FDA’s “Green List” Import Alert: Securing the GLP-1 Peptide Supply Chain

Home » Legal » FDA’s “Green List” Import Alert: Securing the GLP-1 Peptide Supply Chain
November 13, 2025

The FDA green list for GLP-1 active pharmaceutical ingredients (APIs) marks a major shift in how the U.S. Food and Drug Administration monitors peptide imports.

Announced in September 2025, this new alert helps block unverified GLP-1 ingredients at the border and ensures that only FDA-compliant API sources reach U.S. manufacturers and compounding pharmacies.
This move strengthens patient safety and raises the compliance bar for the entire peptide supply chain.

What is the FDA Green List for GLP-1 APIs?

The FDA green list is part of a new import alert created to protect U.S. patients from unsafe or unapproved GLP-1 APIs.
Under this system:

  • FDA-verified foreign manufacturers appear on the green list
  • Products from these facilities may enter more easily
  • Ingredients from unlisted facilities face Detention Without Physical Examination (DWPE)
  • Border agents can block non-compliant APIs immediately

This approach stops risky ingredients before they ever reach U.S. pharmacies or manufacturers.

Why Did the FDA Introduce the Green List Now?

The rise in demand for GLP-1 medications such as semaglutide (Ozempic®, Wegovy®) and tirzepatide (Mounjaro®, Zepbound®) created an international surge in raw peptide production.
Unfortunately, many new suppliers operate without FDA inspection, GMP controls, or validated quality systems.

The green list is a response to multiple risks:

  • Unverified GLP-1 APIs entering the country
  • Poor-quality or contaminated peptides
  • Online sellers shipping unsafe versions of GLP-1 products
  • Compounding pharmacies unknowingly using unapproved ingredients

FDA has also issued warning letters to companies selling unapproved GLP-1 drugs.

The green list strengthens this enforcement effort by targeting the supply chain at its earliest point: importation.

How the FDA Green List Works at the Border

1. Verified companies get fast clearance

Only API manufacturers that meet FDA requirements appear on the FDA green list.
These companies:

  • Follow Good Manufacturing Practices (GMP)
  • Provide validated quality documentation
  • May undergo FDA inspection

Their GLP-1 APIs can pass through customs more easily.

2. Unlisted manufacturers face automatic detention

If a shipment comes from a facility not on the FDA green list, it may be:

  • Detained automatically
  • Tested or reviewed for safety issues
  • Refused entry if found adulterated or misbranded

This system shifts the FDA from reactive to proactive enforcement.

3. Built on the FD&C Act

The FDA uses authority from the Federal Food, Drug, and Cosmetic Act (FD&C Act) to refuse entry to any drug or ingredient that appears:

  • Adulterated
  • Misbranded
  • Unapproved

The FDA green list allows the agency to apply these rules in a more targeted, transparent way.

Illustration depicting compliant and non-compliant APIs, with rejected APIs showing impurities and approved APIs showing purity.

Impact on Compounding Pharmacies

Compounding pharmacies custom-prepare medications for individual patients.
When FDA-approved drugs are in shortage, the agency may permit limited compounding of GLP-1 medications.
However, unapproved or low-quality APIs create significant patient risks.

With the new FDA green list, compounders must:

  • Source GLP-1 APIs only from FDA-verified facilities
  • Request documentation from peptide suppliers
  • Maintain strict GMP alignment
  • Avoid gray-market APIs

This protects both patients and pharmacies from dangerous or legally non-compliant ingredients.

How the FDA Green List Changes the GLP-1 Peptide Industry

1. Supply chain transparency becomes mandatory

Companies must now verify:

  • The origin of each GLP-1 API shipment
  • Manufacturing quality controls
  • GMP compliance
  • FDA inspection history

2. Foreign manufacturers must meet U.S. standards

To stay competitive, foreign peptide producers must:

  • Upgrade production quality
  • Prepare for FDA audits
  • Provide extensive documentation

This may raise global standards over time.

3. Compounding pharmacies face higher regulatory pressure

The FDA green list serves as a clear warning:

Using unverified APIs can lead to:

  • Warning letters
  • Product seizures
  • Injunctions
  • Loss of compounding privileges

4. Domestic manufacturers may gain an advantage

Companies producing GLP-1 APIs inside the U.S. may now:

  • Gain market share
  • Build trust with compounders
  • Offer more stable supply

5. Drug developers must integrate compliance early

Biotech startups working on peptide therapeutics must:

  • Design supply-chain strategies early
  • Source APIs only from verified suppliers
  • Maintain documentation from preclinical to clinical stages

Regulatory readiness now begins at the molecular level.

Illustration emphasizing supply chain diligence for compounding pharmacies, showing careful sourcing and quality control.

Why the FDA Green List Matters

The new FDA green list is more than an import tool it’s a strategic move to protect patients, improve quality, and rebuild trust in a rapidly expanding GLP-1 market.

It ensures:

  • Stronger enforcement at the border
  • Safer GLP-1 medications
  • Better-regulated supply chains
  • Higher standards for global manufacturers

The message from the FDA is clear:
Compliance is not optional. Quality starts at the source.

References

  1. U.S. Food and Drug Administration. (2024, May 2). FDA Takes Action to Stop Potentially Dangerous GLP-1 Active Pharmaceutical Ingredients from Entering U.S. Market. FDA Press Release.
  2. Sharma, R. (2023). Navigating Pharmaceutical Import Regulations: A Guide for Importers. Journal of Regulatory Affairs, 12(3), 187-201.
  3. U.S. Food and Drug Administration. (2024). Import Alert 99-47: Detention Without Physical Examination of Products that Appear to be Adulterated, Misbranded, or an Unapproved New Drug. FDA Enforcement Policy.
  4. Federal Food, Drug, and Cosmetic Act (21 U.S.C. § 301 et seq.).
  5. U.S. Food and Drug Administration. (2023, May 31). Compounding and the FDA: Questions and Answers. FDA Drug Information.
  6. Smith, J. (2024). Global Supply Chains and Pharmaceutical Quality: The Role of International Regulations. Pharmaceutical Policy Review, 8(1), 45-59.

Compliance is strategy. Stay informed. ⚖️
Regulatory and Medical Disclaimer: This article does not constitute medical advice. Information regarding peptides is for research and educational purposes only. Peptides are often sold as research chemicals and are not regulated as dietary supplements or medications for human use unless explicitly prescribed by a medical doctor. All research or potential human application of peptides requires strict oversight by a licensed medical professional.

Anya Sharma
November 13, 2025
Anya Sharma

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