The peptide reclassification, tracked — in one place.

Day 26. Still no FDA action — and the regulatory bar has now converged on the reading we published on July 27. No minutes, no transcript, no proposed rule; the Epitalon footnote stays up. Two national firm analyses are now in the record and both state the position more crisply than we did. Holland & Knight (August 2026) characterizes the vote as a step toward eligibility for lawful compounding, not the achievement of it. Sheppard Mullin's status tracker gives patients the single most checkable sentence anyone has written on this: the six substances are not currently listed in 21 CFR § 216.23. That is a citation you can open in a browser and verify in under a minute — which makes it a better tool than any of our prose for testing a clinic's claim that these peptides are now "legal" or "approved." Both are added to the post-vote read, along with Healio's clinical-audience coverage.

The active enforcement story this month is in Georgia, not Washington. The Georgia Composite Medical Board is conducting unannounced inspections of med spas and IV clinics, and reporting on what inspectors found includes unlicensed staff delivering medical services, unlawful compounding, treatment administered without the required exam, and chiropractors offering testosterone and weight-loss treatments — which Georgia's chiropractic scope statute, O.C.G.A. § 43-9-16, does not authorize. New page: Who is allowed to inject you? — a license-by-license table of prescriptive authority in Georgia, the eight holdings of the Board's May 7 IV therapy position statement, and two questions to ask before treatment. Our NAD+ IV page now sets out each of the Board's requirements alongside how we meet it. The federal clock still runs in years; this one is running in weeks, and it lands on named licensees.

Day 24. No new FDA action — and a competitor clause that is void under federal law. Still no minutes, no transcript, no proposed rule; the Epitalon footnote stays up. The six recommended substances remain absent from the regulation, and compounding remains unlawful pending proposed and final rulemaking. Adding one new secondary source to the record, deliberately one that cuts against this practice's commercial interest: a Health Affairs Forefront analysis arguing the July vote "may open a drug-compounding back door for unapproved peptides." We think the committee's caveats were more substantive than that framing allows, but a tracker that only cites favorable commentary is not a tracker.

The finding that matters today is not about peptides at all. Reviewing the patient agreement of a nationwide telehealth practice now advertising into both Georgia and Tennessee — it sells BPC-157 and TB-500 for "injury healing," among other things — we found this in its Communications Agreement: "You agree not to publish any content online or in any public space, including but not limited to social media, review websites, or public forums, related to your experience with [the practice] without our prior written approval. This includes both positive and negative reviews." A clause of that shape in a form contract is void from the inception of the contract under the Consumer Review Fairness Act, 15 U.S.C. § 45b, and offering it is a per se unfair or deceptive act under the FTC Act, enforceable by the FTC and by state attorneys general. A federal judge in Washington has already applied the CRFA against a medical clinic using NDAs to suppress negative reviews. The same page markets itself as "Physician-Led" while its terms state the company is a "marketing and technology management company… not a medical provider," and its refund policy imposes a three-month minimum in which early cancellation costs the full three months.

We are noting it here for a reason beyond the competitive one. If review-approval clauses are circulating in this market, then published review counts in this category are not a clean signal — including, potentially, ones we have no way to audit. That is worth a patient knowing before they weigh a five-star average against a physician's actual answers.

Page updated. Four questions to ask any peptide clinic now carries a sixth: "Does your patient agreement restrict what I am allowed to say in a review?" — with the statute, the precedent, and the exact language quoted. No competitor named. We have also added our own answer in writing: no Limitless agreement contains a non-disparagement clause, a review-approval requirement, or any pre-publication consent provision, and the new-patient paperwork now says so as a statement of the patient's rights rather than as a term to be signed.

Day 23. No new FDA action. The marketing gap is now structural, not just factual. Still no minutes, no transcript, no proposed rule; the Epitalon footnote stays up. What we have been documenting this month has shifted from which substances a clinic sells to how the clinic is built, and the two are related. The pattern now appearing repeatedly across Georgia and Tennessee: a brand founded by a non-physician, prescriptions written by a nurse practitioner, a physician named as medical director providing oversight, and the whole arrangement marketed as "physician-guided." Nurse practitioners prescribing under a proper collaborative arrangement are practicing lawfully and often excellently — the issue is the distance between the arrangement and the impression it creates.

Three claim patterns are worth naming because they recur nearly verbatim. (1) A flat FAQ answer — "Are peptides legal? Yes." (2) A sourcing claim that changes the subject: "all peptides sourced from licensed, FDA-regulated compounding pharmacies," which conflates pharmacy licensure with bulk-substance eligibility. These are separate questions, and a fully accredited 503A pharmacy still may not lawfully compound from an ineligible bulk substance. (3) The word again — "as restricted peptides become legally compoundable again" — the same error this site carried for three months and corrected in public. We are also now seeing membership models that bundle drug quantity as "credits" (e.g. 200 or 400 credits per month by tier, add-ons priced per credit), which attorneys writing on post-vote telehealth models have flagged as an exposure independent of prescribing quality. One such page, well-designed and currently live, is stamped "Last updated: March 2026" — before the April reclassification and four months before the committee met.

New page. Four questions to ask any peptide clinic — expanded into a full field guide with what a good answer sounds like versus a bad one, quoted language from live pages, a fifth question about how the clinic makes money, and the difference between "physician-guided" and physician-led. No competitor named.

Day 22. No new FDA action — and the second docket's substances are already retailing locally. As of this writing we have seen no new agency action on the July recommendations: no minutes, no transcript, no proposed rule. The Epitalon footnote stays up until FDA posts the official record. What has changed is on the ground. Over the past two weeks we have documented, across three separate metro markets in our region (Chattanooga, Atlanta, and greater Knoxville), commercial clinic menus openly selling four of the five substances slated for the second PCAC meeting — GHK-Cu, Melanotan (both I and II), and LL-37 — months before any committee has reviewed them, in at least one case alongside retatrutide, an investigational drug in active clinical trials with no lawful compounding pathway at all, and in another alongside DSIP, the one substance the July panel declined. The recurring frame on these pages is a blanket "peptides are considered safe." The federal record now says otherwise substance-by-substance, and the state-board layer is moving faster than the FDA one: see today's new page, the regulator nobody mentions — what Georgia and Tennessee boards can do, the Ohio summary suspensions, and the Alabama rule that bans non-FDA-approved peptide prescribing outright. Our posture is unchanged, and our four questions to ask any peptide clinic have not gotten less useful since we published them.

Day 12. Still no minutes — and two corrections to our own pages. FDA's advisory-committee page remains stamped "content current as of 06/29/2026": no minutes, no transcript, no archived webcast. The Epitalon footnote stays up.

Correction 1 — "restored" was wrong. This tracker and two other pages described the April 23 reclassification as having restored legal 503A compounding. That is backwards. At the July hearing FDA's presenter, Matthew Lash, stated that adding these substances to the 503A list would create legal access for the first time — there was no prior era of lawful 503A compounding for them to return to. We have corrected the language here, on the tissue-repair peptide bulletin (which carried the error in its headline and has been rewritten end to end), and on the hype-vs-evidence page. We are logging it rather than editing quietly.

Correction 2 — our timeline was too optimistic. We had been saying "6–12+ months" for the rulemaking path. Prior 503A bulks-list cycles have run roughly 8 to 24 months, and post-vote legal commentary says the process "may take over a year." We have widened our stated expectation sitewide to 12–24 months, with final action unlikely before late 2027, and will revise publicly if FDA moves faster.

New coverage worth reading. CNN ran a next-steps explainer on July 31. Kelley Drye's ad-law team is explicit that treating the vote as a green light carries enforcement risk until FDA formally lists a substance. NutraIngredients (July 27) surfaced committee discussion of a possible future dietary-supplement pathway for some of these substances — which would be faster, looser, and worse for patients, since it strips the prescription requirement, sterility standards, per-lot testing, and physician monitoring. We have added a section on that to the post-vote read. Note also that at least one national legal-trade outlet has now twice run a headline stating these peptides were "added to" the 503A list. They were not. Nothing has been added.

New page. The one peptide the panel said no to — DSIP was declined 6–7–1, and it is still being advertised locally in named sleep blends alongside CJC-1295, which was never on the docket at all. How to read a clinic, with four questions to ask.

Five days out, FDA has published nothing. We checked the agency's advisory-committee page for this meeting again this morning. It is still stamped "content current as of 06/29/2026" — the eight pre-meeting briefing documents are posted, but there are no official minutes, no transcript, and no archived webcast. That matters for one specific reason: the Epitalon tally discrepancy we flagged yesterday can only be settled against the official record, so that footnote stays up until FDA posts. We will check weekly and date the correction when it lands. Separately, we have confirmed the shape of the second PCAC meeting: expected before the end of February 2027, covering GHK-Cu, Melanotan II, Cathelicidin (LL-37), Dihexa acetate, and PEG-MGF. Four of those five had previously been in a withdrawn / no-active-review state. FDA has not posted the date or opened the comment docket. Where we stand on each — including the two we would decline regardless of the vote — is in the refreshed peptide roadmap.

Vote counts refined, and one correction. Our first pass recorded the four Day-1 substances as a single favorable bloc. That was imprecise: MOTS-c did not carry the same margin as the other three. BPC-157, KPV, and TB-500 each passed 8–6 with one abstention; MOTS-c passed 7–5 with two abstentions — a narrower result, and worth stating plainly because MOTS-c is a molecule we actually use. The table above now carries the per-substance counts. We have also flagged a live discrepancy in public reporting of the Epitalon tally (7–4–1 in some accounts, 7–5–1 in others) rather than picking one silently; that line will be reconciled against FDA's official minutes when they post. Added national coverage citations to the post-vote read, along with a note on the panel's composition — a majority of yes-voting members have reported ties to the peptide industry, which is a reason to treat a favorable vote as a regulatory signal rather than as evidence of efficacy.

Final tallies confirmed across both sessions. The committee recommended adding six of the seven peptides to the 503A bulks list: BPC-157, KPV, TB-500 (Jul 23, 8–6–1 each), MOTS-c (Jul 23, 7–5–2), Semax (8–5–1) and Epitalon (7–4–1) on Jul 24. The lone rejection was Emideltide (DSIP), voted down narrowly 6–7–1. This is a real break from FDA staff, who had recommended against all seven in their briefing documents. What it means for you: nothing changes on the shelf today. A recommendation is not a rule — FDA still has to accept the input, publish a proposed rule, run a second comment period, and issue a final rule. That path runs 12–24 months — prior 503A bulks-list cycles have taken 8 to 24 months, and legal commentators covering this vote say it “may take over a year.” Final action is unlikely before late 2027. Our posture is unchanged: prescribe inside named indications, source through licensed 503A pharmacies, disclose the uncertainty in writing.

Day two. The committee recommended Semax (8–5–1) and Epitalon (7–4–1) for addition, and declined Emideltide/DSIP (6–7–1) — the only "no" of the meeting. Combined with Thursday's favorable votes on BPC-157, KPV, TB-500 and MOTS-c, that is a 6-of-7 record. The results table above now reflects the recorded outcomes.

Day one. The panel broke from FDA staff and voted 8–6–1 to recommend adding BPC-157, KPV, and TB-500 to the 503A list, and recommended MOTS-c as well on a narrower 7–5–2. These are advisory recommendations, not rules — see the standing explainer above. Patient posture unchanged.

Meeting eve. The public comment docket (FDA-2025-N-6895 at regulations.gov) closes tonight at 11:59 p.m. ET — the last moment to be on record before the committee meets. Our physician comment was filed back in May, so we are already in the record. The FDA's meeting page still has not posted the live-webcast link (the “two business days before” target has passed); we’ll add it here the moment it appears, and the agency may only post it day-of. A pre-staged day-of results table is now live on this page and will fill in as each substance is voted Thursday and Friday. Patient posture is unchanged: nothing on the Limitless menu changes on the strength of a committee vote.

Ten days out. The public comment docket (FDA-2025-N-6895 at regulations.gov) closed on July 9 — comments filed by that date reach the committee in advance of the vote — and the full docket closes July 22, the day before the meeting. FDA's own scientific briefing materials read negative on all seven peptides going in, which is exactly why the "recommendation is not a rule" framing above matters: even a favorable committee vote would still require FDA to publish a proposed rule, run a second comment period, and issue a final rule — a 1+ year path — before any peptide's durable 503A status changes. Nothing on the Limitless menu changes on the day of the vote. We will update this tracker and the patient FAQ within 48 hours of any final FDA action.

Added a plain-language explainer above on what a "yes" vote does and does not mean — because the vote-day coverage will blur the line. PCAC recommends; FDA then has to publish a proposed rule, run a second comment period, and issue a final rule before any peptide's durable 503A status actually changes. Nothing about your protocol changes on the day of the vote. Meeting is now 25 days out; comment window still open through July 22.

Re-verified the full agenda against the FDA's Federal Register notice and advisory-committee calendar (docket FDA-2025-N-6895): seven peptides across two days are confirmed — day one (July 23): BPC-157, KPV, TB-500, MOTS-c; day two (July 24): Emideltide (DSIP), Semax, Epitalon. The earlier vendor-blog chatter that floated a different slate is now superseded by the official posting. Comment window is open through July 22; comments filed by July 9 reach the committee before the vote. Posture unchanged — the meeting is now 30 days out.

Folded the newest skeptic reporting — STAT ("BPC-157: big claims and scant evidence," Feb 3) and The Conversation ("the peptide problem") — into our hype-vs-evidence brief. Our posture is unchanged: prescribe inside named indications, source through 503A only, disclose the uncertainty. Launched this tracker to keep the whole story in one place ahead of the July meeting.

Confirmed the public FDA agenda detail that each day-one peptide (BPC-157, KPV, TB-500, MOTS-c) is nominated as two substances — free base and acetate — which the committee can vote on separately. Updated the meeting explainer and our filed-comment page accordingly.

Filed our formal public comment with the FDA ahead of the vote — a physician's case to include BPC-157, TB-500, and MOTS-c on the 503A bulks list, with per-lot certificate-of-analysis, stability, and written informed-consent conditions attached. Full text published.

Removed CJC-1295 from the standing menu after verifying it is not currently legal for human compounding and is not on the July docket. Tesamorelin remains the GH-axis lead; sermorelin is the alternative; ipamorelin is conditional on partner-pharmacy formulary.

FDA reclassification moved the affected peptides out of Category 2 and opened a pathway toward 503A compounding — the event that set the July 23–24 PCAC review in motion. Corrected 2026-08-04: this created a candidate pathway; it did not restore a legal status these substances previously held. FDA staff made that point explicitly at the July hearing.