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

At a glance

  • FDA approval / None; AOD-9604 has never been approved as a drug [1][7]
  • FDA compounding lists / In the nominated-but-withdrawn table with stated safety concerns; in no category on the pharmacy or outsourcing-facility lists [2][3][4][5]
  • HHS peptide policy / Not among the six peptides in HHS's draft enforcement-discretion policy of 28 October 2026 [8][9]
  • Missouri statute / Chapter 338 section titles through 338.270 do not name AOD-9604 [6]
  • Approved dose / None [7]
  • Sport / WADA prohibits it at all times, in and out of competition [10]

What AOD-9604 is

AOD-9604 is a 16-amino-acid fragment of human growth hormone: hGH amino acids 177 to 191 with an extra tyrosine at the N-terminus, which is why it also circulates as hGH fragment 176-191 [11]. It is not full-length growth hormone. An Australian company, Metabolic Pharmaceuticals, developed it as an obesity drug candidate, with phase IIa trials under way by February 2002 [1]. It was never approved, and the obesity program was later dropped [7].

The federal position

FDA's page on bulk substances used in compounding says state-licensed pharmacies and physicians may compound only with bulk substances that comply with an applicable USP or NF monograph, are components of FDA-approved drug products, or appear on FDA's list of bulk substances that can be used in compounding [5]. AOD-9604 appears in none of the three categories on FDA's list for state-licensed pharmacies and physicians or on its list for outsourcing facilities, and the category 1 policy does not cover it [3][4][5].

Instead it sits in FDA's nominated-but-withdrawn table, which holds substances previously in category 2 whose nominators withdrew them. FDA's stated concerns: compounded drugs containing AOD-9604 may pose a significant immunogenicity risk for certain routes of administration, due to peptide impurities and characterization problems; FDA has identified no, or only limited, safety information; and FDA has identified 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].

Two other federal actions also leave it out. HHS's draft enforcement-discretion policy for compounding, filed 28 October 2026, names six peptides (BPC-157, epitalon, KPV, MOTS-c, Semax and TB-500), and AOD-9604 is not among them [8][9]. It was not on the agenda of FDA's July 2026 advisory committee meeting either [12]. Compounded drugs are not FDA-approved in any case: FDA does not review their safety, effectiveness or quality before they are marketed [13].

Missouri

Missouri regulates pharmacists and pharmacies under Chapter 338 of the Revised Statutes, whose section titles cover licensure, prescription labeling, recordkeeping and discipline [6]. Those section titles, through 338.270, do not name AOD-9604, peptides or growth hormone fragments [6]. The federal position above is the same in Missouri: the category 1 policy does not cover AOD-9604 [3][4][5].

What the evidence shows

Animal studies reported weight effects. In obese Zucker rats, oral AOD9604 at 500 micrograms/kg/day for 19 days cut weight gain to 15.8 g versus 35.6 g in controls [14]. Obese mice given injected AOD9604 for 14 days lost body weight and fat [15].

In people, a 24-week study (534 enrolled, 502 randomized) tested AOD9604 as an oral anti-obesity candidate and failed to show a significant benefit on its primary weight-loss endpoint. A 2026 review notes that this conclusion rests on sponsor-reported phase 2 results rather than peer-reviewed randomized trials [7]. There is no approved dose [7].

Athletes

WADA's Prohibited List names AOD-9604 and hGH 176-191 in section S2.2.3, growth hormone fragments, and prohibits them at all times, in and out of competition [10]. It is on the 2026 List and remains on the 2027 List [10][16].

Frequently asked questions

Is AOD-9604 legal in Missouri?
AOD-9604 is not FDA-approved, and FDA's category 1 compounding policy does not cover it. Missouri Chapter 338's section titles through 338.270 do not name it, and no verified legal route to obtain it in Missouri is established. [1][3][4][5][6]
Can a Missouri pharmacy compound AOD-9604?
AOD-9604 is in none of the categories on FDA's compounding lists, and the category 1 policy does not cover it [3][4][5]. It sits in the nominated-but-withdrawn table with stated safety concerns, and removal from category 2 was not a finding of safety [2].
Is AOD-9604 GRAS?
FDA's GRAS Notice Inventory contains no AOD-9604 notice [17]. GRAS is a food-ingredient concept and would not make an injectable lawful as a drug [17].
Is AOD-9604 banned in sport?
Yes. WADA names AOD-9604 and hGH 176-191 in section S2.2.3 and prohibits them at all times, in and out of competition; it is on the 2026 and 2027 Lists [10][16].

References

  1. Wilding J. AOD-9604 Metabolic. Curr Opin Investig Drugs. 2004;5(4):436-40. AOD-9604 Metabolic
  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. Missouri Revisor of Statutes - Revised Statutes of Missouri, RSMo Chapter 338. Missouri Revisor of Statutes - Revised Statutes of Missouri, RSMo Chapter 338
  7. 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
  8. Official web page. Official web page
  9. Official web page. Official web page
  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. U.S. Food and Drug Administration. U.S. Food and Drug Administration
  13. Human Drug Compounding | FDA. Human Drug Compounding | 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. World Anti-Doping Agency. World Anti-Doping Agency
  17. GRAS Notices. GRAS Notices
Evidence overview for Is AOD-9604 Legal in Missouri? How to Access It Legally