No Peptide Is a Federally Scheduled Controlled Substance — and the SARMs Control Act Never Passed

What the DEA list actually shows

This is checkable, and we checked it. The DEA Diversion Control Division publishes a complete alphabetical list of controlled substances; the current revision is dated 27 August 2026. Searching it for ipamorelin, CJC-1295, MK-677, ibutamoren, tesamorelin, sermorelin, BPC-157, TB-500, semaglutide, the GHRPs, hexarelin, gonadorelin, somatropin, ostarine, LGD-4033 and RAD-140 returns nothing.

The same search run as a control returns testosterone, nandrolone, boldenone, oxandrolone, clostebol and dozens of other anabolic steroids, all Schedule III. The method works; the peptides simply are not there.

The SARMs Control Act was never enacted

Congress.gov records exactly one action on S.2895: referral. No committee vote, no floor vote, no House companion. Both bills would have placed SARMs in Schedule III, and neither addressed peptides at all.

There is an independent check available. If either bill had passed, ostarine and LGD-4033 would appear on the August 2026 DEA list. They do not.

DASCA is real law — and peptides sit outside it

The contrast matters. The Designer Anabolic Steroid Control Act was enacted, on 18 December 2014, amending the anabolic-steroid definition at 21 U.S.C. § 802(41). It contains a catch-all designed to capture novel compounds. But the catch-all is structure-gated:

The order of operations is what decides it. A substance must first be structurally similar to a listed anabolic steroid; only then does the muscle-growth intent element come into play. Peptides are chains of amino acids and share no relationship with the fused four-ring steroid nucleus, so the structural gate is never cleared and the intent prong is never reached.

The same gate is why SARMs — non-steroidal androgen receptor ligands — fall outside DASCA. And that is precisely why a separate SARMs Control Act was proposed. Its introduction is itself evidence that Congress understood DASCA not to cover them.

The statute nobody talks about: § 333(e)

Human growth hormone is not scheduled either — and yet distributing it for bodybuilding, anti-ageing or athletic performance is a standalone federal felony carrying up to five years, ten if a minor is involved. Section 333(e) criminalises distribution for any use other than an HHS-authorised indication pursuant to a physician's order. A prescription alone does not cure it if the use is not an approved one.

Does it reach secretagogues like ipamorelin or MK-677?

Probably not, but this is genuinely unsettled. The statutory definition covers “somatrem, somatropin, or an analogue of either of them.” Those are recombinant growth hormone molecules. Secretagogues work upstream, stimulating the body's own GH release through the GHRH or ghrelin receptors — a GHRH analogue is an analogue of a different hormone, and MK-677 is not a peptide at all but a small molecule.

We found no prosecution charging § 333(e) on a secretagogue-only theory, and no controlling appellate decision either way. That absence is meaningful but it is not a holding. Treat the distinction as an untested argument rather than a safe harbour — particularly since the government rarely needs § 333(e) when FDCA felony counts are available.

So where does the risk actually sit?

In the Food, Drug, and Cosmetic Act. The pattern across every recent prosecution is the same: unapproved new drug counts under §§ 331(d) and 355(a), misbranding counts, and then the escalator at § 333(a)(2) — intent to defraud or mislead — which turns a one-year misdemeanour into a three-year felony. Add smuggling under 18 U.S.C. § 545 where product is imported, plus forfeiture that routinely dwarfs the sentence.

The 2026 Paradigm Peptides sentencing is the clearest marker: 70 months and a $5,000,000 money judgment. Not one controlled-substance count for the peptides themselves. We cover the mechanism in detail in our piece on “research use only”.

Athletes: a separate regime entirely

Anti-doping status is contractual and sporting, not criminal. Under the WADA 2026 Prohibited List, effective 1 January 2026, essentially every peptide in this market is prohibited at all times — the S2 class names the GHRH analogues (CJC-1295, sermorelin, tesamorelin), the secretagogues (ipamorelin, MK-677, hexarelin, the GHRPs), growth factors including TB-500, and testosterone-stimulating peptides including kisspeptin. BPC-157 is named explicitly under S0, the non-approved substances catch-all.

Note that S2 substances are non-Specified, the strictest category, which materially limits an athlete's ability to argue for a reduced sanction. Separately, the Rodchenkov Act creates real criminal exposure — up to ten years — but it is narrow: it reaches the supply chain around major international competition and expressly excludes athletes themselves. Selling ipamorelin to a gym-goer is not a Rodchenkov offence.

The short version

• No peptide, secretagogue or SARM is federally scheduled — verified against the DEA list revised 27 August 2026.
• The SARMs Control Act is not law and never has been. Two bills, two deaths in committee.
• DASCA is real but structure-gated, and peptides do not clear the gate.
• hGH is unscheduled yet carries five-year exposure under § 333(e); whether that reaches secretagogues is untested.
• The genuine criminal risk is FDCA felony misbranding, not the CSA — and adulterated product can import CSA exposure you never intended.

For status by compound and jurisdiction, see the peptide database.