DEA Classification of Peptides: Current Status

One of the most common questions in the peptide space is deceptively simple: are peptides controlled substances? The short answer is no — the vast majority of peptides do not appear on any DEA schedule. But the longer answer involves a tangle of overlapping regulatory frameworks where the DEA, the FDA, and Congress each play different roles in determining what's legal, what's restricted, and what can land you in federal court.

This guide breaks down the DEA's current classification of peptides, explains which (if any) peptides are scheduled, covers the Controlled Substance Analog Act and how it might apply, and clarifies the practical implications for patients, providers, and vendors.

Table of Contents

How the DEA Scheduling System Works
Are Peptides on Any DEA Schedule?
DEA vs. FDA Jurisdiction: Who Controls What
Human Growth Hormone: A Special Case
The Controlled Substance Analog Act
WADA and Sports-Related Restrictions
Why Not Being Scheduled Does Not Mean Legal
FDA Category Classifications vs. DEA Scheduling
Practical Implications for Patients and Providers
Could Peptides Be Scheduled in the Future?
FAQ
The Bottom Line
References

How the DEA Scheduling System Works

The Controlled Substances Act (CSA), enacted in 1970, is the federal law that creates the framework for regulating drugs in the United States. Under the CSA, the DEA classifies drugs and certain chemicals into five schedules based on three criteria:

Accepted medical use. Does the substance have a currently accepted medical use in the United States?
Abuse potential. What is the substance's potential for abuse?
Dependence liability. Does the substance lead to psychological or physical dependence?

The schedules range from most restrictive to least:

Schedule	Criteria	Examples
Schedule I	High abuse potential, no accepted medical use, lack of accepted safety	Heroin, LSD, MDMA, psilocybin
Schedule II	High abuse potential with severe dependence, accepted medical use with restrictions	Fentanyl, oxycodone, amphetamines, methylphenidate
Schedule III	Moderate abuse potential, accepted medical use	Testosterone, anabolic steroids, ketamine, buprenorphine
Schedule IV	Lower abuse potential, accepted medical use	Benzodiazepines (alprazolam, diazepam), zolpidem
Schedule V	Lowest abuse potential, accepted medical use	Cough preparations with codeine, pregabalin

Scheduling has real consequences. Substances on Schedules I through V require DEA registration to prescribe, distribute, or manufacture. Prescribers must comply with the Ryan Haight Act for telemedicine. Pharmacies must maintain detailed records. Violations carry federal criminal penalties.

The scheduling process can be initiated by the DEA, the Department of Health and Human Services (HHS), or Congress. The DEA can temporarily schedule a substance while it conducts a formal evaluation — a power it has used for synthetic cannabinoids and fentanyl analogs.

Are Peptides on Any DEA Schedule?

No. As of early 2026, no therapeutic or research peptide commonly discussed in the wellness and biohacking space appears on any DEA controlled substance schedule.

This includes:

BPC-157 — not scheduled
Semaglutide — not scheduled
Tirzepatide — not scheduled
CJC-1295 — not scheduled
Ipamorelin — not scheduled
Sermorelin — not scheduled
Tesamorelin — not scheduled
MK-677 (ibutamoren) — not scheduled (note: MK-677 is technically a non-peptide growth hormone secretagogue, but it's frequently discussed alongside peptides)
GHK-Cu — not scheduled
PT-141 (bremelanotide) — not scheduled
Melanotan II — not scheduled
Thymosin Alpha-1 — not scheduled
Thymosin Beta-4 (TB-500) — not scheduled
GHRP-2 and GHRP-6 — not scheduled
AOD-9604 — not scheduled
NAD+ — not scheduled
Epithalon — not scheduled

You can verify this by checking the DEA's alphabetical controlled substance list and the 21 CFR Part 1308 schedules of controlled substances. None of these peptides appear in any schedule.

DEA vs. FDA Jurisdiction: Who Controls What

This is where people get confused. A peptide can be simultaneously:

Not a DEA-controlled substance (no scheduling, no DEA registration required)
An unapproved drug under FDA regulation (illegal to market for human use without approval)

The DEA and FDA have different mandates:

Agency	Mandate	Primary Concern	Tool
DEA	Controlled Substances Act	Abuse potential and diversion	Scheduling (Schedules I-V)
FDA	Federal Food, Drug, and Cosmetic Act	Safety, efficacy, and proper marketing	Drug approval, warning letters, seizure

For peptides, the FDA's regulatory authority is far more consequential than the DEA's. The FDA does not need a substance to be scheduled to take enforcement action. It can act against any product marketed as a drug that has not received approval through the NDA process.

Here's the practical distinction:

Possessing peptides for personal research: Not a DEA violation (because they're not scheduled). May not violate FDA rules if no therapeutic claims are made.
Selling peptides for human use: Not a DEA violation. But it is an FDA violation if the peptides are marketed as drugs without approval.
Prescribing unapproved peptides: Not a DEA violation. But it may violate FDA regulations and state medical board standards.

The DEA has worked with the FDA in some enforcement actions involving peptide products — not because the peptides are controlled substances, but as part of joint operations targeting misbranded or unapproved drug products under the FD&C Act. The DEA's role in these cases is typically limited to providing investigative resources or coordinating seizures.

Human Growth Hormone: A Special Case

Human growth hormone (HGH) occupies a unique regulatory position that intersects with peptide therapy because many peptides — CJC-1295, ipamorelin, sermorelin, GHRP-2, GHRP-6, MK-677 — are growth hormone secretagogues designed to stimulate the body's own HGH production.

HGH is not a DEA-controlled substance. The DEA's Office of Diversion Control has stated this explicitly. HGH does not appear on any schedule.

However, HGH has its own federal restrictions under the Crime Control Act of 1990, which amended the FD&C Act to create special distribution rules for HGH:

Distribution is restricted by statute. Federal law prohibits the distribution of HGH for any purpose other than treatment of a disease or other recognized medical condition authorized by the Secretary of HHS, and pursuant to a valid prescription.
"Anti-aging" is not an approved use. The FDA does not recognize aging as a disease. Prescribing HGH for anti-aging purposes technically falls outside the authorized medical conditions.
Criminal penalties exist for improper distribution. While simple possession of HGH is not a criminal offense, distributing HGH for unapproved purposes can carry criminal penalties.

There have been legislative proposals to make HGH a Schedule III controlled substance — most notably from Senators Grassley and Schumer — which would give the DEA full authority to investigate and prosecute illegal HGH distribution. As of 2026, these proposals have not been enacted.

The relevance for peptide therapy: growth hormone secretagogue peptides themselves are not subject to HGH distribution restrictions. Sermorelin stimulates your pituitary gland to produce more HGH, but sermorelin is not HGH. The distinction matters legally, even though the end result — elevated growth hormone levels — is similar.

The Controlled Substance Analog Act

The Federal Analogue Act (21 U.S.C. 813), part of the Controlled Substances Act, is designed to address substances that are not formally scheduled but are chemically or pharmacologically similar to substances that are.

Under this law, a "controlled substance analogue" is a substance that:

Is structurally substantially similar to a Schedule I or II substance, OR
Has pharmacological effects substantially similar to a Schedule I or II substance, AND
Is intended for human consumption

If a substance meets these criteria, it can be treated as a Schedule I controlled substance for purposes of federal criminal prosecution — even without being formally scheduled.

Could this apply to peptides? In theory, the Analog Act could potentially apply if a peptide were structurally or pharmacologically similar to a Schedule I or II substance. In practice, this is extremely unlikely for current peptides of interest, for several reasons:

No peptides are currently scheduled in Schedules I or II. The Analog Act requires similarity to a substance that is already scheduled. Since no peptides are in Schedules I or II, there is no reference substance to be "analogous" to.
HGH is not scheduled. Growth hormone secretagogue peptides might be considered pharmacologically related to HGH (they stimulate its release), but since HGH itself is not a DEA-scheduled substance, the Analog Act does not apply.
Peptides are structurally distinct from scheduled drugs. Peptides are chains of amino acids. They are structurally different from the small molecules (opioids, amphetamines, synthetic cannabinoids) that the Analog Act was designed to address.

The Analog Act has been used primarily against designer drugs — synthetic compounds intentionally modified to evade scheduling while maintaining psychoactive effects. Peptides do not fit this pattern.

That said, the law is written broadly, and a prosecutor with creative legal theory could argue that a specific peptide falls within its scope. No such prosecution has occurred as of early 2026 for any therapeutic peptide.

While the DEA does not schedule peptides, the World Anti-Doping Agency (WADA) maintains its own prohibited substance list that includes many of them. This is relevant for competitive athletes, though WADA rules carry no criminal penalties for non-athletes.

Peptides on the WADA Prohibited List include:

Category	Prohibited Peptides
Growth Hormone Secretagogues	CJC-1295, ipamorelin, GHRP-2, GHRP-6, hexarelin, MK-677
Growth Hormone Releasing Hormones	Sermorelin, tesamorelin
GLP-1 Receptor Agonists	Selected compounds in certain competitive contexts
Melanocortin Agonists	Melanotan II (due to potential performance effects)
Other	Various experimental peptides under S0 (non-approved substances)

The WADA list is updated annually. Athletes subject to anti-doping testing should check the current list before considering any peptide, including those available through legitimate medical channels.

Notably, WADA's "S0" category prohibits all "non-approved substances" — meaning any pharmacological substance not addressed by other sections of the list and not currently approved for human therapeutic use by any governmental regulatory health authority. This captures virtually every research peptide, regardless of its specific mechanism.

Why Not Being Scheduled Does Not Mean Legal

This is the single most important point in this article, and it's the one most often misunderstood.

The absence of DEA scheduling does not make a peptide legal for human use. It means:

You won't face DEA-specific criminal charges for possession
Prescribers don't need DEA registration to prescribe the peptide (beyond their standard registration)
Pharmacies don't need to maintain DEA-specific records for the substance
The Ryan Haight Act's in-person visit requirement does not directly apply

But the FDA's regulatory authority is independent of DEA scheduling. An unapproved drug is an unapproved drug regardless of whether it appears on a controlled substance schedule. The FDA can:

Issue warning letters to companies selling unapproved peptides
Seize products at the border through import alerts
Seek injunctions to halt sales
Pursue criminal charges under the FD&C Act for distributing adulterated or misbranded drugs

State medical boards can discipline providers who prescribe unapproved peptides. State attorneys general can pursue consumer protection actions against companies marketing them. Malpractice liability exists regardless of scheduling status.

In other words: the DEA schedule is just one of many regulatory frameworks that apply to peptides. Not being on it removes one layer of restriction. Multiple other layers remain.

For a complete picture of the legal status of peptides by state and the FDA's regulatory framework, see our regulatory coverage.

FDA Category Classifications vs. DEA Scheduling

Another source of confusion is the relationship between the FDA's "Category" system for compounding substances and the DEA's scheduling system. These are entirely separate classification systems.

System	Agency	Purpose	Impact
DEA Schedule (I-V)	DEA	Classifies substances by abuse potential and medical use	Criminal penalties, prescribing restrictions, registration requirements
FDA Category (1, 2, 3)	FDA	Classifies bulk substances for compounding eligibility	Determines whether a substance can be legally compounded

The FDA's Category system was created under Section 503A of the FD&C Act to evaluate which bulk drug substances can be used in compounding:

Category 1: Sufficient data supports safety for compounding. The substance can be compounded by licensed pharmacies.
Category 2: Significant safety concerns or insufficient data. The substance cannot be compounded.
Category 3: Under evaluation; insufficient data to place in Category 1 or 2.

A peptide can be in FDA Category 2 (cannot be compounded) while simultaneously having no DEA schedule (no controlled substance restrictions). BPC-157 is a perfect example: it's Category 2 under the FDA (banned from compounding) but has no DEA classification whatsoever.

This distinction matters because people sometimes interpret "banned from compounding" as equivalent to "scheduled" or "illegal to possess." These are different regulatory actions with different legal consequences. The FDA compounding ban prevents pharmacies from making the product. DEA scheduling would make possession itself a potential criminal offense. See our BPC-157 legal status guide for more detail.

Practical Implications for Patients and Providers

Understanding the DEA's (non-)classification of peptides has several practical implications:

For patients:

Possessing peptides for personal use is not a federal controlled substance violation. However, purchasing unapproved peptides marketed for human use may involve a seller who is violating FDA regulations.
If you're receiving peptide therapy from a licensed provider who prescribes legally compoundable peptides, the DEA scheduling question is largely irrelevant to your care.
If you're purchasing "research peptides" online, the legal risk comes from the FDA side (unapproved drug distribution) rather than the DEA side (controlled substance violations).

For providers:

Standard DEA registration is sufficient for prescribing peptides. No special DEA registration or reporting is required because they are not scheduled.
The Ryan Haight Act's in-person telehealth requirements do not apply to non-scheduled peptides (though state telehealth laws may impose their own requirements).
The primary regulatory exposure for prescribing peptides comes from the FDA and state medical boards, not the DEA.
Prescribing testosterone (Schedule III) alongside peptide therapy does require full DEA compliance for the testosterone component.

For vendors:

Selling peptides does not require DEA registration because they are not controlled substances.
This does not exempt vendors from FDA regulation. Marketing peptides for human use without FDA approval violates the FD&C Act regardless of DEA status.
State-level regulations may impose additional requirements beyond federal law.

Could Peptides Be Scheduled in the Future?

It's possible but unlikely in the near term for the peptides currently popular in the wellness space. Here's why:

Arguments for potential scheduling:

If a peptide were found to have significant abuse potential (e.g., if growth hormone secretagogues were widely abused for athletic performance), the DEA could initiate scheduling proceedings.
Legislative action could schedule specific peptides. The HGH scheduling proposals from Senators Grassley and Schumer, while not enacted, show that Congress is willing to consider peptide-adjacent scheduling.
If peptides were used as cutting agents or analogues for scheduled substances, the DEA might take interest.

Arguments against near-term scheduling:

Most peptides do not produce the immediate psychoactive effects associated with substances the DEA typically schedules (euphoria, sedation, stimulation).
The DEA's scheduling resources are focused on fentanyl analogs, synthetic opioids, and other substances causing acute public health crises.
The FDA's existing regulatory authority (unapproved drug enforcement) is sufficient to address most peptide-related concerns without DEA involvement.
Scheduling would require a formal evaluation of each substance's abuse potential — a resource-intensive process for compounds without documented abuse patterns.

The most likely near-term scenario is that peptide regulation continues to be driven primarily by the FDA's compounding and drug approval framework, with the DEA playing a supporting role in joint enforcement actions when needed.

FAQ

Are peptides controlled substances?

No. As of 2026, no commonly discussed therapeutic or research peptide appears on any DEA controlled substance schedule. This includes BPC-157, semaglutide, tirzepatide, CJC-1295, ipamorelin, sermorelin, GHK-Cu, MK-677, and all other peptides frequently discussed in the wellness space.

Is it illegal to possess peptides?

Possession of peptides is not a federal controlled substance violation because they are not scheduled. However, purchasing unapproved peptides marketed for human use may involve a transaction where the seller is violating FDA regulations. The legal risk for individual possession varies by state and depends on the context of the purchase.

Why does the FDA restrict peptides if the DEA doesn't schedule them?

The FDA and DEA have different mandates. The DEA focuses on substances with abuse potential and dependence liability. The FDA focuses on whether products marketed for human use are safe and effective. A substance does not need to be addictive to be dangerous — it just needs to be untested. The FDA's concern with peptides centers on safety (insufficient human data), quality (unregulated manufacturing), and marketing (unapproved drug claims), not on abuse potential.

Could the Federal Analogue Act apply to peptides?

In theory, the Analog Act could apply to a substance that is structurally or pharmacologically similar to a Schedule I or II controlled substance. In practice, no peptides are similar to any currently scheduled substance, and no prosecution under the Analog Act has targeted any therapeutic peptide. The Analog Act was designed for designer drugs that mimic scheduled psychoactive substances.

Is human growth hormone a controlled substance?

No. HGH is not on any DEA schedule. However, it has separate federal distribution restrictions under the Crime Control Act of 1990 that limit its use to approved medical conditions. Growth hormone secretagogue peptides (like CJC-1295, ipamorelin, and sermorelin) are neither DEA-scheduled nor subject to HGH-specific distribution restrictions — they are regulated only under the FDA's general drug authority.

Do I need a DEA license to prescribe peptides?

You need a standard DEA registration to prescribe any controlled substance, but since peptides are not controlled substances, the DEA registration is not required for peptide prescribing specifically. Most prescribers already have DEA registration for other medications. The question of whether you can legally prescribe a specific peptide depends on FDA regulations and state medical board standards, not DEA classification.

The Bottom Line

The DEA's relationship with peptides is, for now, a non-relationship. No commonly discussed peptide appears on any controlled substance schedule. The Controlled Substance Analog Act is theoretically applicable but practically irrelevant for current therapeutic peptides. Even human growth hormone — the closest substance to a scheduled peptide — remains unscheduled despite legislative attempts to change that.

But this absence of DEA scheduling should not be confused with a green light. The FDA's authority over unapproved drugs is independent of and, for peptides, far more consequential than the DEA's scheduling power. A peptide that is not scheduled can still be banned from compounding (Category 2), subject to import seizure, targeted in warning letters, and the basis for state medical board discipline.

For consumers and providers, the practical message is: check the FDA's regulatory status and your state's rules, not just the DEA schedule. The DEA schedule tells you whether a substance has been identified as having abuse potential. It says nothing about whether the substance is safe, effective, approved, or legal to prescribe.

For more on the regulatory framework governing peptides, see our complete FDA regulation timeline, the state-by-state legal guide, and our analysis of FDA warning letters to peptide companies.

References

DEA. "Drug Scheduling." https://www.dea.gov/drug-information/drug-scheduling
DEA Diversion Control Division. "Controlled Substance Schedules." https://deadiversion.usdoj.gov/schedules/schedules.html
DEA. "Controlled Substances — Alphabetical Order." https://www.deadiversion.usdoj.gov/schedules/orangebook/c_cs_alpha.pdf
Electronic Code of Federal Regulations. "21 CFR Part 1308 — Schedules of Controlled Substances." https://www.ecfr.gov/current/title-21/chapter-II/part-1308
Congressional Research Service. "The Controlled Substances Act (CSA): A Legal Overview for the 119th Congress." https://www.congress.gov/crs-product/R45948
United States Code. "21 USC 812: Schedules of Controlled Substances." https://uscode.house.gov/view.xhtml?req=(title:21+section:812+edition:prelim)
United States Code. "21 USC 813: Treatment of Controlled Substance Analogues." https://uscode.house.gov/view.xhtml?req=(title:21+section:813+edition:prelim)
NCBI Bookshelf. "Drug Enforcement Administration Drug Scheduling." StatPearls. https://www.ncbi.nlm.nih.gov/books/NBK557426/
U.S. Senate. "Grassley, Schumer Push Proposals to Curb Abuse of Performance-Enhancing Drugs." https://www.grassley.senate.gov/news/news-releases/grassley-schumer-push-proposals-curb-abuse-performance-enhancing-drugs
Medical Justice. "Can Anti-Aging Doctors Prescribe Human Growth Hormone as Elixir of Youth?" https://medicaljustice.com/blog/can-anti-aging-doctors-prescribe-human-growth-hormone-as-elixir-of-youth/
Florida Healthcare Law Firm. "Are Peptides Legal in the U.S.? Complete 2025 Legal Guide." https://floridahealthcarelawfirm.com/are-peptides-legal/
Holt Law. "Deep Dive: Regulatory Status of Popular Compounded Peptides." https://djholtlaw.com/deep-dive-regulatory-status-of-popular-compounded-peptides/
Frier Levitt. "Regulatory Status of Peptide Compounding in 2025." https://www.frierlevitt.com/articles/regulatory-status-of-peptide-compounding-in-2025/
FDA. "Clinical Pharmacology Considerations for Peptide Drug Products." https://www.fda.gov/regulatory-information/search-fda-guidance-documents/clinical-pharmacology-considerations-peptide-drug-products