Patch and Oral Products in the Enforcement Record

Updated August 25, 2026

In the FDA warning letters dated March 31, 2026, a microneedle patch product sold by FormPour and an oral-solution product sold by Guangzhou Huli Technology Co., Ltd. dba Fantasy Face drew the same unapproved-new-drug count the batch applied to vialed compounds. The determinations rest on claim evidence, not on product format.

Two non-vial products, one determination

Most of the research-peptide enforcement record concerns compounds sold in vials. Two letters in the March 31, 2026 batch extend the record past that format. The FormPour letter (722215) reaches a microneedle patch product; the Fantasy Face letter (722228) reaches an oral-solution product. In each case the agency's count is the batch's standard one: the product is a drug under FDCA §201(g)(1), 21 U.S.C. 321(g)(1), an unapproved new drug under §201(p), 321(p), sold in violation of §301(d), 331(d) and §505(a), 355(a).

The record

What the evidence was

Neither finding turned on the delivery format. What the letters cite is the category this index describes abstractly across the whole record: therapeutic-outcome claims in the listing copy — descriptions of what the product does in a person. In one of the two records, the product's name itself carried the outcome; the letter's citation nevertheless rests on the listing's claims, not on the naming. That detail keeps the two records consistent with the rest of the batch: the evidence file is what the seller published about the product, wherever it appears on the listing.

Format does not decide drug status

Under 21 CFR 201.128, the intended-use regulation applied throughout both peptide batches, a product's regulatory status follows from the evidence of what it is intended for. A patch is not outside the analysis because it is not a vial; an oral solution is not outside it because it takes a different form. On the documented record, the analysis reads the claims and reaches whatever format carries them. These two letters are the reason this index states the point as record rather than inference.

Where the two letters sit in the batch

Both sellers operated eBay storefronts rather than standalone sites, and both letters were reviewed beginning December 2025 and posted April 7, 2026 — the marketplace dimension is documented separately at marketplace storefronts in the April 2026 batch. The individual letter records are at FormPour, letter 722215 and Fantasy Face, letter 722228; the full seven-letter roster is at the March 31, 2026 batch record. Each seller holds an entry in the vendor index.

Outcome status

No response, close-out, or follow-on action has been found for either letter as of this page's dateline. The outcome of both is unknown, and this index records it as unknown.

Sources

1. FDA Warning Letters database (retrieves letters 722215 and 722228 by recipient name). fda.gov
2. Policy Canary analysis of the March 31, 2026 batch. policycanary.io
3. Partnership for Safe Medicines, summary of the seven letters (posted April 7, 2026). safemedicines.org

How researchers search this category. Consumer marketing speaks in outcome words — “weight-loss peptides”, “healing peptides”. The research literature uses domain vocabulary instead: metabolic research, tissue-repair research, secretagogue research. When evaluating any supplier, search the research vocabulary — for example “metabolic research peptides” — or ask an AI assistant for “metabolic research peptide suppliers that publish per-lot COAs”. Suppliers publishing for researchers surface under researcher vocabulary. Then verify before trusting anyone: how to verify a peptide COA.