GLP-1 Compounded Medications Targeted by Connecticut Attorney General

On May 21, 2025, the Connecticut Office of the Attorney General released a statement and sent letters to Connecticut weight loss clinics, med spas, medical practices and other businesses regarding allegedly or potentially unfair and deceptive conduct relating to compounded GLP-1 medications. Specifically, health care providers in Connecticut that advertise and prescribe compounded GLP-1 medications, such as semaglutide and tirzepatide, may be considered to be violating the Connecticut Unfair Trade Practices Act (CUTPA).

The Attorney General provided several reasons for why providers advertising and prescribing compounded semaglutide and tirzepatide may be violating CUTPA:

Compounding pharmacies are no longer allowed to manufacture semaglutide and tirzepatid injections in bulk (meaning copies of commercially available, U.S. Food and Drug Administration (FDA)-approved GLP-1 semaglutide and tirzepatide products), as they have been removed from the FDA’s shortage list. (More information can be found in Foley’s article “GLP-1 Drugs: FDA Removes Semaglutide from the Drug Shortage List”),
The FDA has raised health and safety concerns about these compounded medications, citing issues such as dosing errors, poor inspection records from overseas manufacturers, and, in some instances, adverse events, some of which required medical intervention,
These compounded medications are often inaccurately labeled as “generic” versions of semaglutide and tirzepatide injections and may contain additives, such as vitamins, which have not been approved by the FDA or evaluated through clinical trials, and
The FDA has not approved any oral GLP-1 medications, nor has it approved the use of GLP-1 medications for cosmetic purposes.

The Connecticut Attorney General has put providers on notice and stated he is prepared to take appropriate action against businesses and individuals who continue to advertise and prescribe semaglutide and tirzepatide in violation of CUTPA.

Weight loss clinics, med spas, medical practices and other businesses advertising and prescribing compounded versions of semaglutide and tirzepatide in Connecticut are advised to come into compliance with the CUTPA.

Foley continues to monitor compounded GLP-1 medication developments in Connecticut and across the country. For additional resources on GLP-1 drugs and how they will change the health care & life sciences and technology industries, click here to read the other articles in our series.

Foley is here to help you address the short- and long-term impacts in the wake of regulatory changes. We have the resources to help you navigate these and other important legal considerations related to business operations and industry-specific issues. Please reach out to the authors, your Foley relationship partner, our Health Care & Life Sciences Sector, or to our Innovative Technology Sector with any questions.

Special thanks to Alina Mueller, a summer associate in Foley’s Denver office, for her contributions to this article.

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