Is AOD-9604 Legal in Washington State? How to Access It Through a Prescription

At a glance

  • FDA approval status / Not an approved drug; no approved product exists [5][6]
  • FDA compounding lists / In none of the three categories; category 1 policy does not cover it [2][3][4]
  • FDA safety view / Serious adverse events identified, causality unclear [1]
  • HHS draft peptide policy / Not one of the six named peptides [7][8]
  • Human weight-loss data / Sponsor-reported 24-week oral obesity study failed its weight-loss endpoint [6]
  • Sport / Named in WADA section S2.2.3, prohibited at all times [9]
  • Washington oversight / Department of Health licenses pharmacies [10]

Does a Washington prescription make AOD-9604 legal?

A prescription does not make AOD-9604 FDA-approved. FDA says state-licensed pharmacies and physicians may compound only from bulk substances that meet its stated requirements: a USP or NF monograph, a component of an FDA-approved drug, or a place on FDA's list of bulk substances that compounders may use [4]. AOD-9604 is in none of the three categories on FDA's lists for state-licensed pharmacies and physicians or for outsourcing facilities, and FDA's category 1 policy, under which the agency generally does not act against compounders who meet stated conditions, does not cover it [2][3][4]. Compounded drugs are not FDA-approved, and FDA does not review their safety, effectiveness or quality before marketing [7][8][11].

What FDA says about AOD-9604 specifically

FDA's page on bulk substances that may present significant safety risks lists AOD-9604 in its nominated-but-withdrawn table, which holds substances previously in category 2 that their nominators withdrew [1]. FDA's stated concerns are that compounded drugs containing AOD-9604 may pose significant immunogenicity risk for certain routes of administration because of peptide impurities and characterization problems, that it has identified no or only limited safety information, and that 'FDA has also identified serious adverse events that may be associated with AOD-9604, though causality is not clear' [1]. Removal from category 2 was not a finding that the substance is safe [1]. AOD-9604 is not among the six peptides in HHS's draft enforcement-discretion policy filed October 28, 2026 [7][8].

What the human evidence shows

A 2026 review reports that a 24-week study of AOD9604 as an oral anti-obesity drug candidate did not show a significant weight-loss benefit [6]. The review says this conclusion rests on sponsor-reported phase 2 results rather than a peer-reviewed randomized efficacy paper, and that robust human data for visceral-fat reduction or other metabolic benefit are lacking [6]. There is no approved dose, and no efficacy trials of injected gray-market products were found [6]. In obese Zucker rats, oral AOD-9604 at 500 microgram/kg daily for 19 days cut body-weight gain to 15.8 g versus 35.6 g in controls [12].

Washington State

Washington's Department of Health licenses pharmacists and pharmacies [10]. Its licensing page does not mention AOD-9604, so the federal position described above is the one that applies to a compounded product: not in any of FDA's three active categories, and listed by FDA in the nominated-but-withdrawn table with stated safety concerns [1][2][3][4].

Frequently asked questions

Is AOD-9604 legal in Washington State?
AOD-9604 is not FDA-approved and is in none of FDA's three active compounding categories [2][3][4]. A Washington prescription does not change its federal status.
Can a Washington pharmacy compound AOD-9604 on a prescription?
FDA says state-licensed pharmacies and physicians may compound only from bulk substances that meet its stated eligibility requirements [4]. FDA lists AOD-9604 in its nominated-but-withdrawn table and states safety concerns about compounded versions [1].
Is AOD-9604 FDA-approved for weight loss?
No. A review reports that the sponsor-reported 24-week oral obesity study did not show a significant weight-loss benefit, and the obesity program was dropped [5][6].
Is AOD-9604 on the WADA prohibited list?
Yes. WADA names AOD-9604 and hGH 176-191 in section S2.2.3 as growth hormone fragments, prohibited at all times. It is on the 2026 List [9] and stays on the 2027 List [13].
Is AOD-9604 GRAS?
FDA has no GRAS notice for AOD-9604. GRAS concerns food ingredients and does not authorize an injectable drug [14].

References

  1. 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
  2. U.S. Food and Drug Administration. U.S. Food and Drug Administration
  3. U.S. Food and Drug Administration. U.S. Food and Drug Administration
  4. Bulk Drug Substances Used in Compounding of the FD&C Act | FDA. Bulk Drug Substances Used in Compounding of the FD&C Act | FDA
  5. Wilding J. AOD-9604 Metabolic. Curr Opin Investig Drugs. 2004;5(4):436-40. AOD-9604 Metabolic
  6. 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
  7. Official web page. Official web page
  8. Official web page. Official web page
  9. World Anti-Doping Agency. World Anti-Doping Agency
  10. Pharmacy Professions Licensing | Washington State Department of Health. Pharmacy Professions Licensing | Washington State Department of Health
  11. U.S. Food and Drug Administration. U.S. Food and Drug Administration
  12. 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
  13. World Anti-Doping Agency. World Anti-Doping Agency
  14. GRAS Notices. GRAS Notices
Evidence overview for Is AOD-9604 Legal in Washington State? How to Access It Through a Prescription