Are peptides legal in Ireland and the EU?

How EU law defines a medicinal product

Directive 2001/83/EC gives two definitions in Article 1(2). A product is a medicinal product if it is presented as having properties for treating or preventing disease in human beings. It is also one if it may be used in or administered to human beings to restore, correct or modify physiological functions by exerting a pharmacological, immunological or metabolic action. These are usually called the presentation limb and the function limb.

Article 2(2) adds a rule for doubt: where a product may fall within this definition and within the definition of a product covered by other EU legislation, the medicines rules apply. Under Article 6, no medicinal product may be placed on the market of a Member State without a marketing authorisation. Article 3 excludes medicinal products intended for research and development trials from the directive. The article says nothing about labels.

The Court of Justice has held that national authorities, acting under the supervision of the courts, must decide case by case whether a product is a medicinal product by function, taking account of all its characteristics (Hecht-Pharma, C-140/07, 2009). In 2014 it ruled that the function limb does not cover substances that merely modify physiological functions without any beneficial effect on health and are consumed solely to induce intoxication (C-358/13 and C-181/14). Classification is therefore a national decision on a specific product, and outcomes can differ between countries.

Retatrutide and unauthorised GLP-1 products

Retatrutide is an investigational medicine. ClinicalTrials.gov lists phase 3 trials sponsored by Eli Lilly, several of them still running, and EMA's downloadable table of centrally assessed medicines had no entry for retatrutide on 11 November 2026. The Dutch Health and Youth Care Inspectorate (IGJ) wrote on 24 August 2026 that retatrutide is an experimental medicine that has not been approved and therefore has no marketing authorisation.

On 3 September 2025, EMA and the Heads of Medicines Agencies warned of a sharp rise in illegal medicines marketed as GLP-1 receptor agonists such as semaglutide, liraglutide and tirzepatide, often sold through fraudulent websites and promoted on social media. The warning says these products are not authorised and may not contain the claimed active substance. It does not name retatrutide. Swissmedic did in August 2025: it cited a “retatrutide injection kit” as a substance still in clinical development that is already sold on the black market.

The IGJ notice shows how one national authority acted. It ordered a Dutch webshop to stop supplying and trading medicines containing retatrutide, tirzepatide and semaglutide, because the seller lacked the required registrations and licences. IGJ also said it had received several reports of harm to consumers after retatrutide use. When the order was not followed, it imposed a penalty of 10,000 euros per day, up to 200,000 euros.

• Retatrutide: published trial results in the peptide guide

Ireland: HPRA and the mail-order rule

Regulation 19 of the Medicinal Products (Prescription and Control of Supply) Regulations 2003 (S.I. No. 540 of 2003) states that a person shall not supply by mail order any medicinal product. As made, Regulation 20 exempted supply to a university or other institution concerned with higher education or scientific research, for the purposes of that education or research. The regulations have been amended since 2003. The HPRA's current guidance says that non-prescription medicines may be sold online by suppliers on the Pharmaceutical Society of Ireland's Internet Supply List, and that it is against the law to supply prescription medicines online.

The HPRA states that illegal prescription medicines found entering the country are detained by customs and may be destroyed, and that it writes to the buyer when a package bought online has been detained. In its 2025 enforcement figures, published on 24 March 2026, the HPRA reported 763,027 dosage units of falsified and illegal medicines detained, including just under 14,000 packages each linked to a purchase by a member of the public. Detained GLP-1 type medicines rose from 1,582 in 2024 to 48,752 in 2025.

We found no HPRA publication that addresses BPC-157, GHK-Cu or “research use only” peptides by name. Whether a specific research product is a medicinal product in Ireland is a question for the Irish authorities, and the HPRA is the regulator to ask.

Skincare and sport: two separate rulebooks

Regulation (EC) No 1223/2009 defines a cosmetic product as a substance or mixture intended to be placed in contact with the external parts of the human body, for purposes such as cleaning or protecting them, keeping them in good condition or changing their appearance. The EU glossary of common ingredient names includes Copper Tripeptide-1, the name under which GHK-Cu appears on ingredient lists. A cosmetic needs a designated responsible person in the EU and a safety assessment before it is placed on the market (Articles 4 and 10).

Article 2(2) of the same regulation says that a substance or mixture intended to be ingested, inhaled, injected or implanted into the human body is not a cosmetic product. That a serum with Copper Tripeptide-1 can be marketed as a cosmetic therefore says nothing about lyophilised GHK-Cu sold in a vial as research material.

WADA's Prohibited List is a set of sport rules. The 2026 list, in force since 1 January 2026, prohibits S0 and S2 substances at all times. S0 covers any pharmacological substance not addressed elsewhere in the list and with no current approval by a governmental health authority for human therapeutic use, and it names BPC-157. S2 names, among others, CJC-1295, sermorelin, tesamorelin, ipamorelin, ibutamoren (MK-677) and TB-500. The list does not name retatrutide, GHK-Cu or melanotan II. A WADA listing is not by itself a criminal statute, although national laws may refer to the list, as Germany's Anti-Doping Act does through the UNESCO anti-doping convention.

• GHK-Cu in the peptide guide
• BPC-157 in the peptide guide

Country by country

National rules differ most on three points: whether a doping statute lists named peptides, how private imports of medicines are treated, and what the regulator has said about research labels. Norway's medicines agency announced that BPC-157, CJC-1295, ipamorelin, TB-500, tesamorelin, sermorelin and ibutamoren would be added to the Norwegian doping list on 15 September 2026. Germany's Anti-Doping Act lists CJC-1295, ipamorelin, sermorelin, tesamorelin, ibutamoren and TB-500 in its annex, and ties the possession offence to a quantity threshold and a doping purpose. Our country articles cover Norway, Sweden, Denmark, Finland, Iceland, the Faroe Islands and Germany.

Regulators in Austria and Switzerland have addressed research labels directly. Austria's BASG wrote on 27 May 2026 that calling a product a “research chemical” is irrelevant under medicines law where the overall context of a webshop shows that the products are intended for human use, and that distributors, importers and purchasers may face legal consequences. Swissmedic wrote on 30 June 2026 that labels such as “research chemical” or “not for human use” change nothing if products are destined for human use. In its control of 22 June 2026 with Swiss customs and Swiss Sport Integrity, 23 of 46 checked packages were retained.

• Norway: the September 2026 rules
• Sweden: peptide rules
• Denmark: peptide rules
• Finland: peptide rules
• Iceland: peptide rules
• Faroe Islands: peptide rules
• Germany, with notes on Austria and Switzerland

What is not settled

We found no EU-wide decision that classifies BPC-157, injectable GHK-Cu or retatrutide sold as research material. Classification is national, and for Ireland we found no published decision on these substances as research material.

How far the function limb reaches is also open. The Court of Justice's 2014 ruling concerned herb mixtures containing synthetic cannabinoids. We found no judgment that applies its reasoning to unauthorised peptides.

The Austrian and Swiss statements on research labels concern products that are offered or advertised for use in humans. They do not describe supply to a laboratory or university, which some laws treat separately: Ireland's 2003 regulations and Germany's Medicines Act both contain provisions for research institutions. Lists also change. Check the version of a statute, a regulator page or the WADA list that applies on the day of the assessment.

• Are peptides safe?
• What the term peptide describes
• Peptide guide

Frequently asked questions