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.


Cosmeceutical & consumer skincare
FDA pathway: Cosmetic (MoCRA) | Drug if disease or structure/function claims | OTC monograph for sunscreen/acne actives
Cosmetics must be made in FDA-registered facilities and listed with FDA (enforced since July 1, 2024), have safety substantiation, and have serious adverse events reported within 15 business days; 'cosmeceutical' is not a legal category.
On MedGrid as: Cosmeceutical Skincare · Consumer Skincare · Consumer Take-Home · Medical-Grade Skincare · Post-Procedure Care
The federal rules
Facility registration and product listingExisting facilities had to register and products be listed by Dec 29, 2023; FDA did not enforce until July 1, 2024. Registrations renew every two years and listings update annually.
Submissions go through Cosmetics Direct (or ESG NextGen, or paper forms 5066/5067). Certain small businesses are exempt except for higher-risk products such as eye-area products and injectables.
Serious adverse event reporting and safety substantiationThe responsible person must report serious adverse events to FDA within 15 business days and keep records supporting adequate safety substantiation.
Animal testing is not mandated.
- Modernization of Cosmetics Regulation Act of 2022 (MoCRA) — FDA, 2026-08-10
Fragrance allergens, talc, PFAS, GMPFragrance-allergen labeling and cosmetic GMP rules are still pending (GMP has a draft guidance); FDA withdrew its Dec 2024 proposed talc asbestos-testing rule in Nov 2025; FDA published its PFAS-in-cosmetics report Dec 29, 2025.
FDA's MoCRA page (08/10/2026) lists fragrance allergen labeling as a required regulation but links no proposed or final rule.
- Modernization of Cosmetics Regulation Act of 2022 (MoCRA) — FDA, 2026-08-10
Drug vs cosmetic claimsIntended use decides: claims to treat acne, dandruff or psoriasis, remove wrinkles, promote cell regeneration, or reduce cellulite make a product a drug; FDA says the law 'does not recognize any such category as cosmeceuticals'.
Products can be both (e.g., moisturizer with sunscreen) and must meet both sets of rules.
- Is It a Cosmetic, a Drug, or Both? (Or Is It Soap?) — FDA, 2024-09-11
Imported cosmeticsImport Alert 53-21 allows detention of adulterated cosmetic products and ingredients (revised Mar 5, 2026).
Other cosmetic import alerts cover color additive violations and microbial contamination.
- Import Alert 53-21 — FDA, 2026-03-05
Changing now
- Proposed rules on fragrance allergen labeling and cosmetic GMP. — MoCRA
- FDA draft guidance on its MoCRA records-access authority for cosmetics (Jan 22, 2026). — FDA Records Access Authority for Cosmetics; Draft Guidance, 91 FR 2779
What Nevada adds
State rules for cosmetics and sunscreenNevada prohibits importing or selling cosmetics tested on animals (NRS 598.993); no PFAS-in-cosmetics or sunscreen law was found.State cosmetic/sunscreen rules
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?
NRS 598.993 prohibits the import, sale or offer for sale of cosmetic products tested on animals, subject to exceptions, and makes a violation a deceptive trade practice. Nevada does not appear on 2026 lists of states with PFAS-in-cosmetics laws.
The effective date was not shown on the statute index reviewed. Federal MoCRA and FDA cosmetic and OTC sunscreen rules apply in every state.
NRS 598.993
- NRS Chapter 598 (NRS 598.993 — prohibition on import or sale of cosmetics tested on animals) — Nevada Legislature, 2026-09-23
- Testing cosmetics on animals (US state bans 'as of 2023') — Wikipedia, 2026-09-23
- PFAS in Cosmetics: US State Bans and Compliance Deadlines - 2026 Update — Adherent (formerly Compliance & Risks), 2026-03-13
Compare every state: State rules for cosmetics and sunscreen
Nevada at a glance
Every topic we research, for Nevada. Open any line for the rule, its citation and the source.
Pharmacy & compounding
Out-of-state pharmacies shipping into the stateEvery pharmacy outside Nevada that dispenses prescriptions to Nevada patients must be licensed by the Nevada State Board of Pharmacy and have a Nevada-registered pharmacist responsible for those prescriptions.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?
NRS 639.2328 requires a Board license for every pharmacy outside Nevada that dispenses prescriptions to patients in Nevada, including anyone selling drugs to Nevadans over the internet (NRS 639.23279). The applicant must be licensed in its home state and prove that its facility, records and operations comply with home-state law. It must name its managing pharmacist and at least one Nevada-registered pharmacist at the pharmacy who is responsible for every prescription sent to Nevada. The Board may require its own inspection (NRS 639.2328(3); 639.23284), and internet pharmacies also need Board certification (NRS 639.23288). A toll-free pharmacist line must run at least 5 days and 40 hours a week (NRS 639.23286). On the Board's pharmacy application, out-of-state applicants file their latest home-state inspection and a license verification. A pharmacy that does not do sterile compounding signs an affidavit that it will not ship sterile compounds into Nevada without written Board approval. Applicants shipping compounded parenteral products into Nevada may have to appear before the Board (NAC 639.215).
NRS 639.2328 was last amended in 2023. 'Registered pharmacist' means a pharmacist registered with the Nevada Board (NRS 639.015). The Board's application asks for the managing pharmacist's Nevada registration number only 'if applicable', but it requires at least one Nevada-registered pharmacist responsible for Nevada prescriptions. Licenses renew in October of even-numbered years. Applications are approved at Board meetings, and an appearance may be required.
NRS 639.23279; NRS 639.2328; NRS 639.23284; NRS 639.23286; NRS 639.23288; NRS 639.015; NAC 639.215
- NRS Chapter 639 — Pharmacy (NRS 639.2328 to 639.23288; 639.015) — Nevada Legislature, 2026-09-23
- NAC Chapter 639 — Pharmacy (NAC 639.215) — Nevada Legislature (Nevada Administrative Code), 2026-09-23
- Pharmacy Application (Rev 06/11/2024) — Nevada State Board of Pharmacy, 2024-06-11
Office-use compounding from 503A pharmaciesNevada does not let 503A pharmacies sell compounded drugs to practitioners for office stock; practitioners may buy compounded drugs directly from outsourcing facilities instead.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.
Under NAC 639.757(1), a pharmacy may compound without a manufacturer license only if the drugs are dispensed on a prescription or chart order and are not sold or provided to anyone other than the ultimate user or that user's agent. Quantities are limited to what fills current orders or what past patterns show will be needed. In a June 2, 2025 notice on compounded GLP-1s, the Board 'reminds 503A pharmacies that they are not permitted to sell compounded medications to practitioners.' It also cited the compounding rules as amended by LCB File R053-24 (effective Nov. 15, 2024). By contrast, NRS 639.268(2) lets practitioners and other authorized dispensers buy compounded drugs directly from an outsourcing facility without a patient-specific order. This matches FDA's view that office stock comes from 503B facilities.
The Board's June 2025 notice also told licensees to stop compounding tirzepatide and semaglutide injection products under FDA's shortage-resolution orders (503B semaglutide after May 22, 2025). It warned that wholesaling or distributing restricted drugs in Nevada without a license violates NRS 639.100, 639.233 and related rules.
NAC 639.757(1); NRS 639.268(2), (8); Nevada State Board of Pharmacy notice of June 2, 2025
- NAC 639.757 — Preparation and sale of compounded drugs by pharmacy, pharmacist or dispensing practitioner — Nevada Legislature (Nevada Administrative Code), 2024-11-15
- Notice of FDA's Declaratory Orders Resolving Shortages of Tirzepatide and Semaglutide Injection Products — Nevada State Board of Pharmacy, 2025-06-02
- NRS 639.268 — Purchase by practitioner; acquisition of drugs directly from outsourcing facility — Nevada Legislature, 2026-09-23
503B outsourcing facilities shipping into the stateAn out-of-state outsourcing facility shipping into Nevada must be licensed by the Nevada Board of Pharmacy (as a manufacturer, via the Board's Out-of-State Outsourcing Facility application) with a Nevada-licensed supervising pharmacist.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?
NAC 639.6915 requires an outsourcing facility that compounds sterile drugs in Nevada or for shipment into Nevada to get a Board license as a manufacturer under NRS 639.100 and 639.233 and to meet 21 U.S.C. §353b. NRS 639.100(3) bars anyone from acting as a manufacturer without a Board license. The Board's Out-of-State Outsourcing Facility application requires the following: a $500 fee, a letter of good standing, the home-state license, recent state and FDA inspections, a DEA registration if applicable, Board approval at a meeting where an appearance is required, and a supervising pharmacist licensed by the Nevada Board. Under NAC 639.6916, an outsourcing facility does not need a pharmacy license unless it dispenses patient-specific prescriptions; then it needs a pharmacy license under NRS 639.230 or 639.2328.
NAC 639.6915 was last amended by R025-21, effective 4/11/2022. NAC 639.6912 defines an outsourcing facility as a sterile compounder. NRS 639.268(8), amended in 2023, defines one as a manufacturer compounding sterile or nonsterile drugs. The Board's application form is undated. Licenses renew in October of even-numbered years.
NAC 639.6912; NAC 639.6915; NAC 639.6916; NRS 639.100(3); NRS 639.233; NRS 639.268(8)
- NAC 639.691–639.6916 — Outsourcing facilities — Nevada Legislature (Nevada Administrative Code), 2022-04-11
- Application for Out-of-State Outsourcing Facility License — Information and Checklist — Nevada State Board of Pharmacy, 2026-09-23
- NRS Chapter 639 — Pharmacy (NRS 639.100; 639.268) — Nevada Legislature, 2026-09-23
FDA compounding MOUNevada 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; Nevada 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 registrationNevada requires every practitioner who prescribes, administers or dispenses controlled substances to hold a Nevada State Board of Pharmacy controlled substance registration, obtained before applying for DEA.State CS registration required
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.
NRS 453.226 requires every practitioner who dispenses controlled substances in Nevada to obtain a biennial registration from the State Board of Pharmacy, and NRS 453.056 defines 'dispense' to include prescribing and administering; the Board's application warns that dispensing, prescribing or administering without it is a category D felony (NRS 453.232). The Board's physician application (fee $200, rev. 01/05/2023) requires steps in order: Nevada PMP account, then the state CS registration, then DEA, and says an active state CS registration is required to complete the DEA application; registrations expire October 31 of even-numbered years. A separate registration is required at each principal place of business or professional practice where the practitioner dispenses (NRS 453.226(5)). Practitioners who dispense drugs from an office for a charge also need a Board Dispensing Practitioner registration ($300, per office, inspection required; NRS 639.23505, NAC 639.742-639.745).
Statute text is current; the fee and step order come from application forms revised 2023-01-05 and 2022-06-16 (older than 2 years - fees possibly stale). NP/PA: APRNs need a Board certificate of registration to prescribe (NRS 639.2351) and a separate one to dispense (NRS 639.1375); PAs use a separate 'PA Prescribe and CS Registration' application. Narrow exception in NRS 453.226(3)(d) for locum tenens/temporary-licensed physicians registered with DEA outside Nevada.
NRS 453.226; NRS 453.056; NRS 453.232; NRS 639.23505; NRS 639.2351; NRS 639.1375; NAC 639.742-639.745
- NRS Chapter 453 - Controlled Substances (NRS 453.056, 453.226) — Nevada Legislature, 2026-09-23
- NRS Chapter 639 - Pharmacists and Pharmacy (NRS 639.23505, 639.2351, 639.1375) — Nevada Legislature, 2026-09-23
- Controlled Substance Application (Rev 01/05/2023) — Nevada State Board of Pharmacy, 2023-01-05
- Dispensing Practitioner Registration Application (Rev 06/16/2022) — Nevada State Board of Pharmacy, 2022-06-16
- New Applications - Practitioners — Nevada State Board of Pharmacy, 2026-09-23
PDMP check before prescribingNevada requires a PMP patient utilization report before an initial prescription for any Schedule II, III or IV controlled substance (and Schedule V opioids) and at least every 90 days during the course of treatment, which covers testosterone.Check required (covers C-III)
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.
NRS 639.23507(1) requires every practitioner other than a veterinarian, before issuing an initial prescription for a Schedule II, III or IV controlled substance or a Schedule V opioid, and at least once every 90 days thereafter for the duration of the course of treatment, to obtain and review a patient utilization report and check for duplicate ongoing prescriptions. Under subsection 2 a practitioner may skip the advance check for patients with cancer or sickle cell disease or in hospice or palliative care if it would unreasonably delay care, but must obtain the report as soon as practicable. A documented failed attempt when the system is unavailable counts as compliance, and the Board of Pharmacy must set alternative compliance methods for hospital emergency departments. The PMP is run by the Nevada State Board of Pharmacy with the Department of Public Safety.
Last amended 2019 (Stats. 2019 p. 2136) per the NRS history note. The statute is framed around issuing prescriptions; PDMP TTAC also lists NRS 453.164 and NRS 631.045 (dentists). Testosterone (Schedule III) is caught at the initial prescription and every 90 days.
NRS 639.23507
- NRS Chapter 639 - Pharmacists and Pharmacy, NRS 639.23507 — Nevada Legislature, 2026-09-23
Physicians dispensing from the officeNevada practitioners who charge for dispensed controlled substances or dangerous drugs need a Board of Pharmacy dispensing certificate and must issue a written prescription.Allowed with permit or limits
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.
NRS 639.23505 bars a practitioner from dispensing any controlled substance or dangerous drug for human use while charging the patient for it unless the practitioner first obtains a certificate from the Nevada State Board of Pharmacy, pays the fee and issues a written prescription. In Nevada 'dangerous drug' covers prescription drugs generally, so the certificate effectively applies to all paid dispensing. A vendor summary reports a $300 fee and separate permits for APRNs and PAs.
Fee and separate APRN/PA permits from a vendor summary.
NRS 639.23505
- NRS Chapter 639 - Pharmacists and Pharmacy (NRS 639.23505) — Nevada Legislature, 2026-09-23
- Nevada Board of Pharmacy - Practitioner applications — Nevada State Board of Pharmacy, 2026-09-23
Prescribing by telehealthNevada requires a Nevada license to prescribe by telehealth but offers a telemedicine license to board-certified out-of-state physicians; there is no general in-person exam rule, and pain-specific rules apply to Schedule II-IV.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.
(1) Before prescribing by telehealth to a patient in Nevada, a provider must hold a Nevada license, which may be a telemedicine license under NRS 630.261 (requires a full unrestricted license in another state, no prior discipline and ABMS specialty certification); telehealth providers are subject to Nevada law and board jurisdiction. (2) A relationship may be established by telehealth when clinically appropriate, so no in-person exam is required by statute. (3) For Schedule II-IV drugs prescribed for pain, Nevada requires a bona fide relationship, risk assessment, treatment plan and informed consent, and a meeting in person or by telehealth before further dose increases and at 90 days of continuous use (NRS 639.23911, 639.23913, per CCHP); these do not bar telehealth prescribing of testosterone for non-pain indications. (4) IMLC: member.
NRS 629.515 last amended 2025 and NRS 630.261 last amended 2025 (2025 Statutes). NRS 639.235 requires a Nevada pharmacist filling a Schedule II-IV prescription from a prescriber not licensed in Nevada to confirm a bona fide relationship (exam in person or by telehealth within the prior 6 months). The pain-treatment provisions (NRS 639.23911/.23913) were read via CCHP, not verified line by line. Osteopathic physicians are licensed separately under NRS chapter 633.
NRS 629.515; NRS 630.261(1)(c), (2); NRS 639.235(4); NRS 639.23911; NRS 639.23913
- NRS Chapter 629 - Healing Arts Generally (NRS 629.515) — Nevada Legislature, 2026-09-23
- NRS Chapter 630 - Physicians (NRS 630.261 telemedicine license) — Nevada Legislature, 2026-09-23
- NRS Chapter 639 - Pharmacists and Pharmacy (NRS 639.235) — Nevada Legislature, 2026-09-23
- CCHP - Nevada telehealth policy (Professional Requirements) — Center for Connected Health Policy, 2026-08-24
- 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 fillersNevada RNs (not LPNs) may inject neuromodulators and fillers only on an individual order from a practitioner who assessed the patient, with documented training; fillers in the under-eye, nasal, jawline and temporal zones need the provider physically present.RNs may inject with added conditions
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 Nevada State Board of Nursing's practice decision on aesthetic/cosmetologic procedures (approved 2025-01-17) requires completion of an instructional program with a supervised practicum and demonstrated proficiency for each procedure, facility protocols approved by a qualified practitioner, informed consent, and an order for each individual intervention by a practitioner who has assessed the patient and established a bona fide relationship. Only the practitioner may control access to the drugs. In its Level III grid, neuromodulators and fillers (other than the under-eye, nasal, jawline and temporal zones) are within RN scope under direct supervision (NAC 632.048: the provider is periodically on site or available for immediate guidance). Fillers in the under-eye, nasal, jawline and temporal zones are within RN scope only under immediate supervision (NAC 632.059: the provider is physically present, directly observing or assisting). Biostimulators such as Sculptra in the temporal, mid-face and high-cheek areas are listed under direct supervision. None of these injectables is within LPN scope. APRNs with independent practice authority who meet training rules may inject without supervision.
Grid read from the board's PDF (Level III Advanced Procedures, Cosmetic Injectables) on 2026-09-23. Check the PDF for threads and other biostimulator rows before relying on them.
Nevada State Board of Nursing Practice Advisory Decision 'Scope of Practice Requirements and Limitations for RNs and LPNs Performing Aesthetic/Cosmetologic Procedures' (Board approved 2025-01-17); NAC 632.220, 632.225, 632.255; NRS 639.235, 454.213
- Practice Advisory Decision: Aesthetic/Cosmetologic Procedures — Nevada State Board of Nursing, 2025-01-17
IV hydration and vitamin therapyNevada lets RNs, and IV-certified LPNs, give IV hydration outside hospitals only on an order from a practitioner who assessed the patient beforehand; only the practitioner controls access to the fluids and drugs, and nurses may carry only what was ordered for that patient.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 Board of Nursing's practice decision on out-of-hospital administration of IV solutions and medications (approved 2020-11-18; re-approved 2025-03-19) requires an order from a qualified licensed practitioner who has assessed the patient before ordering. Only that practitioner may control and provide access to IV solutions and medications; after the order, the nurse may remove and possess only the specific items ordered for that patient and is responsible for transporting them per manufacturer guidelines, which bears on mobile IV services. The nurse must keep a patient record with the practitioner's and nurse's assessments and orders and check for contraindications; LPNs must meet the IV course requirements in NAC 632.475.
Nevada State Board of Nursing Practice Decision 'RN & LPN Scope in Out of Hospital Administration of IV Solutions and Medications' (approved 2025-03-19); NAC 632.220, 632.475; NRS 454.213, 454.316
- Practice Decision: RN & LPN Scope in Out of Hospital Administration of IV Solutions and Medications — Nevada State Board of Nursing, 2025-03-19
Corporate practice of medicine / med spa ownershipCompilations rate Nevada a strict corporate practice of medicine state based on its professional corporation law and a 2002 Attorney General opinion.Strong CPOM
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's 2025 guide classifies Nevada as strict, citing NRS 89.040 and 89.050 and Attorney General Opinion No. 2002-10; MedPath Compliance (reviewed 2026-06-20) also rates Nevada strict. Med spas therefore generally hold medical services in physician-owned professional entities managed by an MSO.
The nursing board's aesthetic decision also references licensed cosmetological establishments (NRS 644A) as possible settings.
NRS 89.040, 89.050; Nev. Att'y Gen. Op. No. 2002-10 (as reported by Permit Health)
- The Corporate Practice of Medicine 50-State Guide — Permit Health, 2025-12-23
- Corporate Practice of Medicine (CPOM) Across the 50 States and D.C. — MedPath Compliance Group, 2026-06-20
Who may operate aesthetic lasersNevada's Board of Nursing lets RNs and LPNs perform non-ablative laser hair removal and skin treatments and IPL with laser certification, a practitioner's order and provider availability; fractional ablative lasers need immediate on-site supervision for RNs, and fully ablative resurfacing is outside nursing scope.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?
In the Board of Nursing's 2025 aesthetic practice decision, Level II procedures (non-ablative laser hair removal, non-ablative skin treatment, IPL, HIFU) require a practitioner's order, informed consent, FDA-labeled equipment approved by the medical director, and 'laser certification and licensure for nurses, cosmetologists and aestheticians', with the provider available for direct supervision. Fractional ablative lasers are listed for RNs with immediate supervision (provider physically present) and not for LPNs; total ablative resurfacing and vaginal rejuvenation are not within nursing scope. The Board of Medical Examiners' advisory opinions page listed no laser opinion on 2026-09-23.
The 'laser certification' referenced is not defined in the fetched text. Rules for estheticians/cosmetologists under NRS 644A were not reviewed.
Nevada State Board of Nursing Practice Advisory Decision on Aesthetic/Cosmetologic Procedures (2025-01-17)
- Practice Advisory Decision: Aesthetic/Cosmetologic Procedures — Nevada State Board of Nursing, 2025-01-17
Labs, regenerative medicine & cosmetics
State clinical laboratory licensing (beyond CLIA)Nevada licenses medical laboratories in the state and may require out-of-state labs to be licensed before they test Nevada specimens.State lab license required
Does the state license clinical laboratories itself, beyond federal CLIA certification, including out-of-state labs that test specimens from the state?
NRS 652.080 bars operating, conducting or issuing a report from a medical laboratory without a Nevada license, and lets the state 'require a laboratory that is located outside of this state to be licensed' before it examines specimens collected in Nevada. Out-of-state licensure is therefore at the Division's discretion. Nevada also licenses laboratory directors and technical personnel (NRS 652.125).
Out-of-state labs: discretionary, so confirm with the Bureau of Health Care Quality & Compliance (nvhaclialab@nvha.nv.gov).
NRS 652.080; NRS 652.125
- NRS Chapter 652 — Medical Laboratories (incl. NRS 652.080, 652.125, 652.190) — Nevada Legislature, 2026-09-23
- CLIA State Agency Contacts (updated May 2026) — Centers for Medicare & Medicaid Services, 2026-05-01
- Personnel Licensure (states with clinical laboratory personnel licensure) — American Society for Clinical Laboratory Science, 2026-09-23
Direct-to-consumer lab testingNevada lets anyone order a test only when it uses an FDA-approved home-use kit available without a prescription; other tests need an order from a physician or other authorized person.Limited tests or labs only
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.
NRS 652.190 allows labs to examine specimens only at the request of licensed physicians or other persons authorized by law to use the findings, or at the request of 'any person' when the test uses a testing device or kit 'approved by the Food and Drug Administration for use in the home and which is available to the public without a prescription.' Nevada also licenses labs (NRS 652.080).
NRS 652.190
- NRS Chapter 652 — Medical Laboratories (incl. NRS 652.080, 652.125, 652.190) — Nevada Legislature, 2026-09-23
State laws on stem cell / regenerative therapiesNevada has a long-standing statute letting licensed providers administer, compound and import products containing 'nonembryonic cells' (autologous or allogeneic, including stem cells), expressly without deciding their federal status.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)?
NRS 629.300-629.390 define 'nonembryonic cells' as autologous or allogeneic cellular material, including stem cells and immune cells, not obtained directly from human embryos. They authorize cell or tissue banks (NRS 629.360), administration by the person or by a licensed provider acting within the license (NRS 629.370), compounding (NRS 629.380), and importation and administration of such products (NRS 629.390). NRS 629.350 says the provisions do not indicate the activities' status under federal law. Separately, a 2023 Nevada law allows 'individualized investigational treatments' (e.g., gene therapies, ASOs). A 2025 bill (SB 128) encouraging clinicians to discuss stem cell therapy with arthritis patients was vetoed on June 10, 2025. 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.
Enactment year not confirmed here (one compilation lists 2009). Nevada's state law does not override FDA requirements (NRS 629.350).
NRS 629.300-629.390
- NRS 629.300-629.390 — Nonembryonic Cells — Nevada.Public.Law (Nevada Revised Statutes), 2025-05-26
- Governor's veto message, Senate Bill 128 (83rd Session) — Office of the Governor of Nevada, 2025-06-10
- Another state challenges FDA on biologics as Nevada OKs risky, unproven oligo, gene, & other therapies — The Niche (Paul Knoepfler), 2024-07-15
- State Stem Cell Laws: Accurate 2026 Map Update (lists 12 states with statutes; commercial source) — SaveMyFat, 2026-08-06
State rules for cosmetics and sunscreenNevada prohibits importing or selling cosmetics tested on animals (NRS 598.993); no PFAS-in-cosmetics or sunscreen law was found.State cosmetic/sunscreen rules
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?
NRS 598.993 prohibits the import, sale or offer for sale of cosmetic products tested on animals, subject to exceptions, and makes a violation a deceptive trade practice. Nevada does not appear on 2026 lists of states with PFAS-in-cosmetics laws.
The effective date was not shown on the statute index reviewed. Federal MoCRA and FDA cosmetic and OTC sunscreen rules apply in every state.
NRS 598.993
- NRS Chapter 598 (NRS 598.993 — prohibition on import or sale of cosmetics tested on animals) — Nevada Legislature, 2026-09-23
- Testing cosmetics on animals (US state bans 'as of 2023') — Wikipedia, 2026-09-23
- PFAS in Cosmetics: US State Bans and Compliance Deadlines - 2026 Update — Adherent (formerly Compliance & Risks), 2026-03-13
Compare every state
PDMP check before prescribing. 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.
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.
