20 State Attorneys General Urge State Department to Tighten FDA's GLP-1 'Green List'

What Happened

A coalition of 20 state attorneys general, led by Alabama's Steve Marshall, has formally asked the U.S. State Department to tighten oversight of the FDA's "Green List" — the program that gives preferential border treatment to selected foreign suppliers of GLP-1 active pharmaceutical ingredients (APIs).

In a letter addressed to Secretary of State Marco Rubio, the coalition argues that Chinese suppliers of semaglutide, tirzepatide and retatrutide ingredients used in compounded medications exploited weaknesses in the import program, allowing material from unapproved sources to enter the country through companies the FDA had vetted. The attorneys general frame the gap as both a consumer-safety failure and a national-security exposure.

"Chinese businesses quickly found and exploited a gap in the system that happens to be a direct line to Americans who use these popular injectable drugs," Marshall said, calling it "a direct and immediate risk to consumers' health and safety, as well as a national security risk."

The coalition asks Rubio and the National Security Council to establish greater oversight of the Green List — or to keep ingredients considered potentially dangerous out of the country entirely.

Who Is Affected

• Patients using compounded GLP-1 medications, whose ingredients may trace back to facilities U.S. regulators never inspected
• State enforcers, who have pursued gray-market sellers of research-grade injectables in their own courts
• Compounding pharmacies and telehealth prescribers, who rely on API sources they cannot directly audit
• Researchers, who source incretin compounds through the same global chemical network the coalition is warning about

Timeline

• September 2025 — The FDA establishes the Green List as part of a GLP-1 API import alert, allowing faster entry for ingredients from facilities it had inspected or evaluated
• February 2026 — Harbin Jixianglong Biotech, a Chinese manufacturer previously on the Green List, is removed and placed on a separate import alert covering companies that failed drug-manufacturing standards
• May 2026 — An FDA warning letter finds Harbin bought semaglutide from outside suppliers, repackaged and relabeled it as its own, altered manufacturing and retest dates, and shipped some of it to the United States — conduct the agency said may have circumvented the import program's safeguards
• September 2026 — The 20-state coalition writes to the State Department and National Security Council seeking greater Green List oversight, after Alabama settled with an in-state business that sold research-grade tirzepatide and semaglutide in violation of state deceptive-trade-practices law

What This Means for Researchers

Two lessons stand out. First, a supplier's presence on a regulatory "trusted" list is not proof of integrity — the FDA itself concluded that a listed company relabeled third-party material as its own. Second, enforcement is converging on shipment-level provenance rather than firm-level trust, so documentation expectations around research compounds are likely to tighten. The FDA has separately cautioned that compounded GLP-1 drugs are not FDA-approved and receive no premarket review — a distinction that matters when weighing gray-market sources.

How to Verify Your Peptides

• Start with how peptide testing works and what a certificate of analysis actually proves
• Know the difference between HPLC and LC-MS methods, which answer different questions about purity and identity
• Review the testing FAQ for the questions to ask any supplier before ordering

Safe Alternatives

• For established incretin profiles, see our guides on semaglutide and tirzepatide
• Compare suppliers that publish batch-specific, independent lab results in our vendor directory

Sources

• Regulatory announcements from the Alabama Attorney General's Office, September 2026
• FDA warning letter and import alert disclosures, 2026
• Industry reports on GLP-1 ingredient sourcing