Short answer. Condition 7 says the compounded drug product contains only a single active ingredient listed in Appendix A [2]. A vial with two of the six, or one of the six plus something else, does not meet that condition. As of Oct 29, 2026.

Why the policy says it

HHS gives a surveillance reason, not a marketing reason. It says a single ingredient makes it easier to attribute an adverse event or a clinical outcome to a specific substance [2]. That is about tracking harm. It is not a claim that the single ingredient works.

Appendix A is BPC-157, epitalon, KPV, MOTS-c, semax, and TB-500 [2]. "Stacks," "blends," and "wolverine" style combinations that put BPC-157 and TB-500 in one container are the opposite of this condition. Our page BPC-157 vs TB-500 already notes that the two have not been studied together in people. The new policy does not create a combination product.

What still is not allowed to slide

One ingredient does not relax the other nine conditions. The form and route still have to match Appendix B [2]. The pharmacy, federal facility, or physician requirement in the notice still applies [1]. The label still has to say the product is compounded and not for resale [2].

A menu that says "covered by the new HHS policy" and then lists a blend is using the policy's name for a product the policy's text does not describe.

FAQ

Can a pharmacy dispense two of the six as two separate prescriptions? The condition is about each product containing one active ingredient [2]. It does not tell a clinician to write two prescriptions. A clinician decides whether any prescription is appropriate. Sommar Club does not prescribe or sell these six.

Does "single ingredient" mean the vial can include water and a buffer? The policy's words are a single active pharmaceutical ingredient from Appendix A [2]. Ask the pharmacy what it counts as the active ingredient, and read the label.

Sources

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

2. HHS policy, condition 7 and Appendix A. https://www.hhs.gov/sites/default/files/hhs-503a-peptide-enforcement-discretion-policy-appendix-b.pdf

Education only. Not medical or legal advice. As of Oct 29, 2026.