When is a peptide a medicinal product?
The key provision is § 2 of the German Medicines Act (Arzneimittelgesetz, AMG). It knows two ways in which a substance becomes a medicinal product – and one is enough.
- Medicinal product by presentation: A product is presented as if it cures, relieves or prevents disease. Whether it actually works does not matter. What counts is how it is advertised and packaged.
- Medicinal product by function: A substance changes body functions through its composition – pharmacologically, immunologically or via metabolism. That is exactly why peptides such as tirzepatide, retatrutide or BPC-157 are bought in the first place.
For GLP-1 substances and most “biohacking peptides” there is therefore a lot to suggest that they count as medicinal products. How a specific product is classified is ultimately decided by the authorities and courts on a case-by-case basis.
In Germany, a medicinal product may in principle only be placed on the market with an approval (§ 21 AMG). Approved products include, for example, Mounjaro or Wegovy as finished medicines – but not powder vials from the internet, even if they carry the same drug name. Retatrutide is not yet approved anywhere; more on this in Retatrutide: studies and approval.
Selling, offering, passing on: this is where it becomes a criminal offence
The AMG mainly penalises placing on the market (Inverkehrbringen). According to § 4(17) AMG, this includes not only selling but already keeping stock for sale, offering, and “supplying to others”.
| Provision | What it covers | Penalty range |
|---|---|---|
| § 96 No. 5 AMG | Placing finished medicinal products on the market without the required approval | Imprisonment of up to 1 year or a fine |
| § 95 AMG | Among other things, placing “unsafe” medicinal products on the market (§ 5 AMG), unauthorised trading in prescription-only medicines | Imprisonment of up to 3 years or a fine, considerably more in particularly serious cases |
Important in everyday life: passing something on to friends, your partner or people from a chat group also counts as “supplying to others” – whether for money, at cost or as a gift. Group orders, where one person orders and distributes to others, are therefore legally particularly risky.
Merely using a medicinal product yourself is generally not itself a criminal offence under the AMG. But that does not make it legally “safe”, because acquisition and import can cause problems of their own (see below).
“Not for human use” – why the label does not protect you
Research peptides are almost always sold with notes such as “for research purposes only” or “not for human use”. Many buyers conclude that this makes the purchase legal. Criminal defence lawyers explicitly point out that this wording offers no automatic legal protection. For classification as a medicinal product by function, what counts is the effect of the substance – and if everyone knows what a product is bought for, a sticker changes little.
Health-wise, the label is even a warning sign: it means that nobody vouches for purity, sterility and content. There is no official quality control as there is for pharmacy products. What a certificate of analysis (COA) does – and does not – tell you is explained in Peptide quality and COA.
Ordering from abroad: customs and § 73 AMG
§ 73 AMG contains a general import ban (Verbringungsverbot): medicinal products that require approval in Germany may only be brought in if they are approved or registered here. According to German customs (Zoll), there are only narrow exceptions.
- Travel: If you enter the country yourself, you may bring medicines in a quantity corresponding to “normal personal needs” – according to customs and the Federal Ministry of Health (BMG), usually for about three months at most. This is an exception for travellers, not a licence for parcel orders.
- Shipping from non-EU countries: According to the consumer advice centre (Verbraucherzentrale), consumers generally cannot order medicines from mail-order pharmacies outside the EU and EEA.
- Shipping from the EU: Only purchases via licensed mail-order pharmacies are allowed. An online shop for “laboratory chemicals” is not a pharmacy.
Customs can hold shipments, have samples tested and refer cases to the public prosecutor. Then it is no longer just about the parcel, but about a criminal investigation.
Anti-Doping Act and the WADA list
For certain peptides, a second law comes into play: the German Anti-Doping Act (Anti-Doping-Gesetz, AntiDopG). It does not only apply to professional athletes. Trading in and placing on the market the doping substances listed there are prohibited, as are acquiring, possessing and importing a “non-small quantity” (nicht geringe Menge) for doping purposes. According to specialist lawyers, this also covers growth-hormone-releasing peptides such as CJC-1295, tesamorelin or ipamorelin. The penalty range goes up to three years’ imprisonment, more in serious cases.
The WADA Prohibited List 2026 (in force since 1 January 2026) names:
- S0 – non-approved substances: explicitly BPC-157. S0 generally covers pharmacologically active substances without approval for human use.
- S2 – growth hormone releasing factors: for example CJC-1295, tesamorelin, ipamorelin, MK-677 and GHRPs such as hexarelin.
So if you take part in competitions with doping controls, you also risk a sports ban. GLP-1 substances such as semaglutide or tirzepatide are not named in the 2026 list. You can find more on the individual substances in the peptide index: BPC-157 and in the overview of biohacking peptides.
What does this mean for you?
In brief, with no claim to completeness:
- Approved GLP-1 medicines are available legally with a prescription from a pharmacy – more in Mounjaro: cost and prescription.
- Research peptides are not approved, their quality is unchecked, and the law attaches to many steps: import, trade, passing on.
- Supplying something to others or ordering for a group is the legally riskiest part.
Not legal advice: This article explains the basics of German law in plain language. Laws and case law change, and every case is different. If you receive a letter from customs or the public prosecutor, or have a specific question, contact a lawyer specialising in pharmaceutical or criminal law.
When to see a doctor
- You have injected a research peptide and develop fever, redness or swelling at the injection site – a sign of contamination or infection.
- Severe abdominal pain, persistent vomiting or circulatory problems after an injection: get medical help immediately, in an emergency call 112.
- Tell your doctor openly what you have taken – medical confidentiality applies, and it is the only way to get safe treatment.
In an emergency: 112.
FAQ
Is possessing research peptides a criminal offence in Germany?
Merely possessing a medicinal product for your own use is usually not itself a criminal offence under the AMG (German Medicines Act). It can be different for substances covered by the Anti-Doping Act in a non-small quantity, and import, passing on or selling can constitute offences of their own.
Does the note “not for human use” protect against prosecution?
No. For classification as a medicinal product, what mainly counts is how a substance acts in the body. The note mainly shows that nobody is liable for quality and safety when used in humans.
Can I pass peptides on to friends?
That is legally risky. The AMG also counts supplying to others as placing on the market, regardless of whether money changes hands. Without an approval, this can be a criminal offence under § 96 AMG.
Is BPC-157 banned in sport?
Yes. BPC-157 is on the WADA Prohibited List 2026 in class S0 (non-approved substances). For athletes subject to doping controls, it is prohibited at all times.
Can I order peptides from abroad?
Medicines without a German approval generally may not be imported. The exception for personal needs is narrow, and according to the German consumer advice centre, consumers are generally not allowed to order from suppliers outside the EU. If in doubt, ask a lawyer.
Sources
- German customs (Zoll): medicinal products – import bans and exceptions (German)
- Verbraucherzentrale NRW: buying medicines abroad – only allowed for personal use (German)
- NADA: Prohibited List 2026 (informational German translation of the WADA list)
- Fachanwalt Strafrecht München: medicines offences §§ 95, 96, 97 AMG (German)
- Schneider Mick Rechtsanwälte: pharmaceutical criminal law (definition of medicinal product, placing on the market) (German)
- Kanzlei Kämpf: growth-hormone peptides and the Anti-Doping Act (German)
This article does not replace medical advice. It gives no dosing recommendations. As of September 2026.