RFK Jr on Joe Rogan: 14 Peptides Moving Out of Category 2

On February 27, 2026, HHS Secretary Robert F. Kennedy Jr. appeared on The Joe Rogan Experience (Episode #2461) and made what may prove to be the most consequential statement about peptide regulation in years. Roughly 90 minutes into the conversation, Kennedy told Rogan that approximately 14 of the 19 peptides currently on the FDA’s Category 2 restricted list would be moved back to Category 1 — restoring their eligibility for compounding by licensed pharmacies.

The announcement sent ripples through the peptide research community, the compounding pharmacy industry, and even public equity markets (HIMS stock surged approximately 13.5% on the day of the episode’s release). But what exactly did RFK Jr. say, what does it mean in regulatory terms, and — critically — has anything formally changed yet?

This article breaks down the full context: the FDA’s category system, the 19 peptides originally restricted, which 14 are expected to move, which may remain restricted, and what researchers and compounding pharmacies should know right now.

Understanding the FDA Category System for Compounding

Before diving into what RFK Jr. announced, it is important to understand the regulatory framework at play. Under Section 503A of the Federal Food, Drug, and Cosmetic (FD&C) Act, the FDA maintains what is commonly referred to as the “bulks list” — a list of bulk drug substances that may or may not be used by compounding pharmacies to prepare patient-specific medications.

The FDA sorts these substances into three categories:

• Category 1 — Eligible for compounding. Licensed pharmacies may compound these substances into preparations with a valid prescription. This is the “green light” status.
• Category 2 — Significant safety concerns identified. Substances in this category cannot be compounded under 503A. This is effectively a restriction that removes access through compounding pharmacies.
• Category 3 — Under evaluation. The FDA has not yet made a final determination, and additional review is ongoing.

The distinction between Category 1 and Category 2 has enormous practical consequences. When a peptide sits in Category 1, a physician can write a prescription and a 503A compounding pharmacy can prepare it for a specific patient. When that same peptide is moved to Category 2, that pathway is shut off entirely — patients and clinicians lose access to compounded formulations, and the substance can only be obtained through an FDA-approved drug product (if one exists) or, in practice, not at all through legitimate channels.

How 19 Peptides Ended Up in Category 2

In September 2023, under the Biden administration, the FDA placed 19 peptides on the Category 2 list. The decision was based on the agency’s assessment that these substances posed “significant safety risks” that made them unsuitable for compounding under Section 503A.

The move was controversial from the start. Critics — including many in the clinical research and integrative medicine communities — argued that the Category 2 designation was overly broad, that the safety concerns cited by the FDA were not well-supported by the available scientific literature for many of the listed peptides, and that the practical effect was to eliminate patient access to compounds that clinicians had been prescribing for years.

The full list of 19 peptides placed in Category 2 in September 2023:

1. AOD-9604
2. BPC-157
3. Cathelicidin LL-37
4. CJC-1295
5. Dihexa Acetate
6. Emideltide (DSIP)
7. Epitalon
8. GHK-Cu
9. Ibutamoren (MK-677)
10. Ipamorelin
11. Kisspeptin-10
12. KPV
13. Melanotan II
14. PEG-MGF
15. MOTS-C
16. Selank
17. Semax
18. Thymosin Alpha-1
19. TB-500 (Thymosin Beta-4 fragment)

September 2024: The First Round of Removals

The story did not remain static. In September 2024, the FDA removed five peptides from Category 2 based on nomination withdrawals. The five peptides removed were:

• AOD-9604
• CJC-1295
• Ipamorelin
• Thymosin Alpha-1
• Selank

These removals were procedural in nature — the nominations that had originally placed them on the bulks list under Category 2 were withdrawn, and the FDA removed them accordingly. While this did not automatically restore them to Category 1 compounding eligibility in all cases, it removed the explicit Category 2 restriction.

Then, on January 7, 2025, the FDA published an updated interim policy on bulk drug substances used in compounding, further clarifying the regulatory landscape. The situation remained in flux heading into 2026.

What RFK Jr. Said on Joe Rogan (Episode #2461)

This brings us to February 27, 2026. During his appearance on The Joe Rogan Experience, HHS Secretary Kennedy directly addressed the peptide issue. His key statements included:

“My hope is that they’re going to get moved to a place where people have access from ethical suppliers.”

“We created the black market.”

Kennedy argued that the Category 2 restrictions had been counterproductive. Rather than protecting public safety, he contended, the restrictions had pushed users away from regulated compounding pharmacies and toward unregulated grey-market suppliers — the opposite of the intended effect. He stated that the FDA was “looking at the science” and indicated that a reclassification of approximately 14 of the remaining peptides could happen “within weeks.”

The specific number — 14 out of the original 19 — is notable. When combined with the five already removed in September 2024, this would account for all 19 originally listed peptides, with approximately five expected to remain under some form of restriction.

The 14 Peptides Expected to Move to Category 1

Based on RFK Jr.’s statements and subsequent reporting, the following 14 peptides are expected to be reclassified from Category 2 to Category 1, restoring their eligibility for compounding:

• BPC-157
• Thymosin Alpha-1
• TB-500
• AOD-9604
• CJC-1295
• Ipamorelin
• Selank
• Semax
• KPV
• MOTS-C
• GHK-Cu
• Epitalon
• Emideltide (DSIP)
• Kisspeptin-10

Note that this list includes the five peptides already removed from Category 2 in September 2024 (AOD-9604, CJC-1295, Ipamorelin, Thymosin Alpha-1, and Selank). Their inclusion in the “14” likely reflects their formal reclassification into Category 1 status, rather than simply being removed from Category 2 without a definitive new designation.

The ~5 Peptides Expected to Remain Restricted

Approximately five peptides from the original 19 are expected to remain in Category 2 or under continued restriction. These are:

• Melanotan II
• Dihexa Acetate
• PEG-MGF
• Cathelicidin LL-37
• Ibutamoren (MK-677)

The reasons for keeping these five restricted have not been detailed in RFK Jr.’s public comments. However, several of these peptides have faced particular regulatory scrutiny: Melanotan II has long been flagged for safety concerns by multiple international regulatory bodies; MK-677, while technically a growth hormone secretagogue rather than a peptide, has been the subject of adverse event reports; and Dihexa has limited human safety data relative to its potency.

Full Comparison Table: All 19 Peptides

Peptide	Primary Research Area	Sept 2024 Status Change	Expected New Status
AOD-9604	Metabolic research, lipolysis	Removed from Cat. 2	Category 1
BPC-157	Tissue repair, gastrointestinal research	No change	Category 1
Cathelicidin LL-37	Antimicrobial peptide research	No change	Remains restricted
CJC-1295	Growth hormone secretagogue research	Removed from Cat. 2	Category 1
Dihexa Acetate	Cognitive and neurotrophic research	No change	Remains restricted
Emideltide (DSIP)	Sleep and stress response research	No change	Category 1
Epitalon	Telomerase and aging research	No change	Category 1
GHK-Cu	Wound healing, skin remodeling research	No change	Category 1
Ibutamoren (MK-677)	Growth hormone secretagogue research	No change	Remains restricted
Ipamorelin	Growth hormone releasing peptide research	Removed from Cat. 2	Category 1
Kisspeptin-10	Reproductive endocrinology research	No change	Category 1
KPV	Anti-inflammatory peptide research	No change	Category 1
Melanotan II	Melanocortin receptor research	No change	Remains restricted
PEG-MGF	Muscle tissue and recovery research	No change	Remains restricted
MOTS-C	Mitochondrial and metabolic research	No change	Category 1
Selank	Anxiolytic and immunomodulatory research	Removed from Cat. 2	Category 1
Semax	Neuroprotective and cognitive research	No change	Category 1
Thymosin Alpha-1	Immune modulation research	Removed from Cat. 2	Category 1
TB-500	Tissue repair and recovery research	No change	Category 1

Regulatory Timeline

Date	Event	Significance
September 2023	FDA places 19 peptides on Category 2	All 19 peptides barred from 503A compounding
September 2024	FDA removes 5 peptides from Category 2	AOD-9604, CJC-1295, Ipamorelin, Thymosin Alpha-1, Selank removed following nomination withdrawals
January 7, 2025	FDA publishes updated interim policy	Clarifies compounding framework for bulk drug substances
February 27, 2026	RFK Jr. announces on JRE #2461	States ~14 peptides will move to Category 1; reclassification expected “within weeks”
TBD	Formal FDA publication	No official Federal Register notice or regulatory action published as of March 9, 2026

The Critical Caveat: No Formal Regulatory Action Yet

This is the single most important point in this entire article, and it warrants its own section: as of March 9, 2026, no formal FDA regulatory action has been published confirming the reclassification of any peptide from Category 2 to Category 1 based on RFK Jr.’s announcement.

What RFK Jr. stated on a podcast — even as the sitting HHS Secretary — does not constitute regulatory action. Federal regulatory changes follow a defined administrative process. For a peptide to formally move from Category 2 to Category 1, the FDA must publish the relevant determination, typically through the Federal Register or through updates to the official bulks list with proper notice and comment procedures.

Until that formal publication occurs:

• The legal status of these peptides has not changed.
• Compounding pharmacies cannot begin compounding Category 2 substances based solely on a podcast statement.
• The regulatory framework that existed before February 27, 2026, remains in effect.

This does not mean RFK Jr.’s statements are without significance. As HHS Secretary, he oversees the FDA, and his public statements carry considerable weight as signals of policy direction. But there is a meaningful difference between a policy signal and a completed regulatory action, and researchers, clinicians, and compounding pharmacies should be aware of that distinction.

The “Black Market” Argument

One of the more striking elements of RFK Jr.’s comments was his direct acknowledgment that the Category 2 restrictions had, in his view, created an unregulated market. His statement — “We created the black market” — echoed an argument that industry observers and clinicians had been making since the original 2023 restrictions.

The logic runs as follows: when patients and clinicians lose access to compounded peptides through regulated 503A pharmacies, demand does not disappear. Instead, it shifts to unregulated suppliers — often operating online, often outside the United States, and often without the quality controls that compounding pharmacies are required to maintain. The result, critics argue, is that patients end up using substances of unknown purity and potency, which is a worse safety outcome than the regulated compounding the restrictions were designed to address.

Whether one agrees with this framing or not, it represents a significant rhetorical shift from the sitting HHS Secretary. The Biden-era FDA’s position was that Category 2 restrictions were necessary to protect patients from substances with insufficient safety profiles. The current administration appears to be signaling that the restrictions themselves may have introduced greater risk than the substances they were meant to control.

Market Reaction

The financial markets responded swiftly to RFK Jr.’s comments. Shares of Hims & Hers Health (NYSE: HIMS), which operates telehealth and compounding pharmacy services, surged approximately 13.5% on the day of the announcement. The market reaction underscores the commercial significance of peptide compounding access — the ability for 503A pharmacies to compound these substances represents a meaningful revenue stream for companies in the telehealth and compounding space.

What This Means for Peptide Research

For the research community, the potential reclassification of 14 peptides to Category 1 would represent a significant expansion of access. Many of these peptides — including BPC-157, TB-500, Semax, and MOTS-C — are the subjects of active preclinical and clinical investigation. Their availability through regulated compounding channels has direct implications for researchers working with institutional review boards and clinical protocols that require sourcing from licensed pharmacies.

However, it is essential to reiterate: the formal regulatory process has not been completed. Researchers should monitor the FDA’s official bulks list and Federal Register publications for the definitive regulatory determination. Until then, the existing Category 2 restrictions remain the operative legal framework.

For those conducting research with peptides such as BPC-157, CJC-1295, Ipamorelin, Sermorelin, and others discussed in this article, suppliers like NorthPeptide carry many of these compounds for research purposes, providing third-party tested reference materials to support ongoing scientific investigation.

Looking Ahead

RFK Jr. indicated that the reclassification could happen “within weeks” of his February 27, 2026 appearance. As of this writing on March 9, 2026, no formal publication has appeared. The timeline for federal regulatory actions is notoriously difficult to predict — “within weeks” in the context of FDA rulemaking could mean anything from days to months.

What is clear is that the policy direction has shifted. The current HHS leadership has publicly stated its intention to restore compounding access for the majority of the restricted peptides. Whether that intention translates into formal regulatory action on the timeline suggested, or whether the process encounters procedural delays, remains to be seen.

We will update this article as the regulatory situation develops. Researchers and clinicians are encouraged to rely on official FDA publications rather than media reports — including this one — for regulatory compliance decisions.

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Research Disclaimer

This article is provided for informational and educational purposes only. Nothing in this article constitutes medical advice, a recommendation for use, or a claim regarding the safety or efficacy of any peptide or substance mentioned. All peptides referenced in this article are discussed solely in the context of scientific research. NorthPeptide products are sold exclusively for laboratory research and are not intended for human consumption. Researchers are responsible for ensuring compliance with all applicable federal, state, and local regulations. Always consult the FDA’s official publications for current regulatory status of any substance.

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Summary of Key Research References

Study	Year	Type	Focus	Reference
Obesity Medicine Association	2024	Position Statement FAQ	Compounded peptides — regulatory framework and clinical considerations	PMC11369382
Mancinelli et al.	2024	Review	FDA-approved peptide analogues — GLP-1, GIP, GHRH, and related frontiers	PMC10968328
Wang et al.	2023	Review	Prevalence of peptide therapeutic products — a critical review	PMC10655677
Nussinov et al.	2025	Review	Regulatory guidelines for analysis of therapeutic peptides and proteins	PMC11806371
Al Musaimi et al.	2025	Review	2024 FDA TIDES harvest — peptide and oligonucleotide approvals	PMC11945313
Gorman	2016	Commentary	FDA draft guidances on compounding — rules limiting distribution	PMC4959613
Driscoll	2018	Commentary	Compounding law five years later — FDA implementation and industry criticism	PMC5912243

Written by NorthPeptide Research Team