Have you ever gone to a med spa and wound up in the gray market?

Exploring an intriguing consumer pipeline for peptide protocols in healthcare

This is Part 3 of a four-part series. Read Part One and Part Two.

Part 3: The Med Spa to Gray Market Pipeline

It’s not difficult to imagine the transition from medical consumer to gray market buyer. You may very well know such a patient.

Let’s trace this patient’s steps and their consequences. First, she paid for a telehealth appointment or med spa consult seeking a prescription for a weight-loss peptide she’s seen advertised online and has already researched extensively. Maybe it’s tirzepatide or retatrutide. Tirzepatide was only recently FDA approved, and is manufactured by Eli Lilly and prescribed under the brand name Zepbound to adults who have type 2 diabetes or who have been deemed clinically obese. Retatrutide, another GLP-1 agonist, is still in phase three clinical trials for FDA approval.

But the telehealth provider or med spa have ways of obtaining these compounds that don’t require clinical diagnoses or explicit breaches of the law. They use compounding pharmacies like Hallandale or Red Rock, which must be licensed by their respective states’ Boards of Pharmacy, remain compliant with state pharmacy laws, and are subject to random inspections to ensure compliance. Pharmaceuticals manufactured on-site have USP Monographs, or an index from the United States Pharmacopeia-National Foundry (USP-NF) that identifies the APIs (active pharmaceutical ingredients) in a given drug substance, as well as its purity, dosage forms, and excipients (i.e. inactive substances that serve as vehicles for active ones). If these pharmacies ship to customers out of state, they must be compliant with the United States Postal Service’s standards for shipping pharmaceutical drugs, as well as the pharmaceutical laws in the destination states. While the pharmacies’ operations are subject to state regulations – and thereby to some degree of guidance and oversight from the FDA – the pharmaceuticals themselves are not compounded in FDA-approved form. Some formulations may feature vitamin B12, sometimes described as an “additional supplement” added to help patients deal with nausea or low energy – it also allows the peptide to qualify as a distinct chemical formulation, which helps the compounding pharmacy avoid any legal action from deep-coffered pharmaceutical mega-giant Eli Lilly.

Back to our patient in question: let’s say she gets her peptide prescription, starts the protocol, and sees impressive results. She’s losing weight, regaining energy, and noticing a diminishment in food noise like she’s never before experienced in her life. She feels – as many have – as if this peptide has brought her back from a sort of waking nightmare of ill health into a life well lived. And it was so easy! To quote tech CEO and lifestyle entrepreneur Cate Hall, “much better lives are not only possible, but astonishingly close at hand.”

But then, our patient is hit with the prices. She’ll have to pay $300 per med spa visit, which certainly adds up if she wants to keep up with her weekly peptide protocol. If she got her peptides through Hers, she would be paying $199/month for a six-month prescription (which translates to $1,194 before taxes, paid upfront and in full). Being neither clinically obese nor type 2 diabetic, she doesn’t qualify for brand-name prescriptions of Wegovy, Zepbound or Mounjaro, all of which would be covered by her insurance. As costs stack up, our patient realizes her options are becoming increasingly limited.

So, she takes to the internet. First to Reddit, and then to messaging sites like Discord or Telegram. Where to get affordable peptides to continue her protocol? Can she maintain her newfound health without having access to a lavish lifestyle?

She’s sent links by other searchers. She finds sites on her own. Semaglutides and human growth hormone boosters for such low prices she’s a little stunned. Research use only, these sites advertise. Not for human use. She researches and researches and researches. Her options are many, and unregulated. But as federal and state regulations continue to fall away, she’s not all that worried. “The entire diet and supplement industries aren’t FDA-approved, and it’s not as if those compounds haven’t helped people,” she reminds herself. And she’s right. Depending on who you are, you may or may not raise your eyebrows at the “cures” of the Make America Healthy Again movement like raw milk and seed oil. But what about something as innocuous as an herbal tea for insomnia? Or a sprig of peppermint for indigestion? These things have helped people for centuries, and they’re neither FDA approved nor indicated for clinical use.

Our patient is justified in her skepticism – at least to a degree. So she finds a Research Use Only site that sells drugs on the cheap from a compounding pharmacy that happens to be located in her state. No legal or insurance loopholes to jump through. And now shipping is so much easier. Perfect!

Within days, her peptides arrive. But the bottles look dubious. A shiny wrapper boasting that the product she’s ordered is “99% pure,” “high potency” and “research-grade,” with a Certificate of Authentication (COA) from a “trusted third-party lab.” The peptides need to be reconstituted from powder to injectable liquid using something called bacteriostatic water. They can last 56 days once reconstituted, and one year in powdered form.

The patient may be feeling a little wary. If so, she wouldn’t be alone. Like Jordan in last week’s installment of this series, she’s navigating the uneasy medical consumerist territory circumscribed by urgency, scarcity, and desire. There’s a peptide that she knows could help her but has long been financially and bureaucratically out of her reach. And now here it is in its gray market form, with a wrapper that looks like it belongs on a Mars Bar from the ‘90s and a COA whose authenticity she can’t corroborate. Influencers on TikTok are telling her that reconstitution is “super easy,” but what she’s seeing in these videos looks like a lab-grade chemical process being conducted in residential kitchens without the slightest concern for sterilization or the challenges of long-term storage.

According to Verge reporter Victoria Song, there’s a lot of nuance missing from the gray market peptide world – starting with what consumers don’t know about how these drugs are being compounded. While not the same as FDA-approved brand name manufacturers like Novo Nordisk or Eli Lilly, compounding pharmacies are still state-regulated and, Song writes, often “godsends” for patients who fall outside tightly circumscribed clinical boundaries, like individuals who aren’t diabetic but are nevertheless struggling to lose weight due to hormonal conditions.

“Compounding pharmacies aren’t the same as the gray market,” Song cautions. “The gray market consists of any wholesaler, distributor, or manufacturer that sells outside of authorized distribution networks.” This is an admittedly large umbrella, including everyone from distributors who genuinely strive to ensure the safety and efficacy of their products via rigorous third-party testing to Chinese pharmaceutical manufacturers who may or may not have been previously implicated in DEA probes. The problem: there’s not yet a reliable way for the average consumer to tell the difference.

The reality of our current state of affairs is that the medical consumer to gray market pipeline is going to persist as long as demand for peptides exceeds limited – and, in view of many, bureaucratically and/or financially gatekept – supply. The idealist might wish for the overnight institution of a socialized healthcare system capable of offering compassionate, personalized healthcare to every American citizen regardless of resources. The realist will acknowledge the rosiness of this vision and then offer a more workable solution for the situation we’re in: individual vendors need to take responsibility for creating market conditions that reward safety protocol and scientific rigor. In other words: sloppiness and callousness need to become unprofitable.

Consumers can participate in this by choosing to order their peptides from vendors who are thoroughgoing and scientific when it comes to ascertaining the safety and efficacy of their peptides. But how to find these vendors and weed out the insincere ones? One need only screen a given vendor for an investment in scientific nuance – and while you’re at it, maybe input the vendor’s name in this FDA warning letter database.

Peptide Research, Done Cleanly — Peptide Partners. Independent HPLC/MS, batch COAs, and endotoxin screening to USP <85> validate identity and purity of peptides for research. Browse inventory and view certificates at Peptide Partners.

In September of last year, the FDA announced “sweeping reforms to rein in misleading direct-to-consumer pharmaceutical advertisements.” In the ensuing months, the regulatory agency sent thousands of letters warning pharmaceutical companies to remove misleading ads, and approximately 100 cease and desist letters.

“Pharmaceutical ads hooked this country on prescription drugs,” Health and Human Services Secretary RFK Jr. was quoted as saying in the agency’s September 9th press release. “We will shut down that pipeline of deception and require drug companies to disclose all safety facts in their advertising. Only radical transparency will break the cycle of over-medicalization that drives America’s chronic disease epidemic.”

Though RFK Jr. is a sometime-FDA antagonist and controversial figure on both sides of the aisle, the above statement is rooted in the truth. In the free market economy in which our healthcare system currently exists, the entire medical consumerist enterprise hinges upon the successful persuasion of the medical consumer. If I have a health problem (or, in some of the more nakedly manipulative cases, if I can be convinced I have a health problem), then pharmaceutical companies have a vested interest in selling me on their drugs as the best possible solution. This is the same for healthcare professionals who are not technically employees of the pharmaceutical company, but who are nevertheless on the payroll in the form of consulting fees, speaking fees, research grants, meals, and other gifts. If I walk into the practice of a certain Dr. X who’s currently benefiting from a million-dollar Eli Lilly research grant, it’s safe to say that whatever Dr. X prescribes me is more likely than not going to align with the financial interests of Eli Lilly.

This might help to explain why many of the FDA warnings issued last year were for the “unlawful sale of unapproved and misbranded drugs to United States consumers,” frequently over the internet.

“A drug is misbranded if its labeling is false or misleading in any particular,” reads one warning letter to an online vendor that alleges to work with licensed compounding pharmacies. “A compounded drug is misbranded if its advertising or promotion is false or misleading in any particular.”

The letter goes on to cite the issue: the vendor has labeled its compounded tirzepatide and semaglutide products as having the “same active ingredients” as name-brand drugs like Zepbound, Mounjaro, Wegovy, and Ozempic.

“Compounded drug products are not FDA-approved,” the letter goes on. “Your claims imply that your products are the same as an FDA-approved product when they are not. As a result, these claims are misleading, and your products are misbranded.”

We see this verbiage over and over again, in letter after letter: the vendors advertise their compounded products as having the “same active ingredients” as FDA-approved medications, or yielding “clinically proven results” when there is no clinic to speak of. Most of these letters were sent roughly 4-5 months ago, so I revisited the sites of the affected vendors and telehealth providers to see how they’d addressed the FDA’s concerns. In most every case, wordings had been changed: one site now only mentions the FDA in conjunction with its FDA-approved prescriptions for hair loss treatments, while another has scrubbed the phrase “clinically proven” from all of its digital copy. If name-brand medications like Wegovy or Mounjaro come up at all, it’s as points of comparison to show consumers how much money they’re saving by ordering custom-compounded semaglutide or tirzepatide from the vendor in question. Put simply: the words seem to have changed while the actions haven’t.

Such subterfuge doesn’t exactly inspire confidence, especially considering what we’ve already learned about not every telehealth company, compounding pharmacy, or RUO site being created equally. But then these small businesses aren’t alone in being deceptive. In the fall of 2025, the FDA sent Eli Lilly warning letters for false or misleading claims the manufacturer made about Zepbound and Mounjaro; the agency also sent Novo Nordisk a warning letter for false or misleading claims made about the medications Wegovy, Ozempic, and Victoza. It seems not even FDA approval, patent ownership or brand-name recognition are safeguards against slipping into salesmanship.

Let’s revisit the plight of the hypothetical patient I described at the very beginning of this essay. This strange convergence of circumstances places her in something of a bind: if she can’t trust the medical establishment, the rapidly diversifying cash-pay telehealth sector, the RUO site, nor the gray market group buy, then who can she trust?

The only answer is herself. There’s certainly plenty of snake oil in the wellness and longevity worlds, but there’s also plenty of expertise – not everyone’s the guy who blended a generic bottle of tea and claimed it could cure COVID “within minutes.” There are experts like biogerontologist Dr. Matt Kaeberlein who readily acknowledges the immense research potential of peptides alongside facts about their unscientific misuse and even abuse. There are clinicians like Dr. Tyna Moore, who has guided a number of patients through GLP-1 protocols while remaining vigilant about patient safety and maintaining that all successful peptide therapies must also include substantial lifestyle changes (sleep, diet, exercise, etc.). There are research vendors like Peptide Partners, a group I am happy to work with because of their well-documented commitments to lab safety and evidence-based science.

We may all fantasize about being that rare type of human being: someone who can’t be persuaded, whose loyalty can’t be purchased, or who would never dream of helel-turning from one cause to sell her loyalty to the highest bidder. But the fact of the matter is that our messy and highly subjective human psychology is prohibitive to this kind of stoic objectivity. We all desire, and we all want to be desired in some capacity – each of us will have a different notion of what these things mean. We are hopelessly social creatures, which is not necessarily a bad thing. It’s not a bad thing to be loyal, either, nor to want to believe in a cause, nor to care about the needs and feelings of others, nor to want the basic features of a good life. The trouble only arises when that good life is promised and then retracted, remaining forever just out of reach; when your discernment is questioned and then invalidated for another party’s obvious gain.

This is all to say we ought to seek answers and solutions, even as we remain realists about the conflicted medical landscape we find ourselves in. Discernment is the enemy of blind consumption.

Stay tuned next week for part 4 of this series, in which we’ll learn more about the risks of unscientific peptide use and lapses in oversight before revisiting the need for taking an empirical approach to research compounds.