Coded Product Names in the March 2026 FDA Warning Letters

Updated August 21, 2026

Coded product names — designations such as "GLP-1 SM" and "GLP-3 RT" in place of standard compound nomenclature — are documented in the record of FDA's March 31, 2026 warning letters to research-peptide sellers. Per the letters, the agency read the coding as circumvention, not cover: the drug class stayed legible while its name disappeared.

What coded naming is

A coded name lists a compound without naming it. The construction in the documented examples pairs the drug-class label with an abbreviation: "GLP-1 SM" for a GLP-1-class product, "GLP-3 RT" for another entry in the same family. The compound's standard name appears nowhere on the listing, yet an informed buyer can decode the abbreviation at a glance. The listing is opaque to a text search for the compound name and transparent to its intended audience — which is the property that put it in the letters.

The documented designations

These two are the designations the verified record captures. Whether other coded names appear across the seven letters, and which recipients used which, is not in the verified record of this index; the finding is attributed to the batch, whose seven entities and letter numbers are tabulated in the batch record.

Why sellers coded names

The letters record the practice, not the sellers' testimony about it, so motive can only be described by function. What a coded name does is remove the compound's searchable name from the storefront while the listing keeps selling the same thing. Compliance reviews, payment processors, and platform moderation that key on compound names pass over it; buyers do not. Any further account of intent belongs to the sellers, and none is in the verified record.

The agency's reading: circumvention, not cover

FDA declined to let the renaming work in either direction. Per the letters, the coding was read as circumvention — marketing a recognized drug class while avoiding the terms that would identify it — rather than as caution or as genuine anonymity. The coded name did not take the product out of the analysis; it went into the evidence pile, the same pile that held the therapeutic-effect descriptions and the cart contents. In the same letters the agency stated that, despite research-use disclaimers, "evidence obtained from your website establishes that your products are intended to be drugs for human use." A coded listing is website evidence like any other.

What the letters' handling of the codes establishes

Three things, on the documented record. First: renaming a compound does not remove it from an intended-use review — the agency identified the products behind the codes and named the practice in the letters. Second: the code itself can count against the seller, as an indicator that the seller knew what it was listing. Third: the finding sits inside the same aggregate method that runs through the 2024–2026 letters, documented on this index's page on research-use-only disclaimers — every element of a storefront is evidence, and naming is an element. The December 2024 letters had already catalogued sellers' informal product labels; the Xcel Research letter transcribes listings such as "RETA" and "SEMA" — shorthand, though not yet coding. The March 2026 batch documents the practice one step further along.

All recipients appear in the vendor index.

Sources

1. FDA Warning Letter, Lovega LLC dba Pink Pony Peptides, 721088-03312026. fda.gov
2. FDA Warning Letter, Gram Peptides, 721806-03312026. fda.gov
3. FDA Warning Letter, Xcel Research LLC, 694608-12102024. fda.gov
4. FDA Warning Letters database (remaining letters of the batch). fda.gov
5. Policy Canary analysis of the March 2026 batch. policycanary.io

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.