The FDA advisory panel that spent two days last July recommending gray-market peptides for legal compounding is not done. Its next slate is already set: a second meeting before the end of February 2027 to review five more peptides for the Section 503A Bulks List, the roster of ingredients that licensed pharmacies are allowed to make to order. The five are cathelicidin (also called LL-37), the copper tripeptide GHK-Cu, dihexa acetate, melanotan II, and pegylated mechano growth factor, known as PEG-MGF. That lineup was reported by the regulatory-affairs outlet RAPS ↗ and detailed by the FDA Law Blog ↗.
The important caveat sits in the same sentence as the news. There is no meeting date yet, and no public comment docket has been posted. A scheduled review is a plan, not a decision, and this one is still missing the pieces that would let anyone weigh in.
What is queued
The five read like a tour of the most-searched compounds on peptide forums. Melanotan II ↗ is a synthetic copy of the hormone fragment that darkens skin, sold online as an injectable tan and, separately, for sexual arousal and appetite suppression. GHK-Cu ↗ is a small copper-carrying peptide found naturally in human blood and marketed heavily in cosmetic and wound-healing formulas. LL-37 ↗ is the body's own broad-spectrum germ-killer, a natural antimicrobial peptide. Dihexa acetate is a nootropic derived from angiotensin IV, a blood-pressure hormone fragment, and is sold for cognitive enhancement. PEG-MGF ↗ is a muscle-repair signal, a splice variant of insulin-like growth factor 1 with a polyethylene glycol tail added to make it last longer in the body.
Four of the five have effectively no controlled human trial behind the uses people buy them for. That is the pattern that made the first round contentious, not an exception to it.
Why the timing matters
All five sit in what the FDA calls Category 2, a bin the agency created in September 2023 that effectively prohibits pharmacies from compounding them. Getting off that list is the whole point of a Bulks List review. The February 2027 meeting continues the July 23 and 24, 2026 session, where the panel cleared six of seven peptides ↗ and rejected only the sleep peptide DSIP. Two of the six it waved through, TB-500 ↗ and MOTS-c ↗, have never been tested in a human trial, and the panel recommended them over the written objection of the FDA's own review scientists.
That history is the reason the second slate is worth watching rather than dismissing. The committee has shown it will recommend a peptide on thin evidence, so a scheduled review of five more is a real signal that the compounding channel could widen, even if the science supporting any single molecule stays where it is.
The process is long and the vote is advice
A recommendation from the Pharmacy Compounding Advisory Committee is not a rule. It is non-binding advice to the FDA, and the agency has to run a formal notice-and-comment rulemaking before anything actually changes, a process that under standard timelines takes more than a year and that the FDA is free to decline at the end. So even a clean sweep in February 2027 would not put melanotan II or GHK-Cu on a pharmacy shelf in 2027. It would start a clock.
The broader push here is deregulatory. The July peptides landed in front of the committee after Health Secretary Robert F. Kennedy Jr.'s campaign to loosen the rules on compounded peptides, and the second batch extends that. Other regulators have gone the other direction. Australia's medicines regulator flagged five peptides for tighter control ↗ last month, one of them a late-stage obesity drug, a reminder that the same molecules draw opposite responses depending on which agency is holding the pen.
For now, the concrete thing to track is small and specific: when the FDA posts the meeting date and the comment docket. Until it does, the second wave is a name on a calendar, five peptides with a large online following and, for most of them, the same empty column where the human evidence should be.