Legal Landscape of Performance Enhancers: Steroids, SARMs, and Peptides

Two federal laws, not one

US law has no single rule for "performance enhancers." Anabolic steroids fall under the Controlled Substances Act, the criminal drug law the DEA enforces against sellers and users alike. SARMs and peptides mostly don't. They fall under the federal drug-approval law (the FD&C Act), which FDA enforces mainly against the companies that make or sell drugs.

A vial of testosterone and a vial of BPC-157 can look identical. Possessing the first without a prescription is a federal crime; the second sits in a regulatory gap that FDA closes by going after sellers. This page covers the general US picture (not sport) as of October 2026. For sport, see how anti-doping rules treat these compounds; for other countries, see peptide laws by country; for how the drugs themselves differ, see our comparison of peptide and steroid mechanisms.

Anabolic steroids: Schedule III controlled substances

The Anabolic Steroid Control Act of 1990 placed anabolic steroids in Schedule III of the Controlled Substances Act. A 2004 update (Public Law 108-358) widened the definition to cover steroid precursors such as androstenedione and THG. The DEA's current controlled-substances list puts testosterone in Schedule III, along with derivatives such as nandrolone (Deca-Durabolin) and stanozolol (Winstrol). Ketamine sits in the same schedule.

Penalties come from the general federal drug statutes:

• Simple possession without a valid prescription: up to 1 year in prison and a minimum $1,000 fine for a first offense, with longer minimum terms after prior drug convictions (21 U.S.C. 844).
• Distribution, or possession with intent to distribute, a Schedule III substance: up to 10 years in prison, or up to 15 years if death or serious injury results (21 U.S.C. 841).

State laws add their own layer. The only lawful route is a prescription for an approved product, and there's no "research chemical" exception: a steroid sold under a research label is still a Schedule III drug.

SARMs: unapproved drugs, not controlled substances

SARMs (selective androgen receptor modulators), the class that includes ostarine and LGD-4033, aren't on the DEA's controlled-substances list as of October 2026.

The SARMs Control Act of 2019 (S. 2895) would have added SARMs to Schedule III, defining the class through nine named compounds. It was referred to the Senate Judiciary Committee and never became law. Our October 2026 research found no SARM scheduling bill pending in the current Congress, so any source describing SARMs as "pending scheduling" is out of date.

Legally, SARMs are unapproved drugs. FDA's consumer warning says that although they're often sold as supplements or "for research use only," they "cannot be legally marketed in the U.S. as a dietary supplement or drug at this time." FDA links SARMs to liver injury and a higher risk of heart attack or stroke, and says it has pursued warning letters and criminal cases against distributors.

So enforcement targets sellers, not buyers. Possessing SARMs isn't a federal controlled-substance offense, but no one checks what's in the bottle. In the Paradigm Peptides case, prosecutors said six "SARM" products the government tested all contained actual testosterone, a Schedule III steroid, according to CBS News.

Peptides: approval status decides

"Peptides" covers products with very different legal standing. The first question is whether a given peptide is an approved medicine; the second is whether a pharmacy may compound it.

Approved peptide medicines

Some peptides are FDA-approved prescription drugs. Examples include:

• Semaglutide (Ozempic, Wegovy)
• Tesamorelin (Egrifta), approved only to reduce excess abdominal fat in HIV-associated lipodystrophy
• Bremelanotide (Vyleesi), for low sexual desire in premenopausal women
• Elamipretide (Forzinity), given accelerated approval for Barth syndrome in September 2025

None of these is a controlled substance. The lawful route is a prescription filled by a licensed pharmacy. The same molecule sold online in a "research" vial is a different product in law: FDA's August 2026 warning letter to one research-peptide seller (discussed below) named research-labeled versions of all four, plus retatrutide, as "unapproved new drugs."

Sermorelin is a special case. It was approved as Geref until its maker discontinued it in 2008. In 2013 FDA determined the withdrawal wasn't for reasons of safety or effectiveness, so pharmacies can still compound sermorelin under section 503A as a component of a formerly approved drug (per a 2026 law-firm analysis). Ipamorelin has never been approved anywhere.

Compounded peptides

A 503A compounding pharmacy may use a bulk ingredient only if it qualifies through one of three routes: a USP or NF monograph; being a component of an FDA-approved drug; or a place on FDA's 503A bulks list. Most performance peptides qualify through none of them yet, though 2026 brought real movement:

• April 2026: FDA removed 12 peptides, including BPC-157 and TB-500, from Category 2, its list of bulk substances that may present "significant safety risks," after their nominations were withdrawn. As Orrick's analysis notes, removal doesn't put them on the bulks list; it leaves them in a gray area.
• July 23-24, 2026: FDA's Pharmacy Compounding Advisory Committee recommended adding six peptides to the 503A list (BPC-157, KPV, TB-500, MOTS-c, Semax and epitalon), over the objections of FDA staff. It voted 6-7-1 against DSIP.
• Since then: the votes are advisory. In August 2026 one compounding law firm reported "no proposed rule," and we found no FDA rulemaking as of October 2026. Until FDA acts, none of the six can lawfully be compounded under 503A.
• Earlier: the same committee voted in late 2024 against adding CJC-1295 and ipamorelin, among others.

Size matters too. A polypeptide of more than 40 amino acids counts as a biological product, which can't be compounded under 503A at all. For the buyer's side of the research label, see what "research use only" means for peptides.

"Research use only" peptides

Most gray-market peptides are sold labeled "for research use only" or "not for human consumption." Forum wisdom has long held that this label protects the seller. FDA disagrees. Its August 2026 letter to Peak Performance Peptides says that "despite statements on your product labeling marketing your products for 'research use only' and 'not for human consumption,'" the seller's website showed the products were intended as drugs for human use.

FDA cited two kinds of evidence. Selling bacteriostatic water alongside the vials, it said, provides the means to prepare an injectable drug. And it quoted product copy such as "Studied for effects on glycemic control" as evidence of intended drug use, even though the lines are phrased as research.

For individual buyers, the legal exposure is lower than for steroids. These peptides aren't scheduled, so possession isn't a controlled-substance offense, and the 2026 enforcement actions we found targeted sellers and shippers rather than people buying for themselves. The practical risk sits with the product: Paradigm Peptides' owner admitted forging laboratory certificates, so a vendor's certificate of analysis is a vendor claim until someone independent tests the vial.

How import and sale enforcement works

In 2026, federal enforcement came through these channels:

• Warning letters. FDA sent letters to research-peptide sellers during 2026, including a batch dated August 24. They treat the products as unapproved new drugs under section 505(a) of the FD&C Act and warn of possible "seizure and injunction."
• Criminal cases. In July 2026, a federal judge sentenced Paradigm Peptides owner Matthew Kawa to 70 months in prison after he pleaded guilty to selling unapproved drugs and illegally importing them. Prosecutors estimated 54,000 customers, according to CBS News.
• Border seizures. CBP officers in Cincinnati seized about 5,000 peptide shipments from China between December 2025 and late March 2026, hidden in mis-manifested cartons. The haul included retatrutide and semaglutide, plus MOTS-c and Semax. A shipment can be stopped at the border even when no one is charged.
• Import alerts. FDA Import Alert 66-80 lets field staff detain foreign GLP-1 bulk ingredients without examination unless the manufacturer is on its "Green List" (most recently revised October 2026).

The Legal Risk Matrix

What to watch next

• Whether FDA proposes adding the six recommended peptides to the 503A bulks list, or offers interim enforcement discretion while a rule is written.
• A second advisory committee meeting, planned before the end of February 2027, on the remaining withdrawn peptides, including GHK-Cu.
• Whether more criminal cases follow Paradigm's. The US attorney in that case said he hoped the sentence "sends a deterrent message."
• HHS policy. In February 2026, HHS Secretary Robert F. Kennedy Jr. said the administration would move to make about 14 restricted peptides accessible through lawful channels. As of October 2026, neither the April category change nor the July vote authorizes compounding.