vialauditThe Roundup
GHK-CU·US LEGAL STATUS·LAST CHECKED 12 OCT 2026

Is GHK-Cu legal?

In cosmetics, yes. GHK-Cu is a common cosmetic ingredient. As an injectable drug it has no FDA approval, so selling it for injection breaks federal drug law. It is not a controlled substance. Pharmacies may compound non-injectable forms under FDA's interim policy; injectable forms are not eligible.

RESEARCH-LABELLED SALE
Cosmetic use only
PHARMACY COMPOUNDING
Non-injectable only (Category 1)
PRESCRIPTION
No approved product
WADA 2026
Unclear

DESCRIBES THE LAW · NOT LEGAL ADVICE · NO DOSING INFORMATION

Federal, compounding and sport status

CHECKED 12 OCT 2026

Federal status

FDA approval
supplement category
DEA scheduling
not scheduled
503A compounding
FDA interim category: Category 1 (under evaluation; FDA does not intend to act against compliant pharmacies)
503A Bulks List: not on list
Split by route. Non-injectable GHK-Cu is back in Category 1 (FDA's 14 May 2026 categories list), so FDA does not intend to act against 503A pharmacies compounding it under the interim policy's conditions. Injectable GHK-Cu is listed under 'nominated but withdrawn' and is not eligible. FDA says the PCAC will review GHK-Cu before the end of February 2027; no date set as of 12 Oct 2026.
FDA Warning Letters
none on record for this compound
Shortage status
not currently on shortage list
Sale framing
Research-use-only posture: Same posture as other peptides — RUO label is not a safe harbor when human-use intent is evident for injectable forms.
Personal possession: Not federally scheduled. Topical cosmetic GHK-Cu is sold OTC in skincare; injectable forms are in a different regulatory category.

Sport-body status

WADA 2026
unclear
Not named. As a cosmetic ingredient it is not a drug, but injected GHK-Cu has no drug approval anywhere, which is the S0 test. Check with your anti-doping organisation. From 1 Jan 2027 WADA's List names 'peptides' among the S0 examples, which in our reading makes injected GHK-Cu harder to treat as permitted. WADA has not named GHK-Cu or ruled on it.
USADA
unknown
NCAA
unknown

What we couldn’t verify

State rules

NONE FOUND

We found no state statute, board rule or enforcement action that names GHK-Cu. The federal position above applies in all 50 states and DC.

What changed at the last check

4 CHANGES
DateFieldWasNowWhy
12 Oct 2026WADA 20272027 List not yet publishedunclear (S0 now names peptides as a class example)The 2027 List, published 21 Sep 2026, adds 'peptides' to the S0 examples. GHK-Cu is not named; our reading is that injected use leans toward S0. Status kept as unclear. source ↗
12 Oct 2026WADA 2026not prohibitedunclearNot named. As a cosmetic ingredient it is not a drug, but injected GHK-Cu has no drug approval anywhere, which is the S0 test. Check with your anti-doping organisation. source ↗
12 Oct 2026OH state noteOhio BOP Feb 2026 peptide guidance directs cessation of injectable Category 2 style peptide compounding generally.removedRemoved. The entry described a OH action that does not name GHK-Cu; it applied federal-level or class-wide facts by analogy. source ↗
12 Oct 2026503A interim categorynot on any listCategory 1 (non injectable only)FDA restored non-injectable GHK-Cu to Category 1 in May 2026 after a nominator clarified its withdrawal. source ↗

Questions

3 ANSWERS
Is GHK-Cu legal in the US?

In cosmetics, yes. GHK-Cu is a common cosmetic ingredient. As an injectable drug it has no FDA approval, so selling it for injection breaks federal drug law. It is not a controlled substance. Pharmacies may compound non-injectable forms under FDA's interim policy; injectable forms are not eligible.

Can a pharmacy compound GHK-Cu?

Split by route. Non-injectable GHK-Cu is back in Category 1 (FDA's 14 May 2026 categories list), so FDA does not intend to act against 503A pharmacies compounding it under the interim policy's conditions. Injectable GHK-Cu is listed under 'nominated but withdrawn' and is not eligible. FDA says the PCAC will review GHK-Cu before the end of February 2027; no date set as of 12 Oct 2026.

Is GHK-Cu banned in sport?

Unclear. Not named. As a cosmetic ingredient it is not a drug, but injected GHK-Cu has no drug approval anywhere, which is the S0 test. Check with your anti-doping organisation. From 1 Jan 2027 WADA's List names 'peptides' among the S0 examples, which in our reading makes injected GHK-Cu harder to treat as permitted. WADA has not named GHK-Cu or ruled on it.

Sources

6 DOCUMENTS
  1. FDA approval record
  2. DEA controlled-substance schedules
  3. FDA 503A compounding position
  4. WADA 2026 Prohibited List
  5. Source for: WADA 2027
  6. Source for: OH state note
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