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On The Jab

The compounding question, after the shortages

Compounded semaglutide filled a real gap during a genuine shortage. The regulatory basis for that gap has narrowed — and the market has not gone anywhere. Here is how to reason about it.

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Dr. Nick Robertson

Founder & Editor

Published
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3 min read
Medically reviewed
Clinically reviewed

For roughly two years, the simplest explanation for the compounded GLP-1 market was regulatory: when a drug is on the FDA shortage list, compounding pharmacies gain latitude to prepare copies that would otherwise be off-limits. Demand vastly exceeded supply, the drugs went on the list, and an industry appeared almost overnight.

That latitude narrows when a shortage is declared resolved. The market, predictably, has proven more durable than the legal basis that created it.

Why this is not a simple story

It would be convenient if the compounded market were straightforwardly bad and the branded market straightforwardly good. It is not that tidy.

The compounded market exists because the branded products are unaffordable to a very large number of Americans who clinically qualify for them, and because Medicare’s structural exclusion has left millions without a covered route. Moralizing at patients about that is not medicine; it is an attempt to make a policy failure into a personal one.

At the same time, the risks are real and they are not evenly distributed.

The dosing hazard specifically

The most consistent safety signal in this market has not been contamination. It has been arithmetic.

Branded pens deliver a fixed dose. Many compounded products arrive as a vial of solution at a concentration the patient must convert into units on an insulin syringe. The failure modes are obvious in hindsight — tenfold errors, confusion between milligrams and units, and instructions that vary between suppliers.

Whatever you are taking, and wherever it came from, keep a dated record of it — product, concentration, dose drawn, lot number, and every symptom with the day it started. In a market where recalls happen and sourcing changes without announcement, an accurate personal log is a genuinely useful safety instrument rather than an administrative chore. Zenday is built for it. A notebook by the fridge is not much worse, provided it actually gets written in.

Questions worth asking any source

  • Is this a licensed pharmacy in your state, and can you verify the license independently?
  • Is the active ingredient base semaglutide or tirzepatide, not a salt form?
  • Where is the API sourced and is there third-party testing you can actually see?
  • Is there a named prescriber, and is there a real clinical evaluation?
  • Is the dose delivered fixed, or must you calculate it?

A source that cannot answer these in writing has told you something.

What we are watching

The enforcement posture, the litigation, the manufacturers’ own cash-pay pricing — which has moved in response to this market — and whether the policy conversation ever addresses the underlying reason it exists.

The most useful thing anyone can say about compounding is not “don’t.” It is: understand exactly what you are buying, from whom, at what concentration, and with what recourse if something goes wrong.

Common questions

Compounding is a regulated part of US pharmacy practice, but copying a commercially available FDA-approved drug is generally restricted, with a specific allowance while that drug is on the FDA shortage list. When shortages are declared resolved, that allowance narrows.
Is compounded semaglutide safe?
Compounded products do not undergo FDA premarket review for safety, efficacy or manufacturing quality. The most consistently documented harm has been dosing error, particularly where the patient must draw a dose from a vial rather than use a fixed-dose pen.
What is the difference between semaglutide and semaglutide sodium?
Salt forms such as semaglutide sodium or acetate are different active ingredients from the base semaglutide used in approved products. The FDA has warned specifically against their use in compounding.
How do you check a compounding pharmacy is legitimate?
Verify the state pharmacy licence independently, confirm a named prescriber licensed in your state, ask whether it is a 503A pharmacy or 503B outsourcing facility, request batch testing, and establish whether the dose is fixed or something you must calculate.

Sources

  1. 01

    US Food and Drug Administration. Medicines containing semaglutide marketed for type 2 diabetes or weight loss.

  2. 02

    US Food and Drug Administration. Human drug compounding — questions and answers.

  3. 03

    US Food and Drug Administration. Drug shortage database.

Editorial standards

Written by Dr. Nick Robertson, MD. Clinical content last checked August 27, 2026. On The Jab takes no money from pharmaceutical companies, telehealth platforms or compounders, and uses no affiliate links. Read our policy.

This article is journalism and general education, not medical advice. Talk to your own clinician before changing any treatment.

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