Exosomes
PHS Act Section 351 biologic. No FDA-approved product for any indication. Fails the 361 minimal-manipulation exception. States with permissive stem cell laws generally extend by analogy; TN is the first state to reference exosomes by name; UT has supplier-side duty. CA/MN restrictive.
Enforcement: 7+ warning letters & DOJ actions 2024-26.
Peptides (BPC-157, TB-500…)
No FDA-approved products. Compounding governed by 503A Bulks List — in July 2026 the PCAC voted to add BPC-157, TB-500, KPV, DSIP, Semax, and Epitalon to the bulks list. States without specific statutes default to federal rules.
Widespread gray-market availability; state boards increasingly active.
GLP-1s (Semaglutide, Tirzepatide)
FDA-approved products exist (Wegovy, Ozempic, Mounjaro). 503A/503B compounding allowed during shortages; FDA cracked down 2024-25 with 30+ warning letters to telehealth companies. State boards (AL, NJ, OH, KS, KY, CA) issued position statements.
More regulated than peptides, but legal compounding pathways exist.
Stem Cells
Most state laws target stem cells specifically — 7 permissive (FL, GA, TN, TX, WY, NV, MS), 4 regulated (UT, WA, VT, NC), 2 restrictive (CA, MN). Federal authority governs regardless; state laws govern provider conduct.
This tracker's tier data maps directly to this class.
Biologics (351 Products)
Federal 351 products — BLA or IND required for therapeutic use. State laws referencing "regenerative medicine" or "cellular therapy" cover these. Cosmetic-only positioning keeps products outside drug jurisdiction while claims hold.
Same federal floor as exosomes; state posture varies by regen law.