Short answer. Condition 8 says adequate oral bioavailability of peptides is inherently difficult. If a peptide is compounded in an oral dosage form, the compounder is expected to keep documentation that the specific formulation achieves an adequate level of oral bioavailability in humans [2]. As of Oct 29, 2026.

Who this sentence is about

Appendix B names an oral route for two of the six [2].

An oral product of a peptide whose row does not name oral use is outside the route limit, even before the bioavailability file comes up [2].

What the record is, and is not

The documentation is about the specific formulation given to a patient, and the compounder keeps it [2]. A blog post that says "peptides don't survive the stomach, except this capsule" is not that file. A study of a different formula is not that file. The policy does not tell patients to judge bioavailability from a product page.

This condition also does not set a dose. It does not say the oral form works for any disease. It says that if a covered compounder makes an oral form, they need human bioavailability documentation for that formula [2].

Ask the pharmacy whether your exact formula has that documentation, and whether the route is one Appendix B names. Sommar Club does not prescribe or sell these peptides.

FAQ

Does a capsule of TB-500 or MOTS-c fall under this policy? Appendix B does not name an oral route for either one [2].

Is "adequate bioavailability" a number I can look up here? The policy does not print a percentage or a dose in the text we used [2]. The record sits with the compounder.

Sources

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

2. HHS policy, condition 8 and Appendix B. 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.