On April 30, 2026, the FDA published a proposed determination that semaglutide, tirzepatide, and liraglutide do not meet the statutory criteria for inclusion on the 503B Bulks List. Under 21 U.S.C. § 353b, an active pharmaceutical ingredient may be compounded in bulk by a 503B outsourcing facility only if it is on the FDA's published Bulks List or on the agency's drug shortage list. With semaglutide removed from the shortage list in February 2025 and tirzepatide removed in December 2024, the only remaining legal pathway for industrial-scale 503B compounding of these molecules was bulks-list inclusion.
The FDA's analysis concludes that there is no current clinical need for outsourcing-facility compounding of these three molecules from bulk API, since FDA-approved products (Wegovy, Ozempic, Zepbound, Mounjaro, Saxenda, Victoza) are commercially available and meet patient need. The proposal explicitly rejects affordability and insurance access as constituting clinical need within the meaning of the statute.
The proposal does not affect 503A patient-specific compounding by state-licensed pharmacies, which remains legal where each prescription is supported by individualized medical-necessity documentation and the dispensing pharmacy operates under USP <797> sterile-compounding standards. It does, however, foreclose the path that enabled the 30%-of-supply compounding boom of 2024.
If finalized, the rule ends the legal basis for high-volume 503B compounding of GLP-1 medications. Patient-specific 503A compounding pursuant to a valid prescription, with documented medical necessity, remains lawful. Public comment closes June 29, 2026.