Short answer. Appendix B does not say "the peptide, any salt." It names BPC-157 acetate, TB-500 acetate, epitalon acetate, KPV acetate, and MOTS-c acetate. It names semax free base [2]. As of Oct 29, 2026.

Why the salt is not a footnote

A salt is part of the identity. The policy says identity includes the amino acid sequence, chemical structure, molecular weight, and molecular formula [2]. Acetate shows up in those formulas as an acetic acid addition. Semax's formula, as printed, does not include that addition [2].

The policy also says CDER looked at more than one form for several of these, and recommended against listing. The discretion sentences that follow are still form-specific [2]. A free-base BPC-157 is not the acetate sentence. A semax acetate is not the free-base sentence.

What to compare

Put the certificate next to Appendix B.

"Acetate" on a research-chemical label does not by itself meet the other nine conditions. The maker still has to be the FDA-registered original manufacturer, the route still has to match, and the compounder still has to be one of the three the notice names [1][2].

FAQ

Is the free base safer? The policy does not rank salts that way. It specifies which identity the discretion covers [2].

What if the certificate says the peptide name and skips the salt? Ask for the form. Identity in this policy includes the formula [2].

Sources

1. HHS notice, FR Doc. 2026-22192, filed Oct 28, 2026. https://public-inspection.federalregister.gov/2026-22192.pdf

2. HHS policy, Appendix B identities. https://www.hhs.gov/sites/default/files/hhs-503a-peptide-enforcement-discretion-policy-appendix-b.pdf

Sommar Club does not prescribe or sell these six. Education only. Not medical or legal advice. As of Oct 29, 2026.