What stands out: Enforcement focus on mass-marketing, not patient-specific compounding Clear limits on advertising claims, including prohibitions on calling compounded products generic, the same as, or clinically proven Reinforcement of FD&C Act authorities, including misbranding provisions and Section 503A requirements Shift as shortages resolve, removing the legal basis for broad compounding of GLP-1 drugs Expanded compliance tools, including warning letters, seizure, and injunction where violations persist Bottom line: This signals a firmer FDA posture as the GLP-1 market matures, reinforcing long-standing distinctions between FDA-approved drugs and unapproved compounded preparations, particularly when promoted directly to consumers at scale
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doi:10.1177/2042018810380215 [3] Hu D, Xie F, Xiao Y, et al