2025-09-11, referred to House Energy & Commerce) would remove the MOU provision from §503A.
FD&C Act §503A(b)(3)(B) (21 U.S.C. 353a(b)(3)(B))
- Compounding MOUs (list of signed standard MOUs) — U.S. Food and Drug Administration, 2023-01-23
- Memorandum of Understanding Addressing Certain Distributions of Compounded Drugs — U.S. Food and Drug Administration, 2022-10-20
- Compounding Information for States — U.S. Food and Drug Administration, 2026-08-28
- Federal Register 87 FR 63770 (Oct. 21, 2022), Doc. 2022-22876 — MOU suspension and extension of 5% enforcement period — Federal Register / GovInfo, 2022-10-21
Physicians dispensing from the officeGeorgia physicians may dispense if they notify their licensing board and follow pharmacy recordkeeping, labeling, packaging and storage rules.Allowed
May physicians dispense prescription drugs (not just administer them) directly to patients from their practice? "Yes" means allowed under standard rules (labeling, records, and at most a simple notice to the board); "conditional" means a separate dispensing registration, permit or license, or quantity, day-supply or drug-category limits; "no" means prohibited except narrow exceptions.
O.C.G.A. 26-4-130 exempts practitioners dispensing their own prescriptions from most of the pharmacy act but requires them to meet all pharmacy recordkeeping, labeling, packaging and storage requirements and to open records to inspection. Board of Pharmacy Rule 480-28-.03 requires a practitioner who intends to dispense to notify the licensing board at license renewal with name, license number, DEA number and dispensing address; the Georgia Composite Medical Board passes this to the Board of Pharmacy. The Georgia Drugs and Narcotics Agency inspects dispensing practitioners.
Source older than 2 years - possibly stale. Official sources (rules.sos.ga.gov, gdna.georgia.gov) could not be loaded by the research tools; statute and rule text read from a 2017 law-firm compilation. Verify with the Georgia Composite Medical Board. Answer is yes because only notice is required. Compilation date taken from the file upload timestamp (Feb. 2017).
O.C.G.A. 26-4-130; Ga. Comp. R. & Regs. 480-28-.02, 480-28-.03
- Georgia Dispensing Practitioner Laws and Rules (compilation of O.C.G.A. 26-4-130 and Rule ch. 480-28) — Law firm compilation (dpcattorney), 2017-02-21
- Georgia Drugs and Narcotics Agency - Prescribers — Georgia Drugs and Narcotics Agency, 2026-09-23
Prescribing by telehealthGeorgia requires a Georgia license or a Georgia telemedicine license, allows exams by adequate technology, and restricts controlled-substance prescribing by electronic means.Allowed with extra conditions
For a patient located in the state: must the prescriber hold this state's license (or a telehealth registration or special license), is an in-person exam required before prescribing (generally or for controlled substances), are there state limits on prescribing Schedule III drugs such as testosterone by telehealth, and is the state an Interstate Medical Licensure Compact member? "Yes" means a state license and the in-person standard of care apply (opioid-only or Schedule II-only limits are described but do not change the answer); "conditional" means extra state conditions such as a telehealth registration route, an in-person exam requirement, controlled-substance limits reaching Schedule III, or registration of telehealth businesses. Federal DEA rules apply on top.
Out-of-state physicians who treat Georgia patients electronically need a Georgia license or a telemedicine license, which is limited to telemedicine practice (O.C.G.A. 43-34-31, 43-34-31.1; Rule 360-2-.17). Under Rule 360-3-.07 the treating clinician must have examined the patient personally, be acting at the request of a Georgia clinician who has, or be able to examine the patient using technology and peripherals equal or superior to an in-person exam. The rule does not authorize prescribing controlled substances for pain or chronic pain by electronic means, and board rules treat prescribing controlled substances based solely on an electronic consultation as unprofessional conduct. IMLC: member.
Georgia's official rule and code sites blocked the research tools, so primary text was not read. How the 'solely electronic consultation' rule applies to non-pain controlled substances such as testosterone is unclear; confirm with the Georgia Composite Medical Board.
O.C.G.A. 43-34-31, 43-34-31.1; Ga. Comp. R. & Regs. 360-2-.17, 360-3-.07
- Georgia - Professional Requirements — Center for Connected Health Policy (CCHP), 2026-05-29
- IMLC Commission - Compact State Map (participating states) — Interstate Medical Licensure Compact Commission, 2026-09-23
IV hydration and vitamin therapyGeorgia requires an individualized order and a completed history and physical by a physician, NP/APRN or PA before an RN (or supervised LPN) gives IV hydration; standing orders and menu-based treatment are not a substitute.Extra requirements apply
What does the state require for elective IV hydration/vitamin (incl. NAD+) therapy: who may start IVs, is a patient-specific order or good-faith exam required before a patient's first IV, are standing orders allowed, and are there rules for mobile IV services?
The Georgia Composite Medical Board's IV Hydration/Therapy position statement (2026-05-07) adopts the Board of Nursing's IV Hydration Position Statement: in walk-in, mobile and drip-bar settings an RN or LPN may not be the only licensed professional evaluating and treating the patient. IV hydration, nutrients and medications may be given by an RN, or an LPN under supervision, only on a valid individualized order from a physician, NP or PA after that prescriber completes a history and physical; standing orders are not an appropriate substitute, and businesses must keep on-site policies and emergency procedures. APRNs may evaluate and order under a compliant nurse protocol agreement; the clinic may not rely on RN-only evaluation, generic standing orders, menu-based treatment or non-compliant sterile compounding (USP <797>).
The Board of Nursing's own 2024 statement (sos.ga.gov) could not be fetched (HTTP 403); its content is taken from the Medical Board's summary.
GCMB IV Hydration/Therapy Position Statement (2026-05-07); Georgia Board of Nursing IV Hydration Position Statement (2024-04-01); O.C.G.A. §43-34-25; Ga. Comp. R. & Regs. 360-32-.04, 360-32-.05
- IV Hydration/Therapy Position Statement (v2) — Georgia Composite Medical Board, 2026-05-07
- IV Hydration/Therapy Position Statement (news post) — Georgia Composite Medical Board, 2026-05-19
Compare every state: Out-of-state pharmacies shipping into the state · Office-use compounding from 503A pharmacies · FDA compounding MOU · Physicians dispensing from the office · Prescribing by telehealth · IV hydration and vitamin therapy
Georgia at a glance
Every topic we research, for Georgia. Open any line for the rule, its citation and the source.
Pharmacy & compounding
Out-of-state pharmacies shipping into the stateAn out-of-state pharmacy must hold a Georgia nonresident pharmacy permit, or a Georgia pharmacy license, to ship prescriptions into Georgia.License required
Must a pharmacy located in another state hold a license/registration from this state to ship prescriptions (including patient-specific 503A compounded preparations) to patients or practitioners here?
O.C.G.A. §26-4-114.1 makes it unlawful for a pharmacy located outside Georgia without a nonresident pharmacy permit to ship, mail or deliver prescription drug orders into the state; Board Rule 480-6-.02 implements the permit. The pharmacist-in-charge who dispenses to Georgia residents must be licensed and in good standing in the pharmacy's home state; a Georgia-licensed PIC is not required. Pharmacies that compound must submit a USP-compliance inspection report. The statute sets it at no more than 6 months before initial registration or 2 years before renewal, and the Board's Feb. 2026 application asks for a report under 2 years old from the home-state regulator or a Board-approved inspection. The Georgia Drugs and Narcotics Agency (GDNA) does not inspect out-of-state facilities. Permit holders must run a toll-free counseling line at least 6 days and 60 hours a week, and the application fee is $1,000.
The statute text was read on FindLaw (Justia blocked fetching). The Board's April 22, 2026 rule-hearing notice proposed repealing Chapter 480-48 (delivery by mail) and amending Rule 480-11-.04 and hospital rules; whether and when these were adopted was not confirmed. The nonresident application still refers to pharmacies compounding 'for practitioners to use in patient care in the practitioner's office', which conflicts with Rule 480-11-.02's ban on office-use distribution by 503A pharmacies (see office_use_503a).
O.C.G.A. §26-4-114.1; Ga. Comp. R. & Regs. 480-6-.02
- O.C.G.A. §26-4-114.1 Nonresident pharmacy permits — FindLaw (Georgia Code, current as of 2024-03-28), 2024-03-28
- Ga. Comp. R. & Regs. R. 480-6-.02 Nonresident Pharmacy Permit — Legal Information Institute (Georgia rules), 2024-08-13
- Application for Non-Resident Pharmacy Permit (February 24, 2026) — Georgia State Board of Pharmacy, 2026-02-24
Office-use compounding from 503A pharmaciesGeorgia bans 503A pharmacies from distributing non-patient-specific compounded preparations to practitioners for office use (veterinarians excepted); office stock must come from a 503B outsourcing facility.Not allowed
May a 503A (traditional) pharmacy dispense or distribute compounded preparations to a practitioner for office use (administration in the office, not patient-specific)? The federal position is that 503A requires patient-specific prescriptions; this is what the state pharmacy act and board rules allow.
Board Rule 480-11-.02 says: 'The distribution of non-patient specific compounded preparations for office use by a practitioner, excluding veterinarians, is prohibited.' It adds that this does not affect 503B outsourcing facilities' ability to supply office use. Veterinary office or emergency supply is capped at 5% of a pharmacy's yearly compounding production; above 5% counts as manufacturing and needs a manufacturer license. Pharmacists may compound ahead of orders only based on a history of valid prescriptions within an established pharmacist/patient/prescriber relationship. GDNA's Jan. 2016 letter told in-state and nonresident pharmacies they may no longer compound for office use unless registered with FDA as 503B outsourcing facilities, which matches FDA's view.
The rule was last amended effective 5/24/2023, more than 2 years ago; no later amendment to the office-use sentence was found. The 2016 GDNA letter is possibly stale but agrees with the rule. The Board's Feb. 2026 nonresident application still asks for an inspection report from pharmacies compounding 'for practitioners to use in patient care in the practitioner's office', which looks like legacy wording.
Ga. Comp. R. & Regs. 480-11-.02
- Ga. Comp. R. & Regs. R. 480-11-.02 Compounded Drug Preparations — Legal Information Institute (Georgia rules), 2023-05-24
- GDNA letter: Georgia State Board of Pharmacy Requirements for Office Use Drug Compounding (Jan. 20, 2016) — Georgia Drugs and Narcotics Agency / Georgia Board of Pharmacy, 2016-01-20
503B outsourcing facilities shipping into the stateGeorgia requires a 503B outsourcing facility serving Georgia to hold a Georgia pharmacy license or nonresident pharmacy permit plus a Georgia drug manufacturer permit.State license required
Does the state require an FDA-registered 503B outsourcing facility located outside the state to hold a state license/registration (as an outsourcing facility, nonresident manufacturer, wholesaler or pharmacy) before shipping into the state?
GDNA's January 20, 2016 letter, posted by the Board of Pharmacy, states that 'Georgia requires all 503B outsourcing facilities to be a licensed pharmacy, both in-state and non-resident' and that they must 'also hold a Georgia drug manufacturing permit as well as the pharmacy permit'. Under that letter, 503B facilities may distribute non-patient-specific office-use drugs to practitioners but not for resale. O.C.G.A. §26-4-5 defines an outsourcing facility as a compounding facility registered with FDA under section 503B. Manufacturer permits are issued under Rule 480-7-.01 after the GDNA Director certifies the applicant's qualifications.
The dual pharmacy-plus-manufacturer requirement comes from the 2016 GDNA letter, which is possibly stale (older than 2 years). Neither Rule 480-7-.01 (amended eff. 8/13/2024) nor the other rules checked mention 503B facilities, and the Board's current forms page does not list a separate outsourcing facility application. A secondary search snippet (not fetched) indicated that 503B facilities use the Board's manufacturing application. Confirm the current credential with the Georgia Board of Pharmacy (gbp.georgia.gov, 404-651-8000).
O.C.G.A. §26-4-5; O.C.G.A. §26-4-114.1; Ga. Comp. R. & Regs. 480-7-.01; Ga. Comp. R. & Regs. 480-11-.02
- GDNA letter: Georgia State Board of Pharmacy Requirements for Office Use Drug Compounding (Jan. 20, 2016) — Georgia Drugs and Narcotics Agency / Georgia Board of Pharmacy, 2016-01-20
- O.C.G.A. §26-4-5 Definitions — FindLaw (Georgia Code, current as of 2024-03-28), 2024-03-28
- Ga. Comp. R. & Regs. R. 480-7-.01 Manufacturer's Permit — Legal Information Institute (Georgia rules), 2024-08-13
FDA compounding MOUGeorgia has not signed FDA's standard compounding MOU, so under the statute its 503A pharmacies are limited to 5% out-of-state distribution, although FDA is not enforcing that limit while it rewrites the MOU.Not signed
Has the state signed FDA's standard Memorandum of Understanding Addressing Certain Distributions of Compounded Human Drug Products (October 2020)? If not, FD&C Act §503A limits its 503A pharmacies' out-of-state distribution to 5% of total prescription orders (currently not enforced by FDA pending rulemaking).
Signing the standard MOU means the state board agrees to investigate complaints about compounded drugs its 503A pharmacies ship out of state and to identify and report to FDA pharmacies that distribute "inordinate amounts" interstate (more than 50% of their compounded prescriptions); in exchange, the statutory 5% out-of-state cap in FD&C Act §503A(b)(3)(B) does not apply to that state's pharmacies. FDA lists only Colorado, Kentucky and New Hampshire as signatories; Georgia is not among them. For a non-signing state, FD&C Act §503A(b)(3)(B)(ii) caps a 503A pharmacy's out-of-state distribution of compounded drugs at 5% of its total prescription orders. FDA now considers the October 2020 standard MOU suspended (it does not expect signatory states to carry out MOU activities and will not sign new ones) and is not enforcing the 5% limit until a final rule and an updated MOU are published; FDA's rulemaking (RIN 0910-AI71) listed a proposed rule for 11/2026 in the Fall 2025 Unified Agenda.
The FDA list of signed MOUs (current as of 2023-01-23) is older than 2 years, but FDA stopped entering new agreements under the 2020 MOU in October 2022, so no state can have signed since. The FDA "Compounding Information for States" page (current as of 2026-08-28) still describes the MOU as awaiting rulemaking. Pending: FDA proposed rule on 503A distribution (RIN 0910-AI71, NPRM projected 11/2026); H.R. 5316 (introduced 2025-09-11, referred to House Energy & Commerce) would remove the MOU provision from §503A.
FD&C Act §503A(b)(3)(B) (21 U.S.C. 353a(b)(3)(B))
- Compounding MOUs (list of signed standard MOUs) — U.S. Food and Drug Administration, 2023-01-23
- Memorandum of Understanding Addressing Certain Distributions of Compounded Drugs — U.S. Food and Drug Administration, 2022-10-20
- Compounding Information for States — U.S. Food and Drug Administration, 2026-08-28
- Federal Register 87 FR 63770 (Oct. 21, 2022), Doc. 2022-22876 — MOU suspension and extension of 5% enforcement period — Federal Register / GovInfo, 2022-10-21
Prescribing, dispensing & telehealth
State controlled-substance registrationGeorgia physicians do not need a separate state controlled substance registration: by statute a Georgia-licensed physician is deemed registered and exempt from the Board of Pharmacy registration application and fee.DEA + state license only
Besides DEA registration, does the state require practitioners to hold a separate state controlled substance registration, license or permit to prescribe, administer or dispense controlled substances (e.g. testosterone, Schedule III)? "Conditional" means a state registration is needed only in some settings, such as keeping controlled-substance stock in the office.
O.C.G.A. 16-13-35(a) requires every person who dispenses controlled substances to obtain annually a registration from the State Board of Pharmacy, but subsection (g) provides that persons licensed as a physician, dentist or veterinarian to use, prescribe, dispense and administer drugs 'are registered under this article and are exempt from the registration fee and registration application requirements'. In practice a Georgia license plus a Georgia DEA registration is what is required. The exemption names physicians, dentists and veterinarians; APRNs and PAs prescribe under delegation/protocol arrangements with a physician.
Source older than 2 years - possibly stale (FindLaw text 'current as of' Mar. 28, 2024; the official Lexis-hosted code could not be opened). Statute text read via WebFetch summary of FindLaw, which quoted subsection (g) verbatim. Whether APRNs/PAs need anything beyond DEA and their delegation agreement was not confirmed - check with the Georgia Board of Pharmacy / Composite Medical Board.
O.C.G.A. 16-13-35
- Georgia Code Sec. 16-13-35 (Registration requirements) - FindLaw reproduction — FindLaw (text of the Official Code of Georgia Annotated), 2024-03-28
- Georgia Code Sec. 16-13-34 - FindLaw reproduction — FindLaw (text of the Official Code of Georgia Annotated), 2024-03-28
PDMP check before prescribingGeorgia requires a PDMP check only for Schedule II opiates/cocaine derivatives and benzodiazepines (first prescription and every 90 days), so testosterone is not covered.Required for some drugs only
Must a prescriber query the state Prescription Drug Monitoring Program before prescribing, and does the mandate cover Schedule III drugs such as testosterone? "Yes" means a mandate that reaches Schedule III; "conditional" means a mandate limited to certain drugs (e.g. opioids or benzodiazepines) or situations; "no" means no prescriber query mandate.
Since July 1, 2018, a prescriber issuing a 'controlled medication' - defined as a Schedule II opiate or cocaine derivative under O.C.G.A. 16-13-26(1)-(2) or a benzodiazepine - must review the PDMP the first time the prescription is issued to a patient and at least every 90 days thereafter, and must note the check in the chart. Exemptions: supplies of 3 days or less and no more than 26 pills; patients in a hospital or health care facility where the drug is administered; post-outpatient-surgery supplies of 10 days or less and no more than 40 pills; terminally ill or outpatient hospice patients; and cancer treatment. Enforced by the prescriber's licensing board; the PDMP is run by the Georgia Department of Public Health.
Frequency: first prescription + at least every 90 days. Testosterone (C-III) is not caught. The Georgia rules site (rules.sos.ga.gov) refused the connection; the rule text was read on LII and matches the DPH page (last updated 4/21/2026). The statute text of O.C.G.A. 16-13-63 was not opened directly.
O.C.G.A. § 16-13-63; Ga. Comp. R. & Regs. r. 360-38-.01, 360-38-.04
- Georgia PDMP - prescriber checking requirements — Georgia Department of Public Health, 2026-04-21
- Ga. Comp. R. & Regs. R. 360-38-.04 - Requirements for Checking the PDMP — Legal Information Institute (Georgia Composite Medical Board rule text), 2018-09-03
- Ga. Comp. R. & Regs. R. 360-38-.01 - Definitions — Legal Information Institute (Georgia Composite Medical Board rule text), 2018-09-03
Physicians dispensing from the officeGeorgia physicians may dispense if they notify their licensing board and follow pharmacy recordkeeping, labeling, packaging and storage rules.Allowed
May physicians dispense prescription drugs (not just administer them) directly to patients from their practice? "Yes" means allowed under standard rules (labeling, records, and at most a simple notice to the board); "conditional" means a separate dispensing registration, permit or license, or quantity, day-supply or drug-category limits; "no" means prohibited except narrow exceptions.
O.C.G.A. 26-4-130 exempts practitioners dispensing their own prescriptions from most of the pharmacy act but requires them to meet all pharmacy recordkeeping, labeling, packaging and storage requirements and to open records to inspection. Board of Pharmacy Rule 480-28-.03 requires a practitioner who intends to dispense to notify the licensing board at license renewal with name, license number, DEA number and dispensing address; the Georgia Composite Medical Board passes this to the Board of Pharmacy. The Georgia Drugs and Narcotics Agency inspects dispensing practitioners.
Source older than 2 years - possibly stale. Official sources (rules.sos.ga.gov, gdna.georgia.gov) could not be loaded by the research tools; statute and rule text read from a 2017 law-firm compilation. Verify with the Georgia Composite Medical Board. Answer is yes because only notice is required. Compilation date taken from the file upload timestamp (Feb. 2017).
O.C.G.A. 26-4-130; Ga. Comp. R. & Regs. 480-28-.02, 480-28-.03
- Georgia Dispensing Practitioner Laws and Rules (compilation of O.C.G.A. 26-4-130 and Rule ch. 480-28) — Law firm compilation (dpcattorney), 2017-02-21
- Georgia Drugs and Narcotics Agency - Prescribers — Georgia Drugs and Narcotics Agency, 2026-09-23
Prescribing by telehealthGeorgia requires a Georgia license or a Georgia telemedicine license, allows exams by adequate technology, and restricts controlled-substance prescribing by electronic means.Allowed with extra conditions
For a patient located in the state: must the prescriber hold this state's license (or a telehealth registration or special license), is an in-person exam required before prescribing (generally or for controlled substances), are there state limits on prescribing Schedule III drugs such as testosterone by telehealth, and is the state an Interstate Medical Licensure Compact member? "Yes" means a state license and the in-person standard of care apply (opioid-only or Schedule II-only limits are described but do not change the answer); "conditional" means extra state conditions such as a telehealth registration route, an in-person exam requirement, controlled-substance limits reaching Schedule III, or registration of telehealth businesses. Federal DEA rules apply on top.
Out-of-state physicians who treat Georgia patients electronically need a Georgia license or a telemedicine license, which is limited to telemedicine practice (O.C.G.A. 43-34-31, 43-34-31.1; Rule 360-2-.17). Under Rule 360-3-.07 the treating clinician must have examined the patient personally, be acting at the request of a Georgia clinician who has, or be able to examine the patient using technology and peripherals equal or superior to an in-person exam. The rule does not authorize prescribing controlled substances for pain or chronic pain by electronic means, and board rules treat prescribing controlled substances based solely on an electronic consultation as unprofessional conduct. IMLC: member.
Georgia's official rule and code sites blocked the research tools, so primary text was not read. How the 'solely electronic consultation' rule applies to non-pain controlled substances such as testosterone is unclear; confirm with the Georgia Composite Medical Board.
O.C.G.A. 43-34-31, 43-34-31.1; Ga. Comp. R. & Regs. 360-2-.17, 360-3-.07
- Georgia - Professional Requirements — Center for Connected Health Policy (CCHP), 2026-05-29
- IMLC Commission - Compact State Map (participating states) — Interstate Medical Licensure Compact Commission, 2026-09-23
Aesthetics, IV therapy & practice ownership
Who may inject neuromodulators and fillersNo Georgia rule or board statement on who may inject Botox or fillers could be confirmed; the Georgia Board of Nursing site blocked automated access.Not confirmed
Who may administer botulinum toxin and dermal fillers (physicians, PAs, NPs, RNs, LPNs, estheticians, dentists), under what supervision (on-site vs available), and must a physician/NP/PA perform a prior good-faith exam?
The Georgia Composite Medical Board's guidance, FAQ and rule-update pages (checked 2026-09-23) contain no statement on cosmetic injectables. Its 2026 IV statement, summarizing the Board of Nursing, says RNs and LPNs may not be the only licensed professional evaluating and treating patients in non-traditional settings, because diagnosis and treatment planning are outside nursing scope. Whether the Board of Nursing applies an individualized-order/prior-exam requirement to neuromodulators and fillers was not confirmed.
Georgia Board of Nursing documents on sos.ga.gov returned HTTP 403 to automated requests on 2026-09-23. Check with the Georgia Board of Nursing (Secretary of State).
- Board Guidance and AG Opinions — Georgia Composite Medical Board, 2026-09-23
- IV Hydration/Therapy Position Statement (v2) — Georgia Composite Medical Board, 2026-05-07
IV hydration and vitamin therapyGeorgia requires an individualized order and a completed history and physical by a physician, NP/APRN or PA before an RN (or supervised LPN) gives IV hydration; standing orders and menu-based treatment are not a substitute.Extra requirements apply
What does the state require for elective IV hydration/vitamin (incl. NAD+) therapy: who may start IVs, is a patient-specific order or good-faith exam required before a patient's first IV, are standing orders allowed, and are there rules for mobile IV services?
The Georgia Composite Medical Board's IV Hydration/Therapy position statement (2026-05-07) adopts the Board of Nursing's IV Hydration Position Statement: in walk-in, mobile and drip-bar settings an RN or LPN may not be the only licensed professional evaluating and treating the patient. IV hydration, nutrients and medications may be given by an RN, or an LPN under supervision, only on a valid individualized order from a physician, NP or PA after that prescriber completes a history and physical; standing orders are not an appropriate substitute, and businesses must keep on-site policies and emergency procedures. APRNs may evaluate and order under a compliant nurse protocol agreement; the clinic may not rely on RN-only evaluation, generic standing orders, menu-based treatment or non-compliant sterile compounding (USP <797>).
The Board of Nursing's own 2024 statement (sos.ga.gov) could not be fetched (HTTP 403); its content is taken from the Medical Board's summary.
GCMB IV Hydration/Therapy Position Statement (2026-05-07); Georgia Board of Nursing IV Hydration Position Statement (2024-04-01); O.C.G.A. §43-34-25; Ga. Comp. R. & Regs. 360-32-.04, 360-32-.05
- IV Hydration/Therapy Position Statement (v2) — Georgia Composite Medical Board, 2026-05-07
- IV Hydration/Therapy Position Statement (news post) — Georgia Composite Medical Board, 2026-05-19
Corporate practice of medicine / med spa ownershipGeorgia repealed its corporate practice statute in 1982 and compilations call the doctrine unclear, but the Medical Board bars a physician from being paid by the APRN (or APRN-owned company) that the physician supervises.CPOM with exceptions
Does the state enforce the corporate practice of medicine doctrine (non-physicians may not own medical practices or employ physicians), and how does that affect med spa ownership?
Permit Health classifies Georgia as 'Unclear (Historical)', citing O.C.G.A. §43-34-37 and Sherrer v. Hale (1982); MedPath calls it nuanced. Separately, the Medical Board's May 2026 position statement says that under O.C.G.A. §43-34-25(n) it is unlawful for a physician to be employed by an APRN they supervise, and the Board reads this to cover any compensation from an APRN or APRN-owned company for serving as delegating physician, including payment routed through 'collaborator' matching companies. NP-owned med spas therefore cannot pay their own delegating physician.
O.C.G.A. §43-34-25(n); Ga. Comp. R. & Regs. 360-32-.04(5); Sherrer v. Hale (Ga. 1982) (as reported by Permit Health)
- IV Hydration/Therapy Position Statement (v2) — Georgia Composite Medical Board, 2026-05-07
- The Corporate Practice of Medicine 50-State Guide — Permit Health, 2025-12-23
Who may operate aesthetic lasersGeorgia licenses cosmetic laser practitioners through the Medical Board: nurses and PAs may become senior laser practitioners under a consulting physician's protocols, and other licensees (such as estheticians) may become assistant practitioners supervised by a physician or senior practitioner.Delegable with licensing/training rules
Who may perform laser/IPL/RF aesthetic procedures (laser hair removal, resurfacing): physicians only, delegated to RNs/PAs, or licensed electrologists/estheticians/laser technicians with state certification?
Under the Cosmetic Laser Services Act and Board Chapter 360-35 (amended effective 2026-05-25), 'cosmetic laser services' means nonablative light-based skin care, photorejuvenation or hair removal with FDA-approved lasers or pulsed light and now also energy-based procedures using ultrasound, cryolipolysis, microwave or radiofrequency devices. A senior laser practitioner (a nurse or PA with a licence) practises under a consulting physician's protocols and may supervise assistants. Assistant laser practitioners work under a physician or senior practitioner and must have patients examined first by a consulting physician or a licensed PA/APRN laser practitioner, except that on-site supervision and a prior exam are not required for laser hair removal and pulsed-light treatments. Applicants need physician- or ACCME-taught training certificates (two for senior, three for assistant), and seniors need three years' clinical experience and a consulting physician agreement.
O.C.G.A. §43-34-240 et seq. (Cosmetic Laser Services Act); Ga. Comp. R. & Regs. 360-35-.01, 360-35-.05 (eff. 2026-05-25)
- Rules Chapter 360-35 Lasers (highlighted 2026 changes) — Georgia Composite Medical Board, 2026-05-25
- Cosmetic Laser Practitioner (Senior and Assistant) licensure — Georgia Composite Medical Board, 2026-09-23
- 2026 Legislative Session – Rule & Law Updates — Georgia Composite Medical Board, 2026-05-25
Labs, regenerative medicine & cosmetics
State clinical laboratory licensing (beyond CLIA)Not confirmed. No Georgia lab license beyond CLIA was found in the sources reviewed, but its absence was not verified.Not confirmed
Does the state license clinical laboratories itself, beyond federal CLIA certification, including out-of-state labs that test specimens from the state?
Most states rely on federal CLIA certification alone. The states confirmed in this research as issuing their own lab licenses are California, New York, Pennsylvania, Maryland and Rhode Island (which also reach out-of-state labs testing specimens from their residents), plus Nevada, Washington, Massachusetts, New Jersey and New Hampshire (labs located in the state). Georgia was not among them, but this research did not confirm its statutes. Georgia's CLIA state agency is Georgia Dept. of Community Health, Healthcare Facility Regulation Division, Diagnostic Services Unit (hfrd.diagnostic@dch.ga.gov, 404-657-5700); it can confirm whether any state license or permit applies, including to out-of-state labs.
Georgia may run its own in-state lab licensing program; this could not be confirmed from a primary source in this pass, so check with the agency before relying on CLIA alone.
Not confirmed
- CLIA State Agency Contacts (updated May 2026) — Centers for Medicare & Medicaid Services, 2026-05-01
Direct-to-consumer lab testingNot confirmed whether Georgia consumers may order lab tests without a practitioner order. Practitioner-ordered panels are not affected.Not confirmed
May consumers order their own lab tests without a practitioner order (direct access testing)? A practitioner-ordered panel is always fine; this matters for take-home and consumer test kits.
ADLM (formerly AACC) reported in 2019 that 37 states and DC let consumers order some or all tests directly, but it did not publish the state list, and this research did not confirm Georgia's rule. Georgia's lab regulator (CLIA state agency) is Georgia Dept. of Community Health, Healthcare Facility Regulation Division, Diagnostic Services Unit (hfrd.diagnostic@dch.ga.gov, 404-657-5700). The question matters for take-home and consumer test kits, not for panels a clinician orders.
The ADLM figure dates from 2019 (older than 2 years).
Not confirmed
- Direct-to-consumer laboratory testing (position statement, 2019): '37 states and the District of Columbia permit consumers to order some or all of their laboratory tests directly' — Association for Diagnostics & Laboratory Medicine (formerly AACC), 2026-09-23
- CLIA State Agency Contacts (updated May 2026) — Centers for Medicare & Medicaid Services, 2026-05-01
State laws on stem cell / regenerative therapiesGeorgia (HB 1275, 2026) allows physicians, and PAs or NPs they designate, to perform non-FDA-approved stem cell therapy within their scope, with sourcing standards, an advertising notice and signed consent.State-specific law
Has the state enacted a law or rule specifically about stem cell, exosome or regenerative-medicine therapies (notice/disclosure duties, permission for certain non-FDA-approved uses, or Right to Try extensions covering them)?
HB 1275 adds O.C.G.A. §43-34-49. 'Human stem cell therapy' means treatment using afterbirth placental perinatal stem cells or HCT/Ps (the definition excludes secreted or extracted products such as cell factors), and excludes cells from aborted fetuses or embryos. Cells must come from a facility that is FDA-registered, or certified by WMDA, AABB, AATB or another entity approved by the Department of Public Health, and must follow cGMP and 21 CFR 1271. Facilities must tell the physician of accreditation changes within 30 days. Ads must include a notice ('THIS NOTICE MUST BE PROVIDED TO YOU UNDER GEORGIA LAW...'), and a signed consent must state the treatment's nature, FDA status and anticipated results. IND holders and staff of FACT-, BMT CTN- or AABB-accredited institutions are exempt. Violations are subject to board discipline. Federal FDA rules still apply regardless of state law: stem cell, birth-tissue and exosome products are regulated by FDA, and a state law cannot make an unapproved biologic FDA-approved.
Signed May 11, 2026 and effective July 1, 2026, per secondary sources (the as-passed text has no special effective date). The HCT/P definition excludes 'secreted or extracted human products, such as ... cell factors', so exosome and growth-factor products are likely outside the law.
O.C.G.A. §43-34-49 (HB 1275, 2026)
- HB 1275 (2026), as passed House and Senate — new O.C.G.A. §43-34-49 (human stem cell therapy) — Office of the Governor of Georgia (2026 signed legislation), 2026-09-23
- Georgia and Tennessee Signal the Next Phase of State Stem Cell Therapy Laws — Florida Healthcare Law Firm, 2026-09-23
- State Stem Cell Laws: Accurate 2026 Map Update (lists 12 states with statutes; commercial source) — SaveMyFat, 2026-08-06
State rules for cosmetics and sunscreenNo Georgia-specific cosmetic or sunscreen requirements beyond federal law (MoCRA/FDA) were found.None found beyond federal
Does the state have cosmetic or sunscreen requirements beyond federal MoCRA, such as ingredient bans (PFAS, formaldehyde, phthalates), ingredient reporting, sunscreen-ingredient bans, or bans on selling animal-tested cosmetics?
Georgia does not appear on 2026 compilations of state PFAS-in-cosmetics laws, on the list of states banning animal-tested cosmetics, or among the jurisdictions with sunscreen-ingredient bans. Federal MoCRA and FDA rules on cosmetics and OTC sunscreens still apply. Other state laws that touch cosmetics generally, such as state food-drug-cosmetic acts or consumer-protection laws, were not surveyed.
The animal-testing list is Wikipedia's 'as of 2023' compilation (older than 2 years); effective dates were not confirmed.
None found
- PFAS in Cosmetics: US State Bans and Compliance Deadlines - 2026 Update — Adherent (formerly Compliance & Risks), 2026-03-13
- State PFAS Bans in Cosmetics Expand Ahead of 2026 (updated Jan. 14, 2026) — Morgan, Lewis & Bockius LLP, 2026-01-14
- Testing cosmetics on animals (US state bans 'as of 2023') — Wikipedia, 2026-09-23
Compare every state
Corporate practice of medicine / med spa ownership. Does the state enforce the corporate practice of medicine doctrine (non-physicians may not own medical practices or employ physicians), and how does that affect med spa ownership?
The federal floor, for every category
Two federal compounding lanes: §503A pharmacies vs §503B outsourcing facilitiesA §503A pharmacy (or physician) compounds for an identified patient on a prescription; a §503B outsourcing facility is FDA-registered, follows CGMP, and is the only federal lane for non-patient-specific office stock.
Under §503A, a state-licensed pharmacist or physician may compound for an identified individual patient on a valid prescription, or in limited anticipatory quantities (no more than a 30-day supply based on the compounder's own prescription history). 503A compounders are not required to follow CGMP and are not required to report adverse events to FDA. Under §503B, an outsourcing facility registers with FDA, compounds under CGMP, is inspected on a risk-based schedule, must report adverse events, and may distribute non-patient-specific product to hospitals, clinics and practitioners for office use. Neither lane makes a compounded drug 'FDA-approved'. Both lanes restrict 'essentially copies' of approved or marketed drugs and restrict which bulk ingredients may be used. FDA keeps a public list of registered outsourcing facilities (content current as of 09/08/2026).
- Prescription Requirement Under Section 503A of the FD&C Act — Guidance for Industry — FDA/CDER, 2016-12-01
- Registered Outsourcing Facilities — FDA, 2026-09-08
- FDA's Concerns with Unapproved GLP-1 Drugs Used for Weight Loss (503A adverse events not required to be reported) — FDA, 2026-09-01
'Essentially a copy' of an approved or commercially available drugFDA treats a compounded drug with the same active ingredient, a similar strength and a usable route as a marketed product as 'essentially a copy' unless the prescriber documents a patient-specific significant difference on the prescription.
503A (final guidance, Jan 2018): a drug is not 'commercially available' if it is discontinued or is in 'currently in shortage' status on FDA's drug shortage list. FDA generally considers a compounded drug a copy if it has the same API in the same, similar or easily substitutable strength by a route the commercial product can be used by. The prescriber's determination must name the change and the significant difference for that patient; a patient name plus formulation is not enough, and lower price does not count. FDA does not consider copies to be made 'regularly or in inordinate amounts' if the compounder fills four or fewer such prescriptions per calendar month. 503B (final guidance, Jan 2018): outsourcing facilities may not compound drugs identical or nearly identical to an approved drug unless it is on the shortage list; otherwise a prescriber's determination of a clinical difference must be noted on the prescription or order.
- Compounded Drug Products That Are Essentially Copies of a Commercially Available Drug Product Under Section 503A — Guidance for Industry — FDA/CDER, 2018-01-01
- Compounded Drug Products That Are Essentially Copies of Approved Drug Products Under Section 503B — Guidance for Industry — FDA/CDER, 2018-01-01
Office use / office stock of compounded drugs (federal position)FDA's position is that §503A compounding requires a prescription for an identified patient; clinics wanting non-patient-specific office stock are directed to §503B outsourcing facilities.
FDA's final 503A prescription-requirement guidance (Dec 2016) says hospitals, clinics and practitioners can obtain non-patient-specific compounded drugs from outsourcing facilities registered under §503B, which may distribute sterile and non-sterile office-use product. 503A anticipatory compounding is limited to no more than a 30-day supply based on the compounder's own prescription history. Some states allow limited 503A office use under state law, but the federal 503A exemptions still depend on patient-specific prescriptions (see state topic office_use_503a).
503B products may not be resold by anyone other than the outsourcing facilitySection 503B(a)(8) bars anyone other than the outsourcing facility from selling or transferring its compounded drugs, so a clinic, distributor or marketplace that takes ownership may not resell 503B product.
FDA's June 2023 draft guidance (still draft) says the drug should go from the outsourcing facility to the entity that dispenses or administers it. FDA does not intend to apply the prohibition to transfers to common carriers, third-party logistics providers, regulators, returns processors, waste handlers or contract test labs, or to recall-related transfers. A state-licensed pharmacy may dispense 503B product against a patient-specific prescription. Clinic-to-clinic resale is the core concern.
- Prohibition on Wholesaling Under Section 503B of the FD&C Act — Draft Guidance for Industry — FDA/CDER, 2023-06-27
Which bulk ingredients compounders may use (503A Categories 1/2/3; 503B bulks list)A 503A compounder may use a bulk ingredient only if it has a USP/NF monograph, is a component of an FDA-approved drug, or is on the 503A bulks list; FDA tolerates interim 'Category 1' substances, flags 'Category 2' as significant safety risks, and treats 'Category 3' as lacking support.
FDA's category list was updated May 14, 2026. 503A Category 2 now contains only cesium chloride, domperidone, germanium sesquioxide, ibutamoren mesylate, kisspeptin-10 and quinacrine (intrauterine use). Category 1 includes glutathione, methylcobalamin, NAD, NADH, enclomiphene citrate, GHK-Cu (non-injectable routes only), vasoactive intestinal peptide and others. GHRP-2, GHRP-6, mechano growth factor and thymulin are in Category 3. BPC-157, TB-500, CJC-1295, ipamorelin, AOD-9604, Selank, Semax, epitalon, MOTs-C, dihexa, KPV and thymosin alpha-1 are in no category, so they do not get Category 1 enforcement discretion. FDA does not intend to categorize substances nominated on or after Jan 7, 2025. The final 503B bulks list is short (e.g., diphenylcyclopropenone, glycolic acid topical up to 70%, quinacrine oral, squaric acid dibutyl ester, trichloroacetic acid); 503B Category 2 includes GHRP-2, GHRP-6, ipamorelin acetate, ibutamoren, tranilast and others.
- Bulk Drug Substances Nominated for Use in Compounding Under Section 503A (Categories 1–3) — FDA, 2026-05-14
- Bulk Drug Substances Used in Compounding Under Section 503A of the FD&C Act — FDA, 2026-05-14
- Safety Risks Associated with Certain Bulk Drug Substances for Use in Compounding (Category 2) — FDA, 2026-04-22
- 503B Bulk Drug Substances List — FDA, 2024-05-16
- Bulk Drug Substances Used in Compounding Under Section 503B of the FD&C Act — FDA, 2025-01-07
Biologics (including hCG, tesamorelin, somatropin) cannot be compounded under 503A/503BSince March 23, 2020, protein products approved as drugs became licensed biologics, and FDA says biological products are not eligible for the 503A or 503B compounding exemptions.
The BPCI Act transition on March 23, 2020 deemed approved NDAs for biological products to be BLAs. FDA's transition list includes chorionic gonadotropin (Pregnyl, Novarel, Fresenius chorionic gonadotropin, Ovidrel), menotropins, follitropins, hyaluronidase, somatropin and tesamorelin acetate (Egrifta/Egrifta SV). FDA's notice to compounders states that 'biological products will not be eligible for the exemptions for compounded drugs under sections 503A and 503B'. Separate FDA guidance (Jan 2018) describes limited conditions for mixing, diluting or repackaging licensed biologics outside their labeling.
'Research Use Only' / 'not for human consumption' productsFDA treats RUO-labeled peptides and GLP-1s as unapproved drugs when marketing, dosing information or bundled syringes/bacteriostatic water show human use; the disclaimer does not make them lawful to administer to patients.
FDA's GLP-1 safety page says companies sold products falsely labeled 'for research purposes' or 'not for human consumption' with dosing instructions for human use. FDA has issued repeated warning-letter rounds to peptide/RUO sellers in 2026 (e.g., letters dated March 31, 2026 to Gram Peptides and others; June 17, 2026 to Wholesale Peptide; August 24, 2026 to Royal Peptides and others). Import Alert 66-41 (unapproved new drugs promoted in the U.S.) has listed, for example, a firm offering PT-141 peptide. RUO material is not a USP-grade or approved-drug-component bulk ingredient for compounding and is not a prescription drug a clinician can lawfully buy for patient use.
- FDA's Concerns with Unapproved GLP-1 Drugs Used for Weight Loss — FDA, 2026-09-01
- Warning Letter: Gram Peptides (MARCS-CMS 721806) — FDA, 2026-03-31
- Warning Letter: Wholesale Peptide (MARCS-CMS 729447) — FDA, 2026-06-17
- Warning Letter: Royal Peptides LLC (MARCS-CMS 734884) — FDA, 2026-08-24
- Import Alert 66-41: Detention Without Physical Examination of Unapproved New Drugs Promoted in the U.S. — FDA, 2026-09-11
FDA drug shortage list and why it matters for compoundingA drug in 'currently in shortage' status is not 'commercially available', so 503A/503B compounders may make copies of it; when FDA marks the shortage resolved, that permission ends (503B facilities may finish existing orders for up to 60 days).
The 503A copies guidance says a drug appears on the shortage list only if it is in 'currently in shortage' status, not 'resolved'. FDA's shortage-compounding page says compounders must still meet all other 503A conditions (including a valid patient-specific prescription), and FDA 'may take action if an outsourcing facility continues to fill new orders after the approved drug is removed from FDA's drug shortage list, or if it continues to fill existing orders more than 60 days after the drug has been removed.' The GLP-1 episode shows the effect: large-scale semaglutide and tirzepatide compounding depended on shortage status and ended after FDA resolved the shortages. A prescriber or compounder relying on a shortage should note on the prescription that the drug was on the list and the date checked.
FDA Standard MOU on interstate distribution of 503A compounded drugsThe October 2020 standard MOU is suspended after a 2021 court remand; FDA is not enforcing the statutory 5% out-of-state limit and plans a new rule, with a proposed rule projected for November 2026.
Section 503A limits a pharmacy in a state without an FDA MOU to distributing no more than 5% of its compounded prescriptions out of state. FDA published a final standard MOU in October 2020, but a federal court remanded it in September 2021. FDA 'considers the standard MOU published in October 2020 to be suspended' and, per its Oct 21, 2022 Federal Register notice, will not enforce the 5% limit until a final rule and updated MOU are published. The Fall 2025 Unified Agenda lists RIN 0910-AI71 ('Distribution of Compounded Drug Products Under Section 503A') at the proposed-rule stage with an NPRM projected for 11/2026. State nonresident-pharmacy licensing still applies (see state topics nonresident_pharmacy and fda_mou).
- Memorandum of Understanding Addressing Certain Distributions of Compounded Drugs — FDA, 2022-10-20
- Extension of the Period Before FDA Intends To Begin Enforcing the Statutory 5 Percent Limit on Out-of-State Distribution of Compounded Human Drug Products (87 FR, Oct 21, 2022) — Federal Register, 2022-10-21
- Unified Agenda, RIN 0910-AI71: Distribution of Compounded Drug Products Under Section 503A (Fall 2025) — OMB/OIRA, 2025-10-01
DEA telemedicine prescribing of controlled substances (Ryan Haight Act flexibilities)Through December 31, 2026, DEA-registered practitioners may prescribe Schedule II–V controlled substances by telemedicine without a prior in-person visit under a fourth temporary extension; the permanent special-registration rule is still pending.
The Ryan Haight Act generally requires an in-person medical evaluation before prescribing controlled substances over the internet. DEA and HHS published the Fourth Temporary Extension of COVID-19 Telemedicine Flexibilities (90 FR 61301, Dec 31, 2025), effective Jan 1 – Dec 31, 2026. Prescriptions must still be for a legitimate medical purpose and comply with federal and state law; state telehealth and controlled-substance rules still apply (see telehealth_rx, state_csr, pdmp_mandate). The separate buprenorphine (opioid use disorder) telemedicine final rule and the VA continuity-of-care final rule, both published Jan 17, 2025, took effect Dec 31, 2025 after two delays (90 FR 13410). A Federal Register search on 2026-09-23 found no DEA special-registration final rule published in 2026. The Special Registrations for Telemedicine final rule was reported to be in OMB review as of late August 2026, with a final rule forecast for November 2026. Without a new rule or another extension, the in-person requirement returns on Jan 1, 2027.
- Fourth Temporary Extension of COVID-19 Telemedicine Flexibilities for Prescription of Controlled Medications, 90 FR 61301 (Federal Register API record: effective Jan 1 – Dec 31, 2026) — DEA/HHS, Federal Register, 2025-12-31
- Fourth Temporary Extension of COVID-19 Telemedicine Flexibilities for Prescription of Controlled Medications (FR Doc. 2025-24123) — DEA/HHS, Federal Register, 2025-12-31
- Expansion of Buprenorphine Treatment via Telemedicine Encounter and Continuity of Care via Telemedicine for VA Patients — effective Dec 31, 2025, 90 FR 13410 (API record) — DEA/HHS, Federal Register, 2025-03-24
- DEA and HHS Extend Telemedicine Prescribing Flexibilities Through 2026 — Holland & Knight, 2026-01-13
- DEA Prescribing of Controlled Substances (tracker) — Alliance for Connected Care, 2026-08-26
- Expansion of Buprenorphine Treatment via Telemedicine Encounter and Continuity of Care via Telemedicine for VA Patients — delay of effective date (FR Doc. 2025-05007) — DEA/HHS, Federal Register, 2025-03-24
FTC health-claim substantiation (advertising)The FTC requires competent and reliable scientific evidence, generally randomized controlled human trials, before a marketer makes health-benefit claims for any health product, including devices, tests, supplements and apps.
The FTC's Health Products Compliance Guidance (Dec 2022) replaced the 1998 supplement advertising guide. Marketers must have substantiation for every objective claim, express or implied, before it runs; for health benefits this generally means randomized, controlled human clinical testing. Qualifying disclosures must be clear and conspicuous, and advertisers are liable for misleading testimonials and endorsements. This sits alongside FDA's rules: FDA regulates labeling and intended use, and FDA warning letters in 2025–2026 target 'same as brand' and 'FDA-approved' claims for compounded drugs.
- Health Products Compliance Guidance — Federal Trade Commission, 2022-12-01
- FDA to Telehealth Companies: What to Know When Promoting Compounded Drugs — FDA, 2026-06-15
Adverse event reporting (MedWatch; 503B mandatory reporting)Clinicians and patients can report problems with drugs, biologics, devices and cosmetics to FDA's MedWatch voluntarily; 503B outsourcing facilities must report adverse events, while 503A pharmacies are not federally required to.
MedWatch accepts voluntary reports for prescription and OTC drugs, biologics (including human cell and tissue products), medical devices, combination products and cosmetics. Manufacturers, packers and distributors named on a marketed prescription drug label must file 15-day 'Alert reports' for serious and unexpected adverse experiences under 21 CFR 310.305; FDA's final guidance (Oct 2015) applies adverse event reporting to 503B outsourcing facilities. FDA notes that federal law does not require state-licensed 503A pharmacies to report adverse events, so compounded-drug events are likely under-reported. Under MoCRA, cosmetic 'responsible persons' must report serious adverse events within 15 business days.
- MedWatch: The FDA Safety Information and Adverse Event Reporting Program — FDA, 2026-09-21
- Adverse Event Reporting for Outsourcing Facilities Under Section 503B — Guidance for Industry — FDA/CDER, 2015-10-01
- 21 CFR 310.305 — Records and reports concerning adverse drug experiences on marketed prescription drugs — eCFR, 2026-09-01
- Modernization of Cosmetics Regulation Act of 2022 (MoCRA) — FDA, 2026-08-10
Where FDA enforcement shows up: warning letters, import alerts, recallsFDA posts warning letters in a searchable database, detains risky imports through import alerts (e.g., 66-80 for GLP-1 APIs, 66-41 for unapproved drugs, 80-04 for gloves, 53-21 for adulterated cosmetics), and publishes recalls in its enforcement reports.
Import alerts let FDA detain products without physical examination. Import Alert 66-80 (GLP-1 receptor agonist bulk drug substances) detains semaglutide, tirzepatide, liraglutide, exenatide, orforglipron, retatrutide and dulaglutide APIs unless the manufacturer is on FDA's 'Green List'; FDA cited that 21% of inspected GLP-1 API makers were noncompliant with CGMP. Import Alert 66-41 covers unapproved new drugs promoted in the U.S. and has listed firms offering unapproved botulinum toxin and PT-141 peptide. Recalls, including Class I recalls of compounded glutathione in July–August 2026, appear in FDA enforcement reports and openFDA.
- FDA Warning Letters (searchable database) — FDA, 2026-09-23
- Import Alert 66-80: GLP-1 Receptor Agonist Bulk Drug Substances (Green List) — FDA, 2026-09-21
- Import Alert 66-41: Unapproved New Drugs Promoted in the U.S. — FDA, 2026-09-11
- openFDA drug enforcement (recall) query: sterile water / glutathione recalls 2023–2026 — FDA (openFDA), 2026-09-16
Compounded peptides: where things stand in September 2026FDA pulled 12 peptides out of Category 2 in April 2026 after nominators withdrew them, and its advisory committee voted in July 2026 to recommend six for the 503A bulks list, but none is on the list or in Category 1 yet, so none has federal compounding permission today.
On April 15, 2026 FDA announced that 12 peptides (BPC-157, cathelicidin LL-37, dihexa acetate, emideltide/DSIP, epitalon, GHK-Cu injectable, KPV, PEG-MGF, melanotan II, MOTs-C, Semax, TB-500) would leave Category 2 after seven days because their nominations were withdrawn; FDA's list shows the change effective April 22, 2026. Law-firm analyses stress that leaving Category 2 does not place a substance on the 503A bulks list or in Category 1. At the July 23–24, 2026 PCAC meeting, members voted to recommend BPC-157 (8–6), KPV (8–6), TB-500 (8–6), MOTs-C (7–5), epitalon (7–4) and Semax (8–5), and against emideltide (6–7); FDA staff had recommended against all of them. FDA must still decide and complete notice-and-comment rulemaking. GHK-Cu, dihexa, LL-37, PEG-MGF and melanotan II are slated for a PCAC meeting before the end of February 2027. Earlier, AOD-9604, CJC-1295, ipamorelin, thymosin alpha-1 and Selank left Category 2 in September 2024, and PCAC voted against CJC-1295 and AOD-9604 on Dec 4, 2024.
- Safety Risks Associated with Certain Bulk Drug Substances for Use in Compounding (Category 2; withdrawn list) — FDA, 2026-04-22
- July 23-24, 2026: Meeting of the Pharmacy Compounding Advisory Committee — FDA, 2026-08-06
- Bulk-list bound? PCAC backs majority of peptides in two-day public meeting — McDermott (law firm), 2026-07-27
- FDA Announces Removal of 12 Peptides from Category 2 and Schedules PCAC Meetings — Orrick, 2026-04-16
- FDA to Remove 12 Popular Peptides from the Category 2 'Do Not Compound' List — Frier Levitt, 2026-09-23
- Bulk Drug Substances Nominated for Use in Compounding Under Section 503A (Categories 1–3) — FDA, 2026-05-14
- Pharmacy Compounding Advisory Committee; Notice of Meeting (July 23–24, 2026; 503A bulks nominations), 91 FR 20465 — FDA, Federal Register, 2026-04-16
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Educational summaries of public law and agency guidance, not legal advice. Researched 2026-09-23 from the sources linked on each answer; laws, board rules and FDA policy change, so confirm with the linked agency or your counsel before you rely on an answer. Found something out of date? Tell our compliance desk.
