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UPDATE: Two Considerations When Prescribing Compounded Weight Loss Drugs

Our healthcare and business law firm works with many providers who work with compounded medications.  Our firm previously posted Two Considerations When Prescribing Compounded Weight Loss Drugs on July 14, 2025, which gives an overview of several considerations that providers should consider before prescribing compounded weight loss drugs as part of their practice. We have recently encountered other issues related to compounded weight loss drugs, including prescribers offering compounded glucagon-like peptide-1 (“GLP-1”) drugs with ingredients such as retatrutide and cagrilintide, that have created separate legal risks regarding compounded weight loss drugs. If you are interested in prescribing compounded weight loss drugs as part of your practice or would like to discuss this blog post, you may contact our healthcare and business law firm at (404) 685-1662 (Atlanta) or (706) 722-7886 (Augusta), or by email, info@littlehealthlaw.com. You may also learn more about our law firm by visiting www.littlehealthlaw.com.

Background

Retatrutide is a GLP-1 peptide that has shown promise in clinical trials as a weight loss drug, but the Food and Drug Administration (“FDA”) has not approved retatrutide for any nonexperimental use in humans. Cagrilintide is different from a GLP-1 drug and has also shown promise as a weight loss drug along with semaglutide, the active ingredient in popular weight loss drugs like Ozempic® and Wegovy®, and Novo Nordisk, the maker of Ozempic®,  has a clinical trial to determine if cagrilintide can be an effective weight loss drug standing alone.

First Consideration: The FDA Prohibits Providers from Compounding Retatrutide and Cagrilintide

The FDA has recently issued guidance expressing the agency’s concerns about providers prescribing unapproved GLP-1 drugs for weight loss. In this guidance, the FDA explicitly stated that retatrutide and cagrilintide cannot be used in compounding because they “have not been found safe and effective for any condition.” Time will tell if the FDA’s stance on retatrutide and cagrilintide changes if clinical trials show that retatrutide and cagrilintide are safe and effective in humans for weight loss.

Second Consideration: The FDA Is Also Issuing Warning Letters to Drug Manufacturers and Compounding Pharmacies Who Sell Compounded Weight Loss Drugs that Contain Retatrutide and Cagrilintide

The FDA is issuing warning letters to companies that sell to prescribers compounded weight loss drugs that contain retatrutide and cagrilintide. The FDA has also issued a warning letter to a provider who has sold compounded drugs containing retatrutide. These warning letters say that compounded drugs containing retatrutide or cagrilintide are “new drugs” that are required to go through the FDA-approval process, and because these providers are selling the compounded drugs as unapproved drugs, these providers are violating federal law.

The letters also say that selling and marketing these drugs to humans, when they have been labeled “for research use only,” or when they contain directions for intended use when there has been no approved use for such drugs, is considered misbranding and a violation of federal law.

If you need assistance complying with the changing weight loss landscape, would like to prescribe compounded weight loss drugs as part of your practice, or would like to discuss this blog post, you may contact our healthcare and business law firm at (404) 685-1662 (Atlanta) or (706) 722-7886 (Augusta), or by email, info@littlehealthlaw.com. You may also learn more about our law firm by visiting www.littlehealthlaw.com.

 

 

*Disclaimers: Thoughts shared here do not constitute legal advice nor do they form an attorney-client relationship.  All digital presentations by our firm or its attorneys are provided as a public informational resource.  Although intended to be correct and up to date as of the date posted, we cannot guarantee the accuracy of posted information, especially as it relates to individual situations.  We do not routinely update such information.  To determine up-to-date information about the subject matter of this information and proper application to a specific situation, it is important that you consult your healthcare attorney.  Our communications of information through the Internet shall not constitute “presence,” “doing business” or the practice of law in any location, even when a specific state or its laws/rules are referenced.  Our firm maintains offices in Georgia and no other state. Our attorneys are licensed in some, but not all, states.  For each client engagement we accept, our firm undertakes best efforts to ensure we are aware of and adhere to applicable jurisdictional requirements, which may include reviewing local rules, conducting relevant research and collaborating with, or referring a matter to, a local attorney. 
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