TB-500 Compounding Pharmacy: How to Read a Certificate of Analysis

At a glance

  • Federal requirement / a bulk substance used in compounding must come with a valid COA and be made by an FDA-registered establishment [2]
  • Official standard for TB-500 / none; no USP or National Formulary monograph [1]
  • Molecule to look for / N-acetylated fragment, residues 17 to 23, about 889 g/mol [1]
  • Impurity, aggregate and endotoxin data for TB-500 / FDA found none [1]
  • Approval status / not FDA-approved; FDA does not review compounded drugs for safety, effectiveness or quality [3]

Why TB-500 certificates are harder to read than most

FDA's July 2026 review found no USP or National Formulary monograph for TB-500 and no FDA-approved drug containing it [1].

Identity is the line worth reading hardest. FDA found several salts and derivatives, including different active moieties, sold under the name TB-500 [1]. A useful document identifies the N-acetylated Ac-LKKTETQ fragment at approximately 889 g/mol and states the form, free base or acetate [1].

Esposito and colleagues identified that N-acetylated 17 to 23 fragment in TB-500 by HPLC with high-resolution mass spectrometry. It was an analytical chemistry study of a product suspected of doping use, not a clinical study [4].

What no certificate can answer

Compounded drugs are not FDA-approved, and FDA does not review them for safety, effectiveness or quality before they reach patients [3]. FDA found TB-500 not well characterized, with inconsistent naming and no impurity, aggregate or endotoxin data, and no immunogenicity or aggregation studies. Immunogenicity from aggregation and peptide-related impurities is FDA's stated concern for the injectable [1]. An adverse-event database search through March 26, 2025 retrieved no TB-500 reports, and FDA found no published case reports [1].

TB-500 appears in none of the categories on FDA's bulk substance lists for state-licensed pharmacies and physicians or for outsourcing facilities [5][6][2]. FDA staff recommended against adding it to the bulks list [1]. The July 23, 2026 advisory committee voted in favor of adding it, which was advice only, and TB-500 is not on the list [7][8]. HHS's October 2026 draft enforcement-discretion policy names TB-500 acetate for subcutaneous or intramuscular injection. It says HHS does not intend to take enforcement action where its conditions are met, one of them an FDA-registered manufacturer with a certificate of analysis. The notice states it is not binding, and it is not an approval [8][9].

Three things to check on the document

  • The fragment and the form: N-acetylated Ac-LKKTETQ, about 889 g/mol, with free base or acetate named [1].
  • The bulk substance maker: an FDA-registered establishment, a condition for using a bulk substance in compounding [2].
  • Impurity and endotoxin results, the categories FDA found missing for TB-500 [1].

Frequently asked questions

What molecular weight should a TB-500 certificate show?
About 889 g/mol for the N-acetylated fragment Ac-Leu-Lys-Lys-Thr-Glu-Thr-Gln-OH [1]. Full-length thymosin beta-4 is a different, 43-amino-acid protein [1].
Can a certificate tell me which salt of TB-500 is in the vial?
Only if the document names it. FDA found several salts and derivatives sold under the same name, and the HHS draft policy covers TB-500 acetate specifically [1][8].
Does a certificate of analysis make compounded TB-500 legal?
No. TB-500 appears in none of the categories on FDA's bulk substance lists for state-licensed pharmacies or for outsourcing facilities [5][6][2]. The October 2026 HHS draft says it does not intend to take enforcement action when its conditions are met. It is not binding and does not approve TB-500 [8].

References

  1. U.S. Food and Drug Administration. U.S. Food and Drug Administration
  2. Bulk Drug Substances Used in Compounding | FDA. Bulk Drug Substances Used in Compounding | FDA
  3. Human Drug Compounding Laws | FDA. Human Drug Compounding Laws | FDA
  4. Esposito S, Deventer K, Goeman J, Van der Eycken J, Van Eenoo P. Synthesis and characterization of the N-terminal acetylated 17-23 fragment of thymosin beta 4 identified in TB-500, a product suspected to possess doping potential. Drug Test Anal. 2012;4(9):733-8. Synthesis and characterization of the N-terminal acetylated 17-23 fragment of thymosin beta 4 identified in TB-500, a product suspected to possess doping potential
  5. U.S. Food and Drug Administration. U.S. Food and Drug Administration
  6. U.S. Food and Drug Administration. U.S. Food and Drug Administration
  7. U.S. Food and Drug Administration. U.S. Food and Drug Administration
  8. Official web page. Official web page
  9. Official web page. Official web page
Evidence overview for TB-500 Compounding Pharmacy: How to Read a Certificate of Analysis