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  • Charles D. Snow

    • The PEPTIDE-L Wave Reaches HHS: Enforcement Discretion … Not the Finish LineOctober 28th, 2026

      Well, readers, we finally have an answer.  Or at least an interim answer.  And, yes, it comes with “guardrails.”  After the July 23-24, 2026, Pharmacy Compounding Advisory Committee (PCAC) meeting left compounders asking whether (and when) FDA enforcement discretion would follow the favorable peptide votes, …

    • The PEPTIDE-L Wave Rolls On! PCAC Adds Two More Bulk Drug Substances for the 503A ListJuly 28th, 2026

      Well, don’t say we didn’t tell you what was coming. Day 2 of the Pharmacy Compounding Advisory Committee (PCAC or the Panel) Meeting (mostly) followed in the footsteps and at the pace of Day 1 (see our prior coverage of Day 1).  Over the course of …

    • PEPTIDE-L WAVE! PCAC Approves Four Bulk Drug Substances for the 503A ListJuly 24th, 2026

      See what we did there? Well, readers, some big things have taken place.  “Big things” have happened: we previewed these for you in our two-part FDA’s Pep(tide) Rally! What Compounders and Industry Need to Know blog posts (Part I, Part II). Yesterday, on Day 1 of FDA’s …

    • Old Drugs, New Tricks: FDA’s Drug Repurposing InitiativeMay 26th, 2026

      Don’t look now, but drug repurposing is having a moment. On May 11, 2026, FDA announced a new public docket soliciting stakeholder input on its drug repurposing initiative—specifically, which chronic disease areas should be prioritized and which approved drugs have the most potential to treat conditions …

    • One Day at a Time: FDA’s New AI-Informed Inspection Pilot and What It Means for IndustryMay 15th, 2026

      We have written on this blog about FDA’s modernization agenda from several angles lately—from the psychedelics Executive Order to the peptide compounding landscape (part 1, part 2)—but here is a storyline that cuts to the operational heart of regulated industry (or at least appears to): FDA …

    • “Sounds Great. Do You Want FDA Approval?” A Regulatory Analysis of PsychedelicsMay 6th, 2026

      We have covered a lot of ground on this blog over the years:  Hatch-Waxman disputes, REMS programs, and everything in between.  Rarely have we had occasion to write a sentence like this one:  A podcast host texted the President of the United States about a …

    • FDA’s Pep(tide) Rally! What Compounders and Industry Need to Know (Post 2 of 2)April 22nd, 2026

      As promised and teased in yesterday’s blog post, we discuss other practical implications of and compliance concerns surrounding the ongoing shift in peptide policy below. Supply Chain Complications There is also a supply chain issue that sits upstream of any FDA regulatory authorization of their use in …

    • FDA’s Pep(tide) Rally! What Compounders and Industry Need to Know (Post 1 of 2)April 21st, 2026

      The peptide compounding landscape shifted last week, and if you are interested or involved in the peptide industry, compounding pharmacies, telehealth, or the broader market for injectable wellness products, you’ll want to understand what happened—and perhaps more importantly, what hasn’t happened yet. FDA’s PCAC Meeting Announcement We …

    • Enough Will They-Won’t They! FDA Pushes for Permanent Rare Pediatric Disease PRVsApril 17th, 2026

      As any well-rounded consumer of television knows, one of the most ubiquitous tropes in sitcoms is the “will they-won’t they” dynamic.  Take your pick:  Ross and Rachel from Friends, Jim and Pam from The Office, or Mulder and Scully from The X-Files.  It’s riveting and …

    • FDA Looks East—Here’s What Industry Needs to KnowApril 16th, 2026

      If you’ve been tracking FDA’s international presence, you know FDA has been through a bit of a roller coaster over the past decade.  After consolidating from 13 foreign offices down to 8 between 2012 and 2014—and losing its Pretoria, South Africa office in 2015—the Agency …

    • Bipartisan Push for FDA “Pre-Review” of DTC Drug AdsApril 9th, 2026

      As many of our blog readers already know, direct-to-consumer (“DTC”) prescription drug promotion has been a regulatory flashpoint for years, and especially recently with FDA’s DTC crackdown (see our previous posts here, here, and here), but a new bipartisan push suggests the conversation may be …

    • Don’t Just Say “We’ll Fix It”: FDA Wants Real Investigations in Your 483 ResponseMarch 13th, 2026

      In response to what FDA calls “inadequate responses to FDA 483 observations due to a lack or omission of relevant data, excessive amounts of data, and/or failure to address the root cause of observations,” the Agency published a new Draft Guidance on Responding to FDA …

    • When FDA Can Make You Recall That MascaraJanuary 2nd, 2026

      On December 18, 2025, the U.S. Food and Drug Administration (FDA or the Agency) published clarification on its enforcement approach under the Modernization of Cosmetics Regulation Act of 2022 (MoCRA) with the release of a draft guidance titled “Questions and Answers Regarding Mandatory Cosmetics Recalls: …

    • California’s New Allergen-Disclosure Law: A Sign of Things to Come?October 31st, 2025

      On October 13, 2025, Governor Gavin Newsom signed into law SB 68, titled “Allergen Disclosure for Dining Experiences Act,” officially creating a statewide requirement for certain restaurants to disclose major food allergens on their menus. What SB 68 Requires SB 68: Requires disclosure of the nine major food …

    • Strengthening Postapproval Monitoring: FDA’s Draft Guidance on Cell & Gene Therapy ProductsOctober 19th, 2025

      FDA recently released a draft guidance, titled “Postapproval Methods to Capture Safety and Efficacy Data for Cell and Gene Therapy Products,” that provides valuable direction and insight into how sponsors can (and should) approach long-term data collection once a cell and gene therapy (CGT) product …