06/12/2025
⚠️ Important Warning to Fellow Medical Professionals in the UK
I am seeing a growing number of medical professionals in the UK advertising, promoting, or operating websites that make peptides available—names like Retatrutide, MOTS-C, Tesamorelin, BPC-157, TB-500, CJC-1295, and Ipamorelin—under the guise of "wellness," "anti-ageing," or "regenerative" therapy.
I feel compelled to issue a clear reminder: in the UK, the regulatory status of these substances must be treated with utmost seriousness.
What the law says—and why this behaviour risks your licence
Unlicensed Status
Under the Human Medicines Regulations 2012, none of these peptides currently hold a marketing authorisation (licence) from the Medicines and Healthcare products Regulatory Agency (MHRA) for human therapeutic use in the UK. Any substance marketed or sold for human therapeutic use must have MHRA approval.
The "Research Only" Label Does Not Provide Immunity
These unlicensed peptides may be legally sold strictly for "research purposes only"—meaning for use in laboratory or scientific contexts, not for injection or human therapy. However, the MHRA explicitly disregards "research only" or "not for human consumption" labels when it is clear they are being used to circumvent regulations. Marketing or supplying them as "safe to inject," "wellness treatments," "fat-loss," "anti-ageing," or similar therapeutic uses is likely to be interpreted by the MHRA (and possibly other regulatory or licensing bodies) as offering an unlicensed medicinal product—which is illegal under the Human Medicines Regulations 2012.
Context Matters More Than Labels
Even if a peptide is labelled "for research only," that label does not guarantee legal immunity if the substance is being supplied in a context where human use is implied—for example, offered by a clinic to clients, sold on a website promoting wellness, or accompanied by dosing guidance for therapeutic use.
The Special Need Exception Is Narrow
Regulation 167 of the Human Medicines Regulations 2012 permits supply of unlicensed medicines to fulfil the "special clinical needs" of an individual patient when no licensed alternative exists. However, this exemption requires:
An unsolicited order from a qualified prescriber
Documentation of the specific clinical need that cannot be met by a licensed product
The medicine is for an individual patient under the prescriber's direct responsibility
Informed patient consent and full clinical accountability
This exemption does not permit general marketing, bulk supply, or wellness-branded sales of peptides to clients.
Professional Accountability
The General Medical Council's guidance "Good Practice in Prescribing and Managing Medicines and Devices" (effective April 2021) makes clear that prescribers bear greater responsibility when using unlicensed medicines than when prescribing licensed products. You must:
Be satisfied no suitable licensed alternative exists
Have sufficient evidence of safety and efficacy
Take full responsibility for the patient's care and monitoring
Clearly inform patients of the unlicensed status
Document your clinical reasoning
Operating as a medical professional while marketing or supplying unlicensed peptides outside these narrow parameters raises serious concerns about professional misconduct, regulatory non-compliance—and could risk your licence to practise.
MHRA Enforcement Is Intensifying
In October 2024, the MHRA's Criminal Enforcement Unit conducted what they describe as "the world's largest single seizure of trafficked weight loss medicines"—dismantling an illicit manufacturing facility in Northampton. Officers seized over 2,000 unlicensed Retatrutide and tirzepatide pens, tens of thousands of empty pens, raw chemicals, and approximately £20,000 in cash. The street value exceeded £250,000. This was the first illicit weight loss medicine production facility discovered in the UK. MHRA's Head of Criminal Enforcement stated the agency "will stop at nothing to identify, disrupt, and dismantle the organised criminal networks who put profit before safety".
In short:
Possession of research-grade peptides under "research only" labelling may be legal in some circumstances—but
Marketing them to clients or patients for injection or human use is not legal unless they are a licensed medicine or meet the strict criteria for "special clinical need" under Regulation 167
Operating as a medical professional while doing that should raise serious concerns about professional misconduct, regulatory non-compliance—and could risk your licence to practise
My call to colleagues
If you see colleagues offering these peptides—especially under clinic or wellness-style branding—please:
✓ Double-check the MHRA licence status before you consider offering or administering them
✓ Refuse to promote or supply them for therapeutic use unless they are fully licensed or meet Regulation 167 criteria with proper clinical documentation
✓ Advise patients that these are experimental, unlicensed compounds with uncertain safety, efficacy, and legal status
✓ Prioritise evidence-based, approved treatments rather than "grey market" therapies
Our duty is to uphold patient safety and regulatory standards—not to chase hype.