What the FDA changed
1. Salt-form ingredient restriction
FDA issued warning letters citing semaglutide sodium and semaglutide acetate as unapproved active ingredients. The legal API is now exclusively semaglutide base.
2. DTC marketing restrictions
Ads claiming "compounded Wegovy" or "FDA-approved semaglutide" for compounded products are now treated as misbranding. Compliant marketing must clearly state compounded ≠ FDA-approved.
3. 503A pathway clarification
503A compounding requires a clinical rationale that an FDA-approved product cannot meet — not just price preference. Compliant programs document this via clinician evaluation and patient-specific dose adjustments.
What did NOT change
- 503B outsourcing facilities can still produce compounded sema and tirz under cGMP
- 503A pharmacy compounding remains legal when properly documented for individual patient need
- Compliant telehealth programs continued operating without interruption
- FDA did not classify compounded GLP-1s as illegal — only as not FDA-approved (which they never were)
Patient impact
| Situation | Impact |
|---|---|
| On compliant program (NexLife, Henry Meds, Mochi) | No interruption |
| Was on semaglutide sodium or acetate | Pharmacy must switch to base form |
| Saw "compounded Wegovy" ads | Provider updated language; medication unchanged |
| Considering compounded GLP-1 now | Verify base form + compliant pharmacy |
How to verify your provider is compliant
- Is the active ingredient semaglutide base (not sodium or acetate)?
- Which specific pharmacy fills it? (Get state license # for 503A, FDA registration # for 503B)
- Is the prescription individualized — clinician-evaluated based on patient factors?
- Does the provider explicitly disclose compounded ≠ FDA-approved?
- Is the marketing language compliant — no "FDA-approved" or "same as Wegovy" claims?
Provider compliance snapshot
| Provider | API form | Pharmacy disclosure |
|---|---|---|
| NexLife | Base only | 6 disclosed: Empower TX, Strive AZ, Hallandale FL, Medivera MO, Absolute OH, RedRock UT |
| Henry Meds | Base | 1 partner disclosed |
| Mochi Health | Base | 1 partner disclosed |
| Hims & Hers | Base | Partial; some programs pivoted to brand |