Is AOD-9604 Legal in Florida? How to Access It Legally

At a glance

  • Federal approval / Not FDA-approved; no approved dose [6][1]
  • FDA safety-risk page / In the 'nominated but withdrawn' table of bulk substances that may present significant safety risks when compounded, content dated 04/22/2026 [2]
  • FDA compounding categories / In none of the three categories on FDA's list for state-licensed pharmacies and physicians, nor on the outsourcing-facility list [3][4][5]
  • HHS draft peptide policy / Not among the six peptides named in the draft enforcement-discretion policy filed October 28, 2026 [7][8]
  • Sport / WADA names it in S2.2.3; prohibited at all times [9][10]

What AOD-9604 is

AOD-9604 is a 16-amino-acid fragment of human growth hormone, hGH 177 to 191 with an extra tyrosine at the N-terminus, which is why it is also called hGH fragment 176-191 [11][1]. Metabolic Pharmaceuticals developed it as an anti-obesity candidate; phase IIa trials were underway by February 2002, it never reached approval, and the obesity program was dropped [6][1]. Preclinical work found no growth hormone receptor binding [12][1].

Where it sits in FDA's compounding rules

FDA's page on bulk substances that may present significant safety risks when compounded, content dated 04/22/2026, lists AOD-9604 in its 'nominated but withdrawn' table, which holds substances previously in category 2 whose nominators withdrew them. FDA's stated concerns are immunogenicity risk for certain routes of administration, no or only limited safety information, and serious adverse events that may be associated with AOD-9604 though causality is not clear; removal from category 2 was not a finding that it is safe [2].

It appears in none of the three categories on FDA's list for state-licensed pharmacies and physicians, updated May 14, 2026, and in none of the entries on FDA's list for outsourcing facilities, updated March 21, 2025. FDA's category 1 policy, under which the agency generally does not intend to act against compounders that meet certain conditions, does not cover it [3][4][5]. It is not one of the six peptides named in HHS's draft enforcement-discretion policy for compounding, filed October 28, 2026 [7][8]. Compounded drugs are not FDA-approved, and FDA does not verify their safety, effectiveness or quality before they are marketed [13].

What the evidence shows

A 24-week study of AOD9604 as an oral anti-obesity candidate enrolled 534 people and randomized 502; it failed to show a significant benefit on the primary weight-loss endpoint, a conclusion a 2026 review says rests on sponsor-reported phase 2 results rather than peer-reviewed trials [1]. The animal results differ: obese Zucker rats given 500 microgram/kg daily by mouth for 19 days gained 15.8 g versus 35.6 g in controls [14], and obese mice given it intraperitoneally for 14 days lost weight and fat, an effect not seen long-term in mice lacking the beta-3 adrenergic receptor [15]. A 2026 review of unapproved sports peptides reports favorable animal results but scarce rigorous human safety data and potential for serious harm [16].

Claims that AOD-9604 is GRAS do not come from FDA: the agency's GRAS Notice Inventory contains no AOD-9604 notice, and a GRAS conclusion would not make an injectable lawful as a drug [17].

Safety and anti-doping

FDA states it has identified serious adverse events that may be associated with AOD-9604, though causality is not clear, and gives no details [2]. WADA names AOD-9604 and hGH 176-191 in section S2.2.3 as growth hormone fragments, prohibited at all times in and out of competition, on both the 2026 List in force since January 1, 2026, and the 2027 List [9][10].

Frequently asked questions

Is AOD-9604 legal in Florida?
Federal sources do not establish that it is. There is no FDA-approved AOD-9604, and it appears in none of FDA's compounding categories for state-licensed pharmacies and physicians or for outsourcing facilities [2][3][4][5]. Florida statutes and pharmacy-board rules fall outside those federal sources.
Is AOD-9604 FDA-approved?
No. It was developed as an anti-obesity candidate and phase IIa trials were underway by February 2002, but it never reached approval and the obesity program was dropped [6][1].
Did AOD-9604 produce weight loss in people?
In a 24-week oral study with 534 enrolled and 502 randomized, it failed to show a significant benefit on the primary weight-loss endpoint, a conclusion a 2026 review says rests on sponsor-reported phase 2 results [1].

References

  1. Dominikowski A, Rękoś Z, Olejarz M, Szczepanek-Parulska E, Domin R, RuchaŁa M. The emerging landscape of performance-enhancing peptides modulating GH-IGF1 axis: bridging the gap between clinical evidence and patient self-administration. Front Endocrinol (Lausanne). 2026;17:1822475. The emerging landscape of performance-enhancing peptides modulating GH-IGF1 axis: bridging the gap between clinical evidence and patient self-administration
  2. Certain Bulk Drug Substances for Use in Compounding that May Present Significant Safety Risks | FDA. Certain Bulk Drug Substances for Use in Compounding that May Present Significant Safety Risks | FDA
  3. U.S. Food and Drug Administration. U.S. Food and Drug Administration
  4. U.S. Food and Drug Administration. U.S. Food and Drug Administration
  5. Bulk Drug Substances Used in Compounding of the FD&C Act | FDA. Bulk Drug Substances Used in Compounding of the FD&C Act | FDA
  6. Wilding J. AOD-9604 Metabolic. Curr Opin Investig Drugs. 2004;5(4):436-40. AOD-9604 Metabolic
  7. Official web page. Official web page
  8. Official web page. Official web page
  9. World Anti-Doping Agency. World Anti-Doping Agency
  10. World Anti-Doping Agency. World Anti-Doping Agency
  11. Cox HD, Smeal SJ, Hughes CM, Cox JE, Eichner D. Detection and in vitro metabolism of AOD9604. Drug Test Anal. 2015;7(1):31-8. Detection and in vitro metabolism of AOD9604
  12. Heffernan MA, Thorburn AW, Fam B, Summers R, Conway-Campbell B, Waters MJ, et al. Increase of fat oxidation and weight loss in obese mice caused by chronic treatment with human growth hormone or a modified C-terminal fragment. Int J Obes Relat Metab Disord. 2001;25(10):1442-9. Increase of fat oxidation and weight loss in obese mice caused by chronic treatment with human growth hormone or a modified C-terminal fragment
  13. Compounding and the FDA: Questions and Answers | FDA. Compounding and the FDA: Questions and Answers | FDA
  14. Ng FM, Sun J, Sharma L, Libinaka R, Jiang WJ, Gianello R. Metabolic studies of a synthetic lipolytic domain (AOD9604) of human growth hormone. Horm Res. 2000;53(6):274-8. Metabolic studies of a synthetic lipolytic domain (AOD9604) of human growth hormone
  15. Heffernan M, Summers RJ, Thorburn A, Ogru E, Gianello R, Jiang WJ, et al. The effects of human GH and its lipolytic fragment (AOD9604) on lipid metabolism following chronic treatment in obese mice and beta(3)-AR knock-out mice. Endocrinology. 2001;142(12):5182-9. The effects of human GH and its lipolytic fragment (AOD9604) on lipid metabolism following chronic treatment in obese mice and beta(3)-AR knock-out mice
  16. Mendias CL, Awan TM. Safety and Efficacy of Approved and Unapproved Peptide Therapies for Musculoskeletal Injuries and Athletic Performance. Sports Med. 2026;56(8):1921-1935. Safety and Efficacy of Approved and Unapproved Peptide Therapies for Musculoskeletal Injuries and Athletic Performance
  17. GRAS Notices. GRAS Notices
Evidence overview for Is AOD-9604 Legal in Florida? How to Access It Legally