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The complexities arise from Section 503A of the Federal Food, Drug, and Cosmetic Act, which relates to the necessary conditions for drug compounding.20 The rules concerning the compounding of therapeutic peptides state that they must come from accredited compounding pharmacies, and the compounded drug must either be compounded from an existing FDA-approved drug product or use drug products included on the 503A bulks list (i.e., the FDA’s roster of compoundable substances.)21 But many therapeutic peptides don’t satisfy either of the 503A conditions

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