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.


FDA records for “laser hair removal”
Searching FDA approvals, shortages, recalls and device records…
Wound care & dressings
FDA pathway: Device class I/II/unclassified | Drug | HCT/P 361 or Biologic (BLA)
Plain dressings are mostly Class I exempt devices; dressings with drugs, biologics or animal-derived materials need FDA clearance; amniotic/placental products qualify as 361 HCT/Ps only if minimally manipulated and used homologously.
On MedGrid as: Wound Care & Dressings · Wound Care & Hemostatics
The federal rules
Basic dressings are Class I, exemptHydrophilic (21 CFR 878.4018) and occlusive (878.4020) wound dressings are Class I and exempt from 510(k), but these classifications exclude dressings with added drugs, biologics or animal-derived materials.
Liquid bandages (880.5090) are also Class I.
- 21 CFR 878.4018 — Hydrophilic wound dressing — eCFR, 2026-09-01
- 21 CFR 878.4020 — Occlusive wound dressing — eCFR, 2026-09-01
Drug-containing and animal-derived dressings need 510(k)FDA product codes FRO (dressing, wound, drug) and KGN (wound dressing with animal-derived materials) are unclassified and reviewed through 510(k).
Check the product code and 510(k) number before buying.
- openFDA device classification: FRO, KGN, NAC, MGP — FDA (openFDA), 2026-09-23
Amniotic membrane and other tissue products (361 vs 351)An HCT/P is regulated only as a 361 tissue if it is minimally manipulated, for homologous use, not combined with other articles, and (generally) has no systemic effect; otherwise it needs a BLA or IND.
FDA's July 2020 guidance examples: amniotic membrane ground and lyophilized into particles is more than minimally manipulated; an amniotic membrane product used 'for wound healing and/or to reduce scarring and inflammation' is not homologous use; amniotic membrane covering the eye surface is homologous. Establishments must register and list HCT/Ps.
- 21 CFR 1271.10 — criteria for regulation solely under section 361 — eCFR, 2026-09-01
- Regulatory Considerations for HCT/Ps: Minimal Manipulation and Homologous Use (July 2020) — FDA (CBER/CDRH), 2020-07-01
Unapproved amniotic products marketed for injection draw FDA lettersFDA's March 12, 2024 untitled letter to Amnion Florida said injected amniotic membrane/fluid products marketed for conditions such as arthritis and tendinopathy are drugs and biological products.
See cellular-biologics category.
- Untitled Letter — Amnion Florida, LLC — FDA/CBER, 2024-03-12
Changing now
- FDA untitled/warning letters on amniotic and placental products continue; check CBER's list. — CBER Untitled Letters (BIMO/Team Biologics/Internet Surveillance/Other)
What South Carolina adds
Physicians dispensing from the officeSouth Carolina reportedly lets physicians dispense without a permit from sites they own, but requires a dispensing permit for sites they do not wholly own.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.
A vendor summary reports that South Carolina physicians may dispense to their patients, that a dispensing permit is required for 'non-owned' sites (not directly and wholly owned by the dispensing practitioner, which catches many employed and group physicians), and that controlled substances require the state controlled substance registration. The statute and rule text were not reviewed.
Confirm with the South Carolina Board of Pharmacy (LLR).
South Carolina Pharmacy Practice Act (non-owned site permit) - not verified
- South Carolina Physician Dispensing Laws & Regulations — PharmaLink (vendor summary), 2026-09-23
State laws on stem cell / regenerative therapiesNo South Carolina law specific to stem cell, exosome or regenerative therapies was found, so FDA rules and general medical-practice rules apply.No state-specific law (FDA rules apply)
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)?
Compilations of state stem-cell laws from 2024 to 2026 list about a dozen states with specific laws (California, Florida, Georgia, Mississippi, Nevada, North Carolina, Tennessee, Texas, Utah, Vermont, Washington and Wyoming), plus Montana's general experimental-treatment law and Kansas's state stem cell center. South Carolina is not among them. Without a state-specific law, regenerative products are governed by federal FDA rules plus the state's general medical practice, advertising and consumer-protection laws, enforced by its medical board. 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.
The finding of no law rests on multi-state compilations (a commercial one from Aug 2026 and a peer-reviewed one from Feb 2024, which is older than 2 years) and targeted searches, not a statute-by-statute review, and neither compilation is exhaustive. General Right to Try laws for terminal patients, where they exist, were not reviewed here.
None found
- State Stem Cell Laws: Accurate 2026 Map Update (lists 12 states with statutes; commercial source) — SaveMyFat, 2026-08-06
- U.S. State Laws on Medical Freedom and Investigational Stem Cell Procedures: A call to focus on state-based legislation (Cytotherapy) — Cytotherapy / PubMed Central, 2024-02-03
Compare every state: Physicians dispensing from the office · State laws on stem cell / regenerative therapies
South Carolina at a glance
Every topic we research, for South Carolina. 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 needs a South Carolina Non-Resident Pharmacy Permit before it dispenses prescription drugs to patients in South Carolina.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?
S.C. Code §40-43-83 requires a Board of Pharmacy permit for out-of-state facilities that sell, distribute or dispense prescription drugs in South Carolina, and requires any out-of-state pharmacy shipping into the state to designate a registered agent. Board Regulation 99-43(B)(2) states that a pharmacy located outside South Carolina must obtain a Non-Resident Pharmacy Permit to dispense legend drugs or devices to a patient (or patient's agent) in the state. The application requires the resident-state permit and DEA registration, every operational inspection report from the last two years, current accreditations, a refrigerated-shipping policy, a sample label, photographs and an ownership chart. A pharmacy that compounds (sterile or non-sterile) must also file compounding training records, environmental and cleaning logs, formulas for its top five compounds, policies, and its latest hood/cleanroom certification, even if it is not yet shipping compounds into South Carolina. Instead of an in-person inspection, a pharmacist or knowledgeable person must appear before the Board or its committee. There is no separate nonresident sterile-compounding permit.
The statute's wording covers out-of-state facilities 'whose primary business is mail order pharmacy service', but §40-43-83(I) and R.99-43(B)(2) apply to any out-of-state pharmacy dispensing to South Carolina patients. Permits expire annually. The application form (rev. 1/20) charges a $420 fee, requires the PIC to attend an Application Review Committee meeting, and requires an inspection report dated after the application. Nonresident pharmacies dispensing controlled substances also need a South Carolina Controlled Substances Registration, and every permitted nonresident pharmacy must register with the South Carolina PMP or obtain an exemption. R.99-43 was amended effective May 22, 2026 (SCSR 50-5, Doc. No. 5422), and the nonresident-pharmacy text in that notice matches the prior version.
S.C. Code Ann. §40-43-83(A), (B), (I); S.C. Code Ann. Regs. 99-43(B)(2)
- S.C. Code Title 40, Chapter 43 (Pharmacy Practice Act), §40-43-83 — South Carolina Legislature, 2026-09-23
- S.C. Code Regs. Chapter 99 (State Board of Pharmacy), R.99-43 Facility Permit Classifications — South Carolina Legislature, 2025-05-23
- South Carolina State Register Vol. 50, Issue 5, Final Regulations, Document No. 5422 (R.99-43, R.99-48) — South Carolina Legislative Council, 2026-05-22
- Non-Resident Pharmacy Permit Application (form rev. 1/20) — South Carolina Board of Pharmacy (SC LLR), 2026-09-23
Office-use compounding from 503A pharmaciesSouth Carolina law lets physicians buy compounded medications from a compounding pharmacy to keep and administer in the office or ambulatory surgery center, but not to resell.Allowed with limits
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.
S.C. Code §40-43-86(CC)(2)(f) allows pharmacists to compound on a practitioner's order for administration to patients in institutional or office settings, and bars offering compounds to other pharmacies for resale. Under §40-43-86(CC)(2)(h), physicians who administer compounded medications in an office or licensed ambulatory surgical facility may order and purchase them from the compounding pharmacy and store them for future use but not for resale. No individual-patient prescription is needed for each administration. Compounding in anticipation of prescriptions without a historical basis, or distributing without a patient/practitioner/pharmacist relationship, counts as manufacturing (§40-43-86(CC)(2)(g)). Institutional pharmacies may order and stock sterile and nonsterile compounds, with a chart order needed for each administration ((CC)(2)(i)). The Board of Pharmacy enforces these rules. This state allowance is broader than FDA's view that 503A compounding requires patient-specific prescriptions.
Subsection (CC)(1) says it applies to compounding by 'pharmacies permitted in the State of South Carolina'. The text does not say whether an out-of-state pharmacy holding a South Carolina Non-Resident Pharmacy Permit may ship office-use stock, and R.99-43(B)(2) frames that permit around dispensing to patients. Paragraph (h) refers to 'physicians', while (f) refers to 'practitioners'. §40-43-86 was last amended by 2024 Act No. 132 (eff. May 13, 2024). New R.99-48 (eff. May 22, 2026) sets interim compounding standards (the Board inspection forms in use on July 2, 2024) until permanent compounding regulations are adopted, and it does not change the office-use provisions.
S.C. Code Ann. §40-43-86(CC)(1), (CC)(2)(f)-(i)
- S.C. Code Title 40, Chapter 43, §40-43-86(CC) compounding — South Carolina Legislature, 2026-09-23
- South Carolina State Register Vol. 50, Issue 5, Document No. 5422 (new R.99-48 Compounding Generally) — South Carolina Legislative Council, 2026-05-22
503B outsourcing facilities shipping into the stateAn out-of-state 503B outsourcing facility needs a South Carolina Outsourcing Facility Permit, with a South Carolina-licensed pharmacist-in-charge, to distribute non-patient-specific compounded products in the state.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?
Amended R.99-43(D) (effective May 22, 2026) requires an Outsourcing Facility Permit for any compounding facility that sells, dispenses, transfers or distributes non-patient-specific compounded products in South Carolina, and the facility must be FDA-registered under 503B and follow cGMP. Every applicant must name a pharmacist-in-charge with an active South Carolina pharmacist license and submit policies on cold-chain shipping, temperature and humidity, QC/QA, recalls, complaints, training, aseptic process validation, and environmental and personnel monitoring. Out-of-state applicants must also submit their resident-state outsourcing permit, DEA registration, other state permits, and the most recent FDA establishment inspection report (with any 483s, responses and warning letters). They must also submit all operational inspection reports from the last two years, one showing at least six months of operation. A facility that dispenses patient-specific prescriptions into South Carolina must also hold a South Carolina pharmacy permit. The PIC must report discipline, 483s or warning letters, and recalls to the Board within 30 days.
2024 Act No. 132 (H.3592) defined 'outsourcing facility', added §40-43-197 (practitioners may buy directly from outsourcing facilities without patient orders), and directed the Board to write outsourcing regulations; the amended R.99-43(D) followed in May 2026. The earlier R.99-43(D) and the Board's Non-Resident Outsourcing Facility application (09/29/2023 v1, $700 fee, Application Review Committee appearance) required the facility to hold or concurrently apply for a South Carolina pharmacy or wholesale distributor permit. The 2026 text keeps that only for patient-specific dispensing, so confirm current forms with the Board. A secondary source (Lighthouse, 2026-07-07) says the PIC must also be the PIC in the resident state and that existing permittees have until the June 30, 2027 renewal to comply; this was not found in the State Register text reviewed. Amended R.99-43(D)(5) requires outsourced products to come from South Carolina-permitted facilities and bars redistribution by anyone other than the compounding outsourcing facility. The Board's 2026 regulation-update PDF is a scanned image and could not be text-verified.
S.C. Code Ann. §40-43-30(39); §40-43-83(I); §40-43-197; S.C. Code Ann. Regs. 99-43(D) (as amended by SCSR 50-5, Doc. No. 5422)
- South Carolina State Register Vol. 50, Issue 5, Final Regulations, Document No. 5422, R.99-43(D) Outsourcing Facility (503B) Permit — South Carolina Legislative Council, 2026-05-22
- S.C. Code Title 40, Chapter 43 (§§40-43-30(39), 40-43-83, 40-43-197) — South Carolina Legislature, 2026-09-23
- Non-Resident Outsourcing Facility Permit Application (09/29/2023 v1) — South Carolina Board of Pharmacy (SC LLR), 2023-09-29
- Board of Pharmacy Laws and Regulations page ('Updated regulations for Outsourcing (503B) facilities, as of May 2026') — South Carolina Board of Pharmacy (SC LLR), 2026-09-23
- South Carolina 503B Outsourcing Facility Licensing: New Pharmacist-in-Charge Requirement Effective 2026 — Lighthouse (secondary), 2026-07-07
FDA compounding MOUSouth Carolina 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; South Carolina 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 registrationSouth Carolina requires practitioners, including APRNs and PAs, to hold a South Carolina Controlled Substances Registration from the Department of Public Health's Bureau of Drug Control before prescribing, administering or dispensing controlled substances.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.
S.C. Code 44-53-290 requires every person who dispenses controlled substances to obtain a registration, with a separate registration at each principal place of business or professional practice, and 44-53-110 defines 'dispense' to include prescribing and administering. The DPH Bureau of Drug Control states that providers are not authorized to prescribe, administer, possess or dispense controlled substances without an active SC Controlled Substances Registration; its practitioner form (DPH Form 1174A) covers physicians, APRNs and PA-Cs and requires a copy of the SC professional license. MD/DO registrations expire every October 1 and other classes every April 1 (44-53-280); there is no grace period, and reinstating an expired registration requires a new application plus a $100 penalty.
The code text still names DHEC as 'the Department'; the Bureau of Drug Control now operates under the SC Department of Public Health (DPH) per the agency's own pages. Registration fee amounts and the order relative to DEA were not shown on the pages reviewed. Health clinics use a separate application signed by the medical director.
S.C. Code Ann. 44-53-110; 44-53-280; 44-53-290; 44-53-300
- S.C. Code Title 44, Chapter 53 - Poisons, Drugs and Other Controlled Substances — South Carolina Legislature, 2026-09-23
- Drug Control - Register, Verify — South Carolina Department of Public Health, Bureau of Drug Control, 2026-09-23
- Drug Control - New Registrations (updated Sept. 15, 2026) — South Carolina Department of Public Health, Bureau of Drug Control, 2026-09-15
PDMP check before prescribingSouth Carolina requires a PMP (SCRIPTS) review only before issuing a prescription for a Schedule II controlled substance, so testosterone (Schedule III) 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.
S.C. Code Sec. 44-53-1645(A) requires a practitioner or authorized delegate to review the patient's controlled substance prescription history and opioid-antidote administration history in the prescription monitoring program before issuing a prescription for a Schedule II controlled substance, with the review discussed with the practitioner and documented. Exemptions include hospice-certified patients, supplies of five days or less, established patients treated for a chronic condition (who must still be reviewed at least every three months), approving administration by a licensed provider, residents of skilled nursing, nursing home, community residential care or assisted living facilities whose medications are staff-controlled, and temporary exigent circumstances that are documented. A practitioner whose EHR automatically displays PMP history is deemed compliant.
History: 2017 Act No. 91, eff. May 19, 2017; 2019 Act No. 65, eff. January 1, 2021. PDMP TTAC also lists Sec. 44-53-363.
S.C. Code Ann. Sec. 44-53-1645
- South Carolina Code of Laws Title 44 Chapter 53, Sec. 44-53-1645 - Requirement to review patient's prescription history — South Carolina Legislature, 2026-09-23
Physicians dispensing from the officeSouth Carolina reportedly lets physicians dispense without a permit from sites they own, but requires a dispensing permit for sites they do not wholly own.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.
A vendor summary reports that South Carolina physicians may dispense to their patients, that a dispensing permit is required for 'non-owned' sites (not directly and wholly owned by the dispensing practitioner, which catches many employed and group physicians), and that controlled substances require the state controlled substance registration. The statute and rule text were not reviewed.
Confirm with the South Carolina Board of Pharmacy (LLR).
South Carolina Pharmacy Practice Act (non-owned site permit) - not verified
- South Carolina Physician Dispensing Laws & Regulations — PharmaLink (vendor summary), 2026-09-23
Prescribing by telehealthSouth Carolina requires a South Carolina license (not an IMLC member) and a state controlled-substance registration; telemedicine-only practice may not include Schedule II or III narcotics, but non-narcotic Schedule III drugs such as testosterone are not restricted.Allowed (standard rules)
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) Physicians practicing via telemedicine must hold a South Carolina license; exceptions cover informal consultation requested by a South Carolina physician and care between in-person visits under an existing treatment plan for specialty care established in person in another state, and controlled-substance prescribers must hold a South Carolina Bureau of Drug Control registration (S.C. Code 40-47-37(A)). (2) An appropriate evaluation is required before treatment but need not be in person if the physician can diagnose and treat within the standard of care; a relationship may not be established by telemedicine to prescribe when an in-person exam is necessary for diagnosis, and questionnaire-only prescribing is unprofessional (40-47-37(C); 40-47-113). (3) Telemedicine-only practice must follow the PMP and the Ryan Haight Act and may not include Schedule II-narcotic or Schedule III-narcotic prescriptions except for hospital patients, buprenorphine MAT, palliative care or hospice, or Board-authorized programs; non-narcotic Schedule III drugs such as testosterone are outside this ban. (4) IMLC: not a member.
The South Carolina controlled-substance registration applies to every controlled-substance prescriber, not only telehealth, so it did not change the classification. The narcotic-only limit is treated like an opioid-only limit. 40-47-37 last amended 2024 (Act No. 120, eff. 3/11/2024).
S.C. Code 40-47-37 (amended 2024 Act No. 120); S.C. Code 40-47-113
- S.C. Code Title 40, Chapter 47 - Physicians (40-47-37 telemedicine; 40-47-113 physician-patient relationship) — South Carolina Legislature, 2026-09-23
- 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 fillersSouth Carolina RNs may inject cosmetic dermal fillers only with a supervising physician or APRN on site (able to respond within five minutes) who has first assessed the patient, and with documented training.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?
SC Board of Nursing Advisory Opinion #39 (revised Nov. 2023) says cosmetic dermal fillers are within RN scope only if the supervising physician/APRN is immediately available on site and can respond within five minutes; the physician/APRN performs and documents an initial assessment (an RN cannot establish the practitioner-patient relationship); the RN completes documented training with supervised practice; injections occur in a clinical setting with sterility and resuscitation capability and written policies; and ongoing competency is documented. LPNs are not included for fillers. The opinion does not mention cosmetic botulinum toxin, and no separate SC nursing opinion on cosmetic Botox was found.
Revision month only (Nov. 2023; recorded as 2023-11-01). Advisory opinions #1–#82 were scanned on 2026-09-23; the only Botox opinion (#70) concerns endoscopic/cystoscopic injection, not cosmetic use. Check with the Board for neuromodulators.
SC Board of Nursing Advisory Opinion #39 (formulated 2002-01-24; rev. Nov. 2023)
- Advisory Opinion #39 – Cosmetic procedures by licensed nurses — South Carolina Board of Nursing, 2023-11-01
IV hydration and vitamin therapySouth Carolina's medical, pharmacy and nursing boards say a physician, PA or APRN must personally take a history and examine each IV-clinic patient (telemedicine allowed if it meets the standard of care) before an RN gives an IV; standing orders do not 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 2023 joint advisory opinion on retail IV therapy businesses says only a physician, PA or APRN may diagnose, assess and recommend IV treatment, and must personally perform and document a history and physical, diagnosis and plan and obtain informed consent. A "medical director" who is merely available, and standing orders for the RN to follow, do not satisfy these duties and may amount to aiding unlicensed practice. The relationship may be established by telemedicine under S.C. Code §40-47-37 if the standard of care is met. Patients selecting additives from a menu is not acceptable, and mixing additives is compounding that brings Pharmacy Act requirements (a pharmacy permit unless the facility is 100% practitioner-owned).
Over two years old (possibly stale) but still linked from the Board of Medical Examiners' page on 2026-09-23.
Joint Advisory Opinion of the SC Boards of Medical Examiners, Pharmacy, and Nursing Regarding Retail IV Therapy Businesses (2023-08-15); S.C. Code §§40-47-20(36), 40-47-37, 40-47-200
- Joint Advisory Opinion Regarding Retail IV Therapy Businesses — South Carolina Boards of Medical Examiners, Pharmacy and Nursing, 2023-08-15
Corporate practice of medicine / med spa ownershipCompilations rate South Carolina a strict corporate practice of medicine state based on case law, so med spas' medical services are generally physician-owned or run through MSO arrangements.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 South Carolina as strict, citing S.C. Code §40-47-10 and cases including Ezell v. Ritholz (1938), Wadsworth v. McRae Drug (1943) and McMillan v. Durant (1993); MedPath Compliance (2026) also lists it as a CPOM state. The 2023 joint IV opinion notes that a pharmacy permit is required for IV compounding unless the facility is 100% practitioner-owned.
Case law and statute text not fetched.
S.C. Code §40-47-10; Ezell v. Ritholz (S.C. 1938) (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 lasersIn South Carolina cosmetic lasers may be used by physicians, trained PAs and NPs, RNs under direct supervision with the physician on site, and certified medical assistants for non-ablative lasers under direct supervision; a practitioner must examine each patient first.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?
The SC Board of Medical Examiners' guidance on surgery using lasers, pulsed light and RF devices (adopted 2024-05-07) treats these as the practice of medicine; they may be delegated to trained PAs (under supervision) and NPs (under a practice agreement), and practitioners must examine each patient before the first treatment or before authorizing a non-physician to treat. Its 2025 laser summary adds that RNs may perform under direct supervision of a physician, APRN or PA, and certified medical assistants may use non-ablative lasers under direct supervision (S.C. Code §40-47-196). Board of Nursing Advisory Opinion #39 limits RN laser hair and spider-vein removal to cases where the supervising physician is on site and can respond within five minutes, with a prior physician/APRN assessment and documented training.
The 2025 summary shows only the year (recorded as 2025-01-01).
SCBME 'Guidance on Surgery Using Lasers, Pulsed Light, Radiofrequency Devices, or Other Techniques' (2024-05-07); S.C. Code §40-47-196; SC BON Advisory Opinion #39
- Guidance on Surgery Using Lasers, Pulsed Light, Radiofrequency Devices, or Other Techniques — South Carolina Board of Medical Examiners, 2024-05-07
- 2025 Summary – Laser procedures — South Carolina Board of Medical Examiners, 2025-01-01
- Advisory Opinion #39 – Cosmetic procedures by licensed nurses — South Carolina Board of Nursing, 2023-11-01
Labs, regenerative medicine & cosmetics
State clinical laboratory licensing (beyond CLIA)Not confirmed. No South Carolina 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). South Carolina was not among them, but this research did not confirm its statutes. South Carolina's CLIA state agency is South Carolina Dept. of Public Health, Healthcare Quality (SC_CLIA@dph.sc.gov, 803-545-4203); it can confirm whether any state license or permit applies, including to out-of-state labs.
Absence of a state license was not verified against the state's statutes or rules.
Not confirmed
- CLIA State Agency Contacts (updated May 2026) — Centers for Medicare & Medicaid Services, 2026-05-01
Direct-to-consumer lab testingNot confirmed whether South Carolina 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 South Carolina's rule. South Carolina's lab regulator (CLIA state agency) is South Carolina Dept. of Public Health, Healthcare Quality (SC_CLIA@dph.sc.gov, 803-545-4203). 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 therapiesNo South Carolina law specific to stem cell, exosome or regenerative therapies was found, so FDA rules and general medical-practice rules apply.No state-specific law (FDA rules apply)
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)?
Compilations of state stem-cell laws from 2024 to 2026 list about a dozen states with specific laws (California, Florida, Georgia, Mississippi, Nevada, North Carolina, Tennessee, Texas, Utah, Vermont, Washington and Wyoming), plus Montana's general experimental-treatment law and Kansas's state stem cell center. South Carolina is not among them. Without a state-specific law, regenerative products are governed by federal FDA rules plus the state's general medical practice, advertising and consumer-protection laws, enforced by its medical board. 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.
The finding of no law rests on multi-state compilations (a commercial one from Aug 2026 and a peer-reviewed one from Feb 2024, which is older than 2 years) and targeted searches, not a statute-by-statute review, and neither compilation is exhaustive. General Right to Try laws for terminal patients, where they exist, were not reviewed here.
None found
- State Stem Cell Laws: Accurate 2026 Map Update (lists 12 states with statutes; commercial source) — SaveMyFat, 2026-08-06
- U.S. State Laws on Medical Freedom and Investigational Stem Cell Procedures: A call to focus on state-based legislation (Cytotherapy) — Cytotherapy / PubMed Central, 2024-02-03
State rules for cosmetics and sunscreenNo South Carolina-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?
South Carolina 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
Physicians dispensing from the office. 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.
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.
