Semax: where it stands with the FDA, and what it costs

Registered as a medicine in Russia, not approved in the US.

Allowed under HHS's Oct 2026 draft policyFrom $79/mo
  • Lowest per month

    Semax nasal spray

    PepScribe · from $79/mo

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  • Lowest at a clinic we link to

    Semax injection (5ml)

    Pepti · $229/mo (≈ $245 per 30 days with its fees)

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FDA

Where Semax stands today

No FDA-approved drug contains semax. FDA had it in 503A Category 2 from September 29, 2023 until April 22, 2026 (nominations withdrawn). On July 24, 2026 the advisory committee voted 8-5 (1 abstention, per law-firm reports) to recommend listing it, against FDA staff's proposal. HHS's October 30, 2026 interim policy covers semax free base for intranasal use only, single-ingredient, under ten conditions; it does not cover 503B facilities.

For pharmacies compounding one patient's prescription (section 503A)

Not on the 503A bulks list and in no FDA category (removed from Category 2 on April 22, 2026 after its nominations were withdrawn). Since Oct 30, 2026 it is one of six peptides in HHS's interim enforcement discretion policy for 503A compounding, limited to the form and routes below and ten conditions.

“Bulk drug substances nominated but withdrawn ... Semax (heptapeptide) Compounded drugs containing semax (heptapeptide) may pose risk for immunogenicity for certain routes of administration due to the potential for aggregation and peptide-related impurities.”
Source (fda.gov/drugs/human-drug-compounding/certain-bulk-drug-substances-use-compounding-may-present-significant-safety-risks), read 14 November 2026; content current as of 04/22/2026
““Semax (heptapeptide)” has been removed from category 2 because the nominations were withdrawn by the nominators.”
Source (web.archive.org/web/20260422215502/https://www.fda.gov/media/94155/download), read 14 November 2026; updated April 22, 2026 (archived copy of FDA's list)

HHS interim enforcement discretion policy (Office of the Secretary, not FDA)

“HHS does not intend to take enforcement action against a State-licensed pharmacy, Federal facility, or licensed physician compounding a drug product using a bulk drug substance in Appendix A.”
Source (hhs.gov/sites/default/files/hhs-503a-peptide-enforcement-discretion-policy-appendix-b.pdf), read 14 November 2026; PDF modified 2026-11-06 (document metadata); Federal Register notice of availability 2026-10-30

Form and routes HHS covers

“Based on the identified updated information, enforcement discretion for semax free base is appropriate for intranasal use that is compounded from API accompanied by a CoA meeting the conditions of this policy.”
Source (hhs.gov/sites/default/files/hhs-503a-peptide-enforcement-discretion-policy-appendix-b.pdf), read 14 November 2026; PDF modified 2026-11-06
“Semax was in Category 2 from September 29, 2023, until April 22, 2026, and neither the placement nor the removal changed its status under section 503A; CDER recommended against listing either form, and the PCAC voted in favor of both forms.”
Source (hhs.gov/sites/default/files/hhs-503a-peptide-enforcement-discretion-policy-appendix-b.pdf), read 14 November 2026; PDF modified 2026-11-06

One of the ten conditions: single-ingredient products only (no blends)

“The compounded drug product contains only a single Active Pharmaceutical Ingredient (API) listed in Appendix A.”
Source (hhs.gov/sites/default/files/hhs-503a-peptide-enforcement-discretion-policy-appendix-b.pdf), read 14 November 2026; PDF modified 2026-11-06

The Federal Register notice calls the policy a draft; written comments closed two weeks after publication

“HHS is announcing the availability of a draft”
Source (federalregister.gov/documents/2026/10/30/2026-22192/enforcement-discretion-policy-regarding-503a-compounding-using-certain-peptide-bulk-drug-substances), read 14 November 2026; federal Register, October 30, 2026 (91 FR 68526)

21 CFR 216.23(a), the 503A bulks list itself: six substances (Brilliant Blue G, cantharidin, diphenylcyclopropenone, N-acetyl-D-glucosamine, squaric acid dibutyl ester, thymol iodide); none of the compounds in this file

“The following bulk drug substances can be used in compounding under section 503A(b)(1)(A)(i)(III) of the Federal Food, Drug, and Cosmetic Act.”
Source (ecfr.gov/current/title-21/chapter-I/subchapter-C/part-216/subpart-B/section-216.23), read 14 November 2026; eCFR point-in-time text as of 2026-11-12

For outsourcing facilities (section 503B)

Not on the 503B bulks list and not in any 503B category (FDA's 503B nominations list, updated March 21, 2025, does not name it)

“Outsourcing facilities, which operate under section 503B of the Federal Food, Drug, and Cosmetic Act (FD&C Act), may not compound a drug product that includes a bulk drug substance unless: The bulk drug substance appears on a list identifying bulk drug substances for which there is a clinical need (the 503B bulks list), or”
Source (fda.gov/drugs/human-drug-compounding/bulk-drug-substances-used-compounding-under-section-503b-fdc-act), read 14 November 2026; content current as of 01/07/2025 (503B page); 503B categories list updated March 21, 2025; 503B bulks list content current as of 05/16/2024

The 503B bulks list holds five substances (diphenylcyclopropenone, glycolic acid, quinacrine HCl oral, squaric acid dibutyl ester, trichloroacetic acid); none of the compounds in this file

“FDA has evaluated the following bulk drug substances and determined that there is a clinical need for outsourcing facilities to compound drug products using these bulk drug substances under section 503B of the FD&C Act:”
Source (fda.gov/drugs/human-drug-compounding/503b-bulk-drug-substances-list), read 14 November 2026; content current as of 05/16/2024

The HHS policy names 503A compounders only; it does not cover 503B outsourcing facilities

“HHS does not intend to take enforcement action against a State-licensed pharmacy, Federal facility, or licensed physician”
Source (hhs.gov/sites/default/files/hhs-503a-peptide-enforcement-discretion-policy-appendix-b.pdf), read 14 November 2026

The FDA's compounding advisory committee

24 July 2026: Should semax (free base) and semax acetate be placed on the 503A bulks list? (use FDA reviewed: cerebral ischemia, migraine and trigeminal neuralgia). Vote: 8 yes, 5 no, 1 abstention (both forms), per law-firm reports. Committee recommended inclusion, against FDA staff's proposal; no FDA rule yet; HHS cited the vote in its Oct 30, 2026 interim policy

“VOTE: Should Semax (free base) be placed on the list? ... VOTE: Should Semax acetate be placed on the list?”
Source (fda.gov/media/193711/download), read 14 November 2026

Our reading

A 503A pharmacy can compound semax (free base) nasal spray for a patient-specific prescription under HHS's enforcement discretion if every condition is met; injectable semax, semax acetate, 'N-acetyl semax amidate' and blends fall outside it.

Every source above was checked again on 14 November 2026.

Prices

What 39 clinics charge

  1. PepScribeSemax nasal sprayfrom $79/mo
  2. EnhancedSemax nasal sprayfrom $109/mo
  3. Bon HealthSemax nasal spray (10ml)$114/mo
  4. System LabsSemax nasal spray (10ml)$119/mo
  5. YuviaSemax nasal spray (15ml)$119/mo
Every Semax price, with its terms
The compound

What Semax is

What it is
Synthetic peptide (ACTH 4-10 analog)
How it works
A synthetic analog of a fragment of adrenocorticotropic hormone, developed in Russia.
How it is given
Nasal spray
Compare

Semax side by side

Questions

About Semax

Is Semax FDA-approved?

No. No FDA-approved drug contains Semax. What clinics sell is compounded by a pharmacy for a prescription, and the FDA does not review compounded products before they are sold.

Is Semax legal in the US?

Whether a pharmacy may compound it for your prescription is what decides it. No FDA-approved drug contains semax. FDA had it in 503A Category 2 from September 29, 2023 until April 22, 2026 (nominations withdrawn). On July 24, 2026 the advisory committee voted 8-5 (1 abstention, per law-firm reports) to recommend listing it, against FDA staff's proposal. HHS's October 30, 2026 interim policy covers semax free base for intranasal use only, single-ingredient, under ten conditions; it does not cover 503B facilities.

How much does Semax cost?

39 clinics publish a price. The lowest that compares per month is from $79/mo at PepScribe, and the middle of 28 clinics' lowest monthly prices is about $177. What a month buys differs by clinic, so each price lists what it includes. every Semax price

What forms does Semax come in?

Clinics sell it as nasal spray (41 prices), injection (2 prices), other (1 price).

We publish prices and public records; we are not a clinic, a pharmacy or a medical service, and nothing here is advice to take, stop or change any treatment. Compounded peptides and NAD+ are not FDA-approved, and the FDA's position on several of them is changing. A clinician who knows your health is the person to decide whether any of them is right for you.