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Compounded semaglutide and tirzepatide: where things stand

The drug shortages that opened the door to compounded semaglutide and tirzepatide ended in 2024 and 2025. What that means for pharmacies, why FDA keeps warning about dosing errors and salt forms, and what is still undecided.

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PeptideHelp

Why compounded versions existed

Compounded drugs are mixed by a pharmacy rather than made by a drug company under an FDA approval. FDA's position is that a compounded drug "might be appropriate if a patient's medical need cannot be met by an FDA-approved drug, or the FDA-approved drug is not commercially available." Compounded drugs are not FDA-approved, which means the agency "does not review compounded drugs for safety, effectiveness or quality before they are marketed."4

Federal law also lets pharmacies make copies of a drug while it is on FDA's drug shortage list. That is what happened with GLP-1 drugs. Demand outran supply: Wegovy went on the shortage list on March 31, 2022, Ozempic on August 23, 2022, and tirzepatide (Mounjaro and Zepbound) on December 15, 2022.1,2 For roughly two to three years, compounded semaglutide and tirzepatide filled the gap, usually in multi-dose vials rather than the pre-filled pens the approved products come in.

The shortages are over

FDA declared the tirzepatide shortage resolved on October 2, 2024. A lawsuit sent that decision back to the agency, and FDA reached the same conclusion again on December 19, 2024.2,3 It declared the semaglutide shortage resolved on February 21, 2025.1 FDA noted that people "may still see intermittent and limited localized supply disruptions" as stock moves from manufacturers to local pharmacies.3

Fig. 1From shortage to the end of the grace periods
SemaglutideTirzepatide
  1. Mar 31, 2022Semaglutide

    Wegovy added to FDA's shortage list.

  2. Aug 23, 2022Semaglutide

    Ozempic added.

  3. Dec 15, 2022Tirzepatide

    Tirzepatide injection added to the shortage list.

  4. Oct 2, 2024Tirzepatide

    FDA declares the shortage resolved; the decision is sent back for review during a lawsuit.

  5. Dec 19, 2024Tirzepatide

    FDA re-decides: the shortage is resolved.

  6. Feb 21, 2025Semaglutide

    FDA declares the semaglutide shortage resolved.

  7. Mar 5, 2025Tirzepatide

    A court declines to block the decision; the 503A grace period ends.

  8. Mar 19, 2025Tirzepatide

    503B grace period ends.

  9. Apr 22, 2025Semaglutide

    Grace period for state-licensed (503A) pharmacies ends; a court declined to block FDA's decision two days later.

  10. May 22, 2025Semaglutide

    Grace period for outsourcing facilities (503B) ends.

Dates from FDA's semaglutide declaratory order, its December 2024 tirzepatide decision and its compounding policy page (content current as of April 1, 2026).1,2,3 FDA's page states the 503A grace periods as a date "or until the date of the district court's decision… whichever is" later; the court dates are the ones FDA reports.
Not in shortage

Resolved February 21, 2025. Not in FDA's shortage list download on November 1, 2026.1,9

Not in shortage

Resolved October 2, 2024; re-confirmed December 19, 2024. Not in the shortage list on November 1, 2026.2,9

On the shortage list since July 18, 2023 and still current. FDA lists generic liraglutide from several makers as available.9

What it means for pharmacies: 503A and 503B

Two kinds of compounders work under different sections of federal law. Which one made a product decides what it may do now that the shortages are over.

Fig. 2The two kinds of compounder
Section 503A
State-licensed pharmacies
Makes
Drugs for individual patients' prescriptions.
The limit now
May not regularly compound drugs that are "essentially a copy" of a commercially available drug: same active ingredient, similar strength, same route.3
The exceptions
A prescriber documents a change that makes a significant difference for an identified patient. FDA also says it won't act over four or fewer prescriptions of a copy a month.3
Grace period ended
Tirzepatide March 5, 2025; semaglutide April 22, 2025.3
Section 503B
Outsourcing facilities
Makes
Larger batches, with or without prescriptions for specific patients, under drug-manufacturing quality rules.
The limit now
May compound from bulk powder only if the ingredient is on the 503B bulks list or the drug is on the shortage list. Semaglutide and tirzepatide are on neither.3
Pending
FDA proposed in April 2026 to keep both, and liraglutide, off the bulks list.5,6
Grace period ended
Tirzepatide March 19, 2025; semaglutide May 22, 2025.3
Paraphrased from FDA's compounding policy page, content current as of April 1, 2026.3

Adding a vitamin doesn't make a copy into something else. FDA gives the example of semaglutide combined with vitamin B12: it may still count as essentially a copy if it is used the same way and the amounts are within 10% of the strengths of the approved products.3 FDA also says the safety and effectiveness of combining semaglutide with other ingredients, such as B12, B6, L-carnitine or NAD, "has not been established."8

For outsourcing facilities, the open question is the 503B bulks list. On April 30, 2026, FDA proposed leaving semaglutide, tirzepatide and liraglutide off it, saying it found "no clinical need" for outsourcing facilities to compound them from bulk substances.5 The Federal Register notice says FDA does not treat shortages or backorders as "clinical need."6 The comment period was extended to July 30, 2026.7 As of November 1, 2026, the Federal Register shows no final decision.

Dosing errors: units, milliliters and milligrams

The approved injectable semaglutide products are dosed in milligrams, come in standard concentrations and were, when FDA wrote its alert in July 2024, sold only in pre-filled pens. Compounded versions usually come in multi-dose vials. Their instructions may give the dose in "units," whose volume depends on the concentration, and some patients were sent syringes much larger than the volume they needed.8

Fig. 3The same "5" on a U-100 syringe
Meant: 5 units0.05 mL020406080100Drawn: 50 units0.5 mL · 10× the volume020406080100
A U-100 insulin syringe holds 100 units in 1 mL, so each unit is 0.01 mL. FDA's July 2024 alert describes patients told to draw 5 units (0.05 mL) from a multi-dose vial who drew 50 units instead.8 The drawing shows volume only. How much drug that volume holds depends on the vial's concentration.

FDA's alert says most reports involved patients "mistakenly drawing up more than the prescribed dose from a multiple-dose vial," which led to five to 20 times the intended dose. In other reports, the error was the prescriber's: converting milligrams to units or milliliters wrongly led to five to 10 times the intended dose. Reported effects included nausea, vomiting, abdominal pain, fainting, headache, dehydration, acute pancreatitis and gallstones, and some patients were hospitalized. Because semaglutide's half-life is about a week, FDA notes that watching and treating an overdose can take a long time.8

Poison-center data show the same pattern. A review of California Poison Control System records from December 2017 to December 2023 found 36 exposures involving compounded GLP-1 drugs. In 33 of them (91.7%), an administration error was the main reason for the call.13 An earlier case series described two patients who injected ten times their intended dose from compounded vials.14 FDA has also received reports from people prescribed compounded semaglutide or tirzepatide at doses beyond the approved labels, or raised faster than the labels' schedules.4

The salt-form problem

Ozempic, Wegovy and the other approved semaglutide products contain semaglutide in its base form. FDA says some compounders have used salt forms instead, such as semaglutide sodium and semaglutide acetate. These "are different active ingredients than are used in the approved drugs." FDA says it does not know whether they have the same chemical and pharmacologic properties, and that it is "not aware of any lawful basis for their use in compounding."4,8

Where the powder comes from matters too. In September 2025, FDA created a "green list" import alert for GLP-1 active ingredients. Bulk powder from facilities FDA hasn't inspected or evaluated can now be held at the border. Of the 48 GLP-1 ingredient sites FDA evaluated, 21% were found noncompliant. FDA also notes that 503A pharmacies are exempt from manufacturing quality rules, including the requirement to check an ingredient's purity and potency against specifications. That raises the risk that a bad batch of powder goes uncaught.10,18

Marketing claims and "research use only" vials

In February 2026, FDA said companies may not claim that compounded products are generic versions of, or the same as, FDA-approved drugs. They also may not say the products use the same active ingredient or are clinically proven to work.11 In March 2026, FDA announced 30 warning letters to telehealth companies, mostly over claims implying sameness with approved products and labels that hid which pharmacy actually made the drug.12

Vials sold online as "for research purposes" or "not for human consumption" are a separate problem. FDA has warned sellers of semaglutide, tirzepatide, retatrutide and other GLP-1 drugs labeled that way but sold to consumers with dosing instructions. It calls them "of unknown quality." FDA also says retatrutide and cagrilintide cannot be used in compounding at all, because they are not components of any approved drug.4

The list above is condensed from FDA's consumer page.4 FDA also reports compounded GLP-1 products that arrived warm or with too little ice.

The approved options have changed

The approved options have also changed since the shortages began. FDA approved Wegovy tablets, an oral semaglutide for weight management, on December 22, 2025.15 It approved a higher-dose Wegovy injection (7.2 mg, Wegovy HD) on March 19, 2026.16 On April 1, 2026, it approved Foundayo (orforglipron), a daily pill that acts on the GLP-1 receptor but is not a peptide.17 Zepbound gained an indication for moderate to severe obstructive sleep apnea in adults with obesity in December 2024.19 Whether any of these suits a particular person is a question for a prescriber, but their existence is part of why FDA treats the approved drugs as commercially available.

What isn't settled

  • The 503B bulks list. FDA's decision on keeping semaglutide, tirzepatide and liraglutide off it is still a proposal as of November 1, 2026.6,7
  • Restricting the ingredients themselves. FDA said in February 2026 that it intends to restrict GLP-1 active ingredients meant for mass-marketed compounded drugs.11 We found no rule or notice on FDA's site or in the Federal Register putting that into effect yet.
  • How often things go wrong. Adverse-event reports can't show cause, and 503A pharmacies aren't required to report them to FDA, so the counts are likely low.4 FDA's dosing-error alert gives no count of cases at all.8
  • Product quality across the market. There is no FDA-reviewed data on how consistent compounded GLP-1 products are in strength, purity or sterility. That is the gap approval is meant to fill.
  • Liraglutide. It is still on the shortage list, which keeps the shortage route open for it in principle, while FDA's bulks-list proposal would close the other route.6,9

We'll update this guide when FDA finalizes the bulks-list decision or the shortage list changes, and the "Last reviewed" date at the top will say when we last checked.

Sources

Trials and reviews on PubMed, prescribing labels on DailyMed, and FDA and Federal Register pages, each read for what it says. Regulatory pages were checked on November 1, 2026.

  1. 1
  2. 2
    Resolution of Tirzepatide Injection Product Shortage and Supply Status
    FDA, CDER Drug Shortage Staff, December 19, 2024 · FDA / regulatory
  3. 3
    FDA clarifies policies for compounders as national GLP-1 supply begins to stabilize
    FDA, content current as of April 1, 2026 · FDA / regulatory
  4. 4
    FDA's Concerns with Unapproved GLP-1 Drugs Used for Weight Loss
    FDA, content current as of October 1, 2026 · FDA / regulatory
  5. 5
    FDA Proposes to Exclude Semaglutide, Tirzepatide, and Liraglutide on 503B Bulks List
    FDA press announcement, April 30, 2026 · FDA / regulatory
  6. 6
  7. 7
  8. 8
  9. 9
    FDA Drug Shortages: current shortages list (download)
    FDA, updated through October 30, 2026; checked November 1, 2026 · FDA / regulatory
  10. 10
    FDA Launches Green List to Protect Americans from Illegal Imported GLP-1 Drug Ingredients
    FDA press announcement, September 5, 2025 · FDA / regulatory
  11. 11
    FDA Intends to Take Action Against Non-FDA-Approved GLP-1 Drugs
    FDA statement, February 6, 2026 · FDA / regulatory
  12. 12
    FDA Warns 30 Telehealth Companies Against Illegal Marketing of Compounded GLP-1s
    FDA press announcement, March 3, 2026 · FDA / regulatory
  13. 13
  14. 14
  15. 15
    Approval letter, NDA 218316: Wegovy (semaglutide) tablets
    FDA, December 22, 2025 · FDA / regulatory
  16. 16
  17. 17
  18. 18
  19. 19
In the database
Education, not medical advice. This guide explains what published research and regulators say. It gives no doses and makes no promise of results; decisions about any medicine belong with you and a clinician who knows your health. We re-check guides against their sources and update the review date when we do. Found an error? ask@peptidehelp.com
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Compounded semaglutide and tirzepatide: where things stand