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FDA's proposal to keep compounded GLP-1s off the 503B bulks list — and how to comment

In May 2026 the FDA proposed to exclude semaglutide, tirzepatide, and liraglutide from the 503B compounding bulks list, a decision that affects how compounded GLP-1s can be made. The public comment period closed July 30, 2026, and as of late September 2026 the FDA has not published a final determination. This guide explains the proposal, why it matters for access, and what you can still do.

By the glp1.how editorial teamReviewed 3 min read

Evidence-backed

On May 1, 2026, the FDA published a notice (Docket FDA-2018-N-3240) proposing to exclude the three main GLP-1 substances, semaglutide, tirzepatide, and liraglutide, from the "503B bulks list." It sounds technical, but it decides how compounded GLP-1s can be made. The public comment period closed on July 30, 2026. As of late September 2026 the FDA has not published its final decision, so if access matters to you, keep an eye on this docket.

What the 503B bulks list is

"503B outsourcing facilities" are compounders that make medications in larger volumes under stricter federal oversight than a typical pharmacy. A 503B facility generally cannot compound a drug from a bulk substance unless that substance is on the FDA's "503B bulks list", which lists substances for which the FDA has found a clinical need. A separate pathway was open while the brand-name drugs were in official shortage, but the FDA declared those shortages resolved on December 19, 2024 (tirzepatide) and February 21, 2025 (semaglutide).

So whether semaglutide, tirzepatide, and liraglutide are on this list decides whether 503B facilities can keep compounding them from bulk.

What the FDA is proposing, and why

After reviewing the nominations it received, the FDA says it did not find sufficient evidence of a clinical need for outsourcing facilities to compound these three drugs from bulk substances, and it proposes to leave them off the list. In the notice, the FDA explains how it judges clinical need: it first asks whether some attribute of the FDA-approved product makes it medically unsuitable for certain patients, and whether the compounded version is meant to address that. It says it does not count supply problems such as backorders, convenience, or the lower cost of a compounded product as clinical need.

The notice also shows what each side argued. The nominators pointed to shortages, growing demand, and access to these drugs, which the FDA said fall outside the clinical-need standard. Commenters raised safety and quality concerns about compounded versions, and the FDA said it didn't need to reach those arguments because the drugs failed the first step. We aren't taking a side here. The decision is still open, and there are ways to follow it.

Why it matters for access

If finalized as proposed, this would further narrow the legal routes for 503B-compounded GLP-1s. For patients, the practical questions are cost and whether alternatives are available, and those are the access issues where public comment and patient experience carry weight.

The comment period (closed July 30, 2026) and what happens next

Public comments are part of how the FDA reaches a final decision, and anyone could submit one, including patients, caregivers, and clinicians. The FDA first set a June 30, 2026 deadline, then extended it to July 30, 2026. That window has closed, but the process isn't over.

  • The notice and all public comments are posted on regulations.gov as Docket FDA-2018-N-3240 (external link). Reading what patients, clinicians, and organizations submitted is a good way to understand each side's arguments.
  • While the period was open, anyone could file through the "Comment" button on the docket page, and personal, specific accounts were often the most useful. If the FDA reopens or extends the period, the same button applies; check the docket page for current status.
  • The FDA will publish its final determination as a new Federal Register notice filed to the same docket. Until then, the proposal is not final.

Comments on the docket are public record, so anyone can see what's filed there.

Want to go deeper?

Patient-advocacy organizations like the Obesity Action Coalition track decisions like this and sometimes offer ways to add your voice, which is useful if you want context or a coordinated channel. For the broader access-versus-safety argument behind this docket, see our guide on the compounding pharmacy debate.

This is general information about a public regulatory process, not legal or medical advice. It summarizes an FDA proposal that may change; rely on the official docket for the authoritative text and current status.

advocacyfdacompounding503bpublic-commentaccesspolicy

Common questions

Questions people often ask about this topic.

  • What is the FDA proposing about compounded GLP-1s?

    The FDA proposed to keep semaglutide, tirzepatide, and liraglutide off the 503B 'bulks list,' finding insufficient evidence of a clinical need for outsourcing facilities to compound them from bulk substances. If finalized, it further narrows legal routes for 503B-compounded GLP-1s.

  • How can I submit a public comment?

    The comment period for this proposal closed July 30, 2026. While it was open, anyone could file through the 'Comment' button on the regulations.gov page for Docket FDA-2018-N-3240. The docket and all submitted comments remain public, and if the FDA reopens or extends the period the same button applies, so check the docket page for current status.

  • What's the deadline to comment?

    The extended comment period closed July 30, 2026. As of late September 2026 the FDA had not published a final decision; watch Docket FDA-2018-N-3240 on regulations.gov and the Federal Register for the outcome.

  • Does this ban compounded GLP-1s entirely?

    No. It applies specifically to 503B outsourcing facilities and the bulks list, and the proposal may change before it's final. It's one part of a shifting legal picture around compounding.

Evidence

The sources behind this article, labeled by type and strength.

Supporting4

Revision history

Updated 5 times since Sep 2, 2026 · show changes
  1. v6

    Body revised

  2. v5

    Evidence sources 3 → 4

  3. v4

    Common questions revised

  4. v3

    Summary rewritten; Body revised

  5. v2

    Body revised

  6. v1

    Change tracking began

Related guides

  • The compounding pharmacy debate: patient access vs. safety regulation · When brand-name GLP-1 supply couldn't meet demand, compounded versions filled the gap for many patients who couldn't otherwise afford or get treatment. Those shortages ended in December 2024 (tirzepatide) and February 2025 (semaglutide), and the argument over access versus safety has continued since.
  • The Treat and Reduce Obesity Act (H.R. 4231 / S. 1973): what it is and why it matters · TROA is the main federal bill aimed at ending Medicare's exclusion of obesity medications. It was first introduced in 2013 and has been reintroduced with bipartisan support in later Congresses, but it hasn't passed. This guide explains what it would change.
  • Why GLP-1 access is uneven across income and race · Few eligible adults get a GLP-1 prescription at all, and the gaps follow insurance type, employer size, where you live and, in some settings, race and ethnicity. What the studies show and what drives the differences.
  • Sharing your story: how patient testimonials influence coverage decisions and legislation · Congressional staff say personal stories are helpful and that they rarely get them. Where your GLP-1 coverage story can be used, how to tell it so it's useful, and what to check before you share it.
  • The push to get Medicare to cover GLP-1 medications for obesity · Medicare is legally barred from covering weight-loss drugs, yet it covers the same medications for diabetes or heart disease. As of September 2026, a temporary CMS demonstration called the GLP-1 Bridge lets eligible beneficiaries get certain GLP-1s for about $50 a month while the underlying exclusion stays in place. This guide explains why the gap exists, what the Bridge does and doesn't change, and how patients and advocates are pushing for a permanent fix.
  • How GLP-1 coverage mandates differ by state · A few states require some insurance plans to cover obesity treatment, including GLP-1 medications; most don't. This guide covers how state mandates work, why they skip most people with job-based insurance, and how to find out what your state requires.

Related terms

  • Tirzepatide · A once-weekly dual GIP and GLP-1 receptor agonist made by Eli Lilly, marketed as Mounjaro for type 2 diabetes and Zepbound for weight management and obstructive sleep apnea.
  • Semaglutide · A GLP-1 receptor agonist medication made by Novo Nordisk, sold under the brand names Ozempic (type 2 diabetes) and Wegovy (weight management), each as an injection or a pill.
  • GLP-1 · A gut hormone (glucagon-like peptide-1) that stimulates insulin release, slows digestion, and reduces appetite; the target of drugs like semaglutide and liraglutide.
  • Liraglutide · A first-generation GLP-1 receptor agonist taken as a daily injection, sold as Victoza for type 2 diabetes and Saxenda for weight management, and now also as a US generic.

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