On September 17, 2026, 20 state attorneys general (AGs) led by Alabama AG Steve Marshall issued a letter to the federal government concerning Chinese-sourced ingredients in compounded GLP-1 drugs and peptides. Addressing their to Secretary of State and National Security Adviser Marco Rubio, the AGs characterize these supply chain issues as a national security concern, criticize a 2025 Food and Drug Administration (FDA) policy for exacerbating the problem, and seek federal intelligence on foreign GLP-1 and peptide supply chains and improved information sharing between federal and state partners.
Background
The letter builds on President Donald Trump’s August 2025 executive order on the Strategic Active Pharmaceutical Ingredients Reserve, which treats active pharmaceutical ingredients (APIs), the components that give a drug its therapeutic effect, as a strategic national security vulnerability. The AGs identify semaglutide, tirzepatide, and retatrutide. Retatrutide is investigational and not FDA approved.
The vulnerability alleged by the AGs concerns FDA’s “Green List” under Import Alert 66-80, which identifies manufacturers and products FDA has reviewed and exempted from detention without physical examination under that alert. Listed shipments remain subject to FDA examination at the border. The AGs warn that, without real-time verification of source, chain of custody, and downstream use, the list can become a “laundering channel.”
The Harbin Warning Letter
The AGs cite an FDA warning letter issued to Harbin Jixianglong Biotech Co., Ltd., a Chinese company on the Green List. According to the AGs, an on-site inspection months after Harbin’s placement on the Green List found that it had purchased knock-off semaglutide API from a non-Green List facility not registered with FDA, repackaged and relabeled it under Harbin’s name, changed manufacturing and retest dates, and distributed the API to the United States.
The letter contends that the breach was caught by inspection, noting that detecting the conduct in the Harbin matter required physical presence at the facility. The AGs compare the pattern to the 2007 heparin contamination crisis, in which contaminated bulk material sourced in China was incorporated into finished product in the U.S., resulting in several deaths and hundreds of adverse reactions worldwide. They cite it as evidence that a complex global supply chain is vulnerable to sophisticated adulteration.
The Fentanyl Nexus
The letter’s second concern rests on reporting rather than on an agency finding. The AGs cite reporting that Chinese manufacturers tied to fentanyl precursor supply chains have moved into the U.S. market for cosmetic and weight-loss peptides.
The AGs ask whether those entities also supply GLP-1 ingredients, related peptides, or key starting materials to the U.S. compounding market. The letter does not establish such a connection.
Why It Matters
The letter accompanies active state enforcement. In January 2026, Marshall’s office announced a settlement with Aurora IV and Wellness, a clinic accused of administering research-grade tirzepatide and semaglutide to patients while advertising the drugs as pharmaceutical-grade. Other AGs have also been active in this space, and their enforcement efforts transcend party lines. State consumer protection statutes may reach misrepresentations about what a product is and where it came from, and they operate independently of federal regulatory authorities.
The request signals coordinated state interest. The AGs seek federal information on foreign GLP-1 and peptide supply chains and warning signs states should watch for. Although the letter does not announce an enforcement initiative, it identifies an area businesses should monitor.
The supply-chain concern extends beyond compounded drugs. Manufacturers of branded and generic drugs also rely on foreign-sourced APIs. In 2019, FDA told Congress that 72% of API manufacturing facilities supplying the U.S. market were overseas, including 13% in China. The heparin crisis cited by the AGs involved Baxter’s FDA-approved product, not a compounded drug. Although the regulatory frameworks differ, the letter raises a broader question: whether concerns about foreign API integrity will prompt comparable scrutiny of supply chains for FDA-approved drugs.
Troutman Pepper Locke State Attorneys General Team
| Ashley Taylor – Co-leader and Firm Vice Chair Ashley is co-leader of the firm’s nationally ranked State Attorneys General practice, vice chair of the firm, and a partner in its Regulatory Investigations, Strategy + Enforcement (RISE) Practice Group. He helps his clients navigate the complexities involved with multistate attorneys general investigations and enforcement actions, federal agency actions, and accompanying litigation. |
|
| Clay Friedman – Co-leader Clay co-leads the firm’s State Attorneys General practice and is nationally ranked by Chambers USA for AG Government Relations and in Best Lawyers for Advertising Law. He has dedicated his entire career to state attorney general and federal work, serving for nearly a decade in a senior role and more than 25+ years in private practice. Clay focuses his practice on helping industry-leading companies mitigate the risks associated with state and federal regulatory investigations and associated litigation. |
|
| Chris Carlson Chris advises clients on regulatory, civil, and criminal investigations and litigation. With a background as an assistant attorney general, he provides practical guidance to clients with matters involving state attorneys general and federal regulatory agencies. |
|
| Lauren Fincher Lauren has vast experience handling state attorneys general investigations, navigating complex regulatory compliance matters, and providing strategic counsel in enforcement actions across various industries. She helps clients manage high-stakes regulatory matters and guides them through complex legal landscapes. |
|
| Stephen Piepgrass Stephen leads the firm’s Regulatory Investigations, Strategy + Enforcement (RISE) Practice Group, representing clients in single and multistate enforcement actions, including inquiries and investigations involving state attorneys general and other state and federal governmental enforcement bodies including the CFPB and FTC. He regularly represents clients in highly regulated sectors such as financial services, emerging technologies, health care, insurance, and education. |
|
| Michael Yaghi Mike handles high-profile investigations led by state attorneys general, the FTC, and other federal and state regulatory bodies. He assists clients through these complex government inquiries, assisting them throughout the entire life cycle of investigations, from regulatory enforcement through formal litigation. |
|
| Matthew J. Berns Drawing on his experience in senior leadership roles in the New Jersey Attorney General’s and Governor’s Offices and as a trial attorney for the U.S. Department of Justice, Matt provides an insider’s perspective when guiding clients through complex government investigations, litigation, and other actions. |
|
| Jeff Johnson Jeff helps clients navigate complex regulatory and litigation challenges with local, state, and federal authorities. His clients benefit from his decade of broad litigation experience, understanding of emerging state and federal regulatory issues, and strong relationships with attorneys general across the U.S. In addition to handling cases from trial through state or federal appeals, Jeff serves as amicus counsel in advancing legal rules to support his clients’ vital interests. |
|
| Jay Myers Jay assists clients in heavily regulated industries, including health care, energy, insurance, emerging industries, and data privacy. He provides both regulatory legal advice and government relations strategies. Jay’s past and current clients include Fortune 10 companies, startups, nonprofits, industry associations, and advocacy groups. Recognizing that state government matters are often complex and multifaceted, he utilizes regulatory guidance, government advocacy, or both in tandem to deliver tailored solutions for each client’s unique needs. |
|
| Zoe Schloss Zoe represents clients in litigation and government investigations. As former deputy attorney general for the Delaware Department of Justice, she is an experienced litigator who understands the enforcement priorities that impact her clients. Zoe works with individuals and corporate entities in highly regulated industries, including financial services, health care, and energy. |
|
| Jessica Birdsong Jessica is an associate in the firm’s Regulatory Investigations, Strategy + Enforcement Practice Group. She received her J.D. from the University of Richmond School of Law, magna cum laude, where she served as associate articles editor of the Journal of Law & Technology. |
|
| Sydney Goldberg Sydney is an associate in the firm’s Regulatory Investigations, Strategy + Enforcement (RISE) Practice Group. She advises clients on regulatory compliance and state attorney general (AG) investigations in highly regulated industries, including health care and life sciences. She routinely helps clients navigate alcohol compliance and licensing issues, helping proactively manage regulatory risk. |
|
| Troy Homesley Troy is an accomplished litigator who has represented and defended clients across a wide range of complex, high-stakes disputes at both the trial and appellate levels. He has represented technology companies, business executives, law firms, investment funds, high-ranking federal officials, international non-profits, and asylum seekers. Troy draws on his broad litigation experience to advise clients before litigation arises, while claims are pending or threatened, and leading up to and through trial and appeals. |
|
| Namrata Kang Namrata (Nam) is an associate in the firm’s Regulatory Investigations, Strategy + Enforcement (RISE) Practice Group, based in the Washington, D.C. office. She routinely advises clients on a wide variety of state and federal regulatory matters, with a particular emphasis on state consumer protection laws relating to consumer financial services and marketing and advertising. Nam’s experience transcends multiple industries, including financial services, telecommunications, media, and sports betting. |
|
| Michael Lafleur Michael is an associate in the firm’s Regulatory Investigations, Strategy, and Enforcement Practice Group. Based out of the firm’s Boston office, Mike has deep experience in litigation, investigations, and other regulatory matters involving state-level regulators and state attorneys general. |
|
| William LaRosa Bill represents clients in complex regulatory investigations, state attorneys general matters, and enforcement proceedings. He draws on his experience as a former assistant U.S. attorney and as a private-sector litigator advising corporations in high-stakes litigation and regulatory investigations, including multistate AG investigations. |
|
| Lane Page Lane represents financial institutions and other clients in federal and state regulatory investigations and complex civil litigation. He is particularly focused on consumer protection and fair lending issues. |
|
| Dascher Pasco Dascher provides strategic counsel and representation to clients navigating regulatory compliance, enforcement, and high-stakes litigation. She regularly represents clients in both single and multistate state attorney general (AG) investigations and enforcement actions, as well as before other state enforcement bodies and local government agencies. |
|
| Kyara Rivera Rivera Kyara is an associate in the firm’s Regulatory Investigations, Strategy + Enforcement Practice Group. She received her J.D. from the University of Richmond School of Law, cum laude, where she served as publications and online editor of the Public Interest Law Review. |
|
| Timothy Shyu Timothy advises clients on regulatory compliance and enforcement in highly regulated industries, including health care and life sciences, data privacy and cybersecurity, and emerging technology. He assists companies in navigating complex investigations and enforcement actions, helping them mitigate regulatory risk proactively. |
|
| Trey Smith Trey focuses his practice on representing and advising regulated utilities before state public utility commissions. He routinely helps clients obtain certificates of public convenience and necessity for transmission infrastructure. In this role, Trey works with his clients’ subject-matter experts to manage administrative proceedings, including by preparing initial filings; responding to discovery requests; drafting rebuttal testimony; and litigating any disputed issues. |
|
| Daniel Waltz Dan helps clients navigate all aspects highly regulated relationships between industry participants and federal, state and local governments. Whether engaging with regulators, negotiating transactions or representing clients in the courtroom, he delivers solutions that help his clients achieve their strategic goals. |
|
| Stephanie Kozol Stephanie is Troutman Pepper Locke’s senior government relations manager in the state attorneys general department. |
Recent Comments