Last Week in Peptides. What Happened. What it Means. What Comes Next.

Considering the powerful position in government that he occupies, every time RFK Jr. tweets about a subject, or speaks on a podcast, we of course need to listen. But even in this sometimes-unconventional Administration, government policy change still has a process. An announcement on a podcast may signal intentions, but it is not itself rulemaking.  To that end, when RFK Jr. appeared on Joe Rogan last month, announcing a new day in peptides, no actual rule making or other formal government action publicly occurred.

But last week, in connection with RFK Jr.’s post on X, the government wheels started to publicly turn. And we are seeing a clearer picture starting to develop.    

What actually happened last week on the peptide front? Three specific things:

1. On April 15, 2026, RFK announced on X that 12 peptides are going to be re-considered by the Pharmacy Compounding Advisory Committee, or PCA

   C, which is the board that voted against adding them to the FDA 503A Bulks List in late 2024.   

2. 

   The same day, the FDA formally scheduled a PCAC meeting for July 23, 2026, from 8:00 a.m. to 4:30 p.m. Eastern Time, and July 24 from 8:00 a.m. to 3:50 p.m.

3. The 12 compounds were formally removed from the Category 2 list and referred to PCAC for evaluation.

What is the function of PCAC?

The Pharmacy Compounding Advisory Committee (PCAC) is an independent panel of outside experts that advises the FDA on scientific, technical, and medical questions related to drug compounding. Its primary practical function is to evaluate specific substances nominated for inclusion on the 503A bulks list — the FDA's curated list of ingredients that licensed compounding pharmacies are explicitly authorized to use. When a substance comes up for review, the committee holds a public meeting, hears presentations from nominators and FDA staff, and then votes on whether the substance should be permitted for compounding. That vote is non-binding, but the FDA has historically followed PCAC recommendations the vast majority of the time. The committee's decisions carry real downstream consequences: what ends up on the 503A bulks list determines what compounding pharmacies can legally produce, what patients can access through a prescription, and what remains in regulatory limbo or outright prohibited.

What happened last time PCAC met?

The last time PCAC met was in October and December 2024, about three month before RFK Jr. was appointed. At those meetings, PCAC voted against adding several peptides to the Category 1 bulks list, including CJC-1295, Thymosin Alpha-1, AOD-9604, ipamorelin, ibutamoren, and kisspeptin-10.

What’s different now?

The members of the 12-seat committee that opposed peptides in late 2024 are largely gone. The seats mostly sit vacant: there are currently only three voting members listed on the FDA’s website. Due to some FDA policy changes, some members were no longer eligible. Others are simply not listed anymore, without explanation. There was no high-profile purge like the Advisory Committee on Immunization Practices.

It seems likely that a slate of RFK Jr.-friendly and peptide-friendly members will be announced before the meeting.

What will happen after the July PCAC meeting?

Assuming the current committee votes in support of the peptides, the process to add them to the Category 1 list is not straightforward.

Under current FDA published guidance, the FDA does not have discretion to add compounds to the 503A Category 1 – Bulk Drug Substances Under Evaluation (Interim Category 1 List). The guidance requires a final Federal Register notice updating the bulks list, which typically trails the advisory vote by four to nine months. Full rulemaking with notice and comment can push that to twelve to eighteen months.

Notably that January 2025 guidance, which was released in the waning days of the prior administration, has to date not been rescinded. However, the guidance states that it “Contains Nonbinding Recommendations.”    

My prediction: The days are numbered for this January 2025 guidance. After the newly-comprised PCAC committee votes in favor of the 12 peptides at the July 2026 meeting, new guidance will be published shortly thereafter returning discretion to FDA to update the Interim Category 1 List, based on favorable findings of PCAC and possibly adding new guidance as to the standards PCAC should use to evaluate compounds in the future.