Table of Contents
1 | The Boom—and the Brick Wall
The global market for dietary supplements, cosmetic injectables, “research” peptides and bio-hacking powders has sprinted past 180 billion dollars a year. Consumers want faster recovery, leaner physiques and sharper minds, and they are willing to buy novel compounds to get there. Unfortunately, the same novelty that excites shoppers sparks anxiety inside the offices of regulators and, by extension, the card networks and acquiring banks that clear every transaction.
Over the past two years the U.S. Food & Drug Administration has flooded the Federal Register with warning letters that target everything from stimulant-spiked fat burners to peptide weight-loss kits and unapproved hormone analogues. Visa answered with its Visa Integrity Risk Program, a successor to the Global Brand Protection rules, while Mastercard hardened its own BRAM standards. Each program brands unapproved pharmaceutical ingredients as “intolerable” risk.
When an underwriting team spots those compounds on a product label—or even in a blog post that hints at future availability—the safest move for the bank is an immediate decline or termination.
2 | How Banks Decide What’s “Forbidden”
Acquiring banks start by reading the FDA playbook. If a substance carries the agency’s “unapproved drug” designation, that alone is grounds to refuse processing.
Next they scan the Drug Enforcement Administration schedules, because it is illegal to touch money tied to controlled substances even when a merchant claims “not for human consumption.”
Visa and Mastercard then circulate their own confidential watch lists to processors; these documents often pull language straight from FDA warning letters but also fold in emerging chargeback data that shows which ingredients are triggering refunds.
Once a compound lands on a brand-network bulletin it may never come off, so merchants who ignore early red flags often discover too late that the acquiring ecosystem has closed around them.
In short
FDA status. Anything classified as an unapproved drug—for example SARMs or peptide injectables—instantly moves to a “no-board” list.
DEA scheduling. Controlled substances (Schedule I–V) are off-limits, even if marketed as “not for human consumption.”
Card-brand watch lists. Visa VIRP and Mastercard BRAM circulate ingredient bulletins to acquirers.
Chargeback data. Ingredients tied to a spike in fraud or product-quality disputes are often black-flagged long before the FDA acts.
The result is a living blacklist that can feel opaque to merchants. The table that follows pulls those fragmented policies into one reference sheet.
DISCLAIMER: Regulatory positions change quickly; use this list as a starting point and run every SKU through an updated compliance check.
| Category | Banned / Unsupported Examples* | Key Reason Processors Reject | Notable FDA / Card-Brand Reference |
|---|---|---|---|
| Amphetamine-like Stimulants & Fat-Burners | DMAA, DMHA, 1,4-DMBA, AMP Citrate, Ephedra/Ephedrine alkaloids, Oxilofrine, Octodrine, Clenbuterol, Synephrine > 50 mg, Higenamine, DNP (2,4-dinitrophenol) | Unapproved drugs; cardiac events & deaths | FDA “Bodybuilding Products Can Be Risky” update (2024) |
| Selective Androgen Receptor Modulators (SARMs) | Ostarine (MK-2866), Ligandrol (LGD-4033), RAD-140, YK-11, S-23, S-4 (Andarine), SR9009 (Stenabolic), GW501516 (Cardarine), MK-677 (Ibutamoren) | Investigational drugs; serious hepatotoxicity & stroke risk | FDA SARM warning & USADA advisory |
| Research Peptides | BPC-157, TB-500, CJC-1295, Ipamorelin, Sermorelin, GHRP-2/6, Hexarelin, Tesamorelin, PT-141 (Bremelanotide) OTC, Melanotan I/II, Kisspeptin-10, AOD-9604, IGF-1 LR3, PEG-MGF, Epithalon, GHK-Cu | Not on FDA 503A bulk-drug list; unapproved new drugs | FDA 503A peptides exclusion notice (2024) |
| Hormone / Pro-Hormone Derivatives | 1-Androstenediol, 4-Andro, 19-Nor-DHEA, Methylstenbolone, Halodrol, Superdrol, Trenavar, Epistane, hCG oral drops, Pregnenolone >50 mg, Liothyronine (T3) | Classified as anabolic steroids or Rx-only | Multiple FDA steroid warning letters |
| Unapproved Sexual-Enhancement Analogues | Undeclared Sildenafil, Tadalafil, Vardenafil & analogues; Yohimbe extracts > 30 mg; Icariin > 60 % | Adulterated “tainted” products; cardiac risk | cardiac risk FDA Tainted Sexual Enhancement list (updated 2025) |
| Weight-Loss Pharmaceuticals | Sibutramine, Lorcaserin, Rimonabant, DNP, high-dose Tirzepatide or Semaglutide (non-Rx), Phenolphthalein | Withdrawn or Rx-only drugs | FDA weight-loss tainted products database |
| Cognitive / Mood “Grey-Market” Drugs | Phenibut, Picamilon, Noopept, Vinpocetine, Adrafinil | Classified as unsafe food additives or unapproved drugs | FDA warning letters (various) |
| Plant- or Alkaloid-Derived Risks | Kratom (Mitragynine, 7-OH-Mitragynine), High-kavalactone Kava extracts > 70 %, Yohimbe high dose, Betel nut concentrates | Import alerts; DEA watch; hepatotoxicity cases | FDA import alerts & public health advisories |
| Cannabinoid Variants & Psychedelics | Δ-8 THC, Δ-10 THC, THCO, HHC-P, THCP, Synthetic cannabinoids (Spice/K2), Ibogaine micro-dose capsules, “Nootropic mushrooms” with psilocybin | Federal Schedule I or patchwork legality; Visa & Mastercard cannabis policies | Visa VIRP & Mastercard BRAM cannabis notes |
4 | Deep-Dive Spotlights
BPC-157—the Biohacker’s Darling
Marketed online as a magical “gut-healing” peptide, BPC-157 was formally rejected from the FDA 503A bulk-drug list in 2024, making any over-the-counter sale an unapproved new-drug violation. Acquiring banks now treat BPC-157 SKUs the same way they treat counterfeit Viagra: a zero-tolerance drop.
SARMs and the 0.00 % Approval Rate
Despite relentless re-labeling tricks (“research chemical,” “not for human consumption”), Visa and Mastercard’s enforcement data show near-instant account terminations once SARMs are detected, largely because they sit on WADA’s Prohibited List and have no FDA approval path in sight.
DMAA & Relatives—the Stimulants That Won’t Die
Since FDA’s 2013 seizure of Jack3d and OxyElite Pro, DMAA keeps re-emerging under botanical aliases (“geranium extract,” “2-amino-4-methylpentane”). Processors now auto-flag the CAS numbers, not the marketing names, so swapping labels no longer slips past underwriting.
5 | How Processors Detect Red-Flag Ingredients
Underwriting teams deploy a mix of automation and human review. Web-crawling software scrapes product pages, blog articles and even JavaScript variables for a growing dictionary of chemical synonyms. Certificates of analysis are checked for purity values that make sense; an implausible ninety-nine-percent purity on a kitchen-sink isolate often lands the merchant in manual review.
Meanwhile risk engines crunch chargeback data: if a single SKU generates an unusual surge of product-quality disputes, the bank will pull the label and check for undeclared drugs even when the ingredient panel appears innocent. Because Visa and Mastercard may fine acquirers up to one hundred thousand dollars a month for knowingly processing prohibited products, most banks err on the side of cancelling first and asking questions later.
Detection Methods in Short
Automated scrapers parse product URLs, labels and blog posts for a growing dictionary of chemical synonyms.
Certificate-of-analysis triggers: inconsistent COA values or out-of-range purity percentages move an account to manual review.
Chargeback heuristics: if a SKU drives refund spikes, the acquirer cross-checks for known banned substances—even when the label appears clean.
Visa’s VIRP and Mastercard’s BRAM both allow fines of up to $100,000 per month for acquirers that knowingly process prohibited goods, so banks rarely give second chances.
6 | What Happens When You List a Forbidden Ingredient
The consequences are immediate. Processing usually halts the same day, terminals switch to a “call auth” response and funds already in the pipeline slide into a 180-day reserve. Your LLC, the site’s domain names and even key officers are tagged in shared risk databases, making future approvals vastly harder. Regulatory headaches follow close behind; the FDA and FTC can subpoena processor statements to trace sales volumes, leaving merchants exposed to civil suits and, in extreme cases, criminal charges.
Quick View of Consequences
Same-day MID termination—no processing, no revenue.
Rolling reserve converted to permanent hold for up to 180 days.
Reputation tagging—shared risk databases mark your LLC, site domains and even key officers, making future approvals harder.
Regulatory spill-over—the FDA and FTC can subpoena processor statements to trace sales, exposing merchants to civil or criminal penalties.
7 | Staying on the Rails—A Due-Diligence Blueprint
Avoiding those nightmares starts with disciplined ingredient vetting. Every raw material that arrives in your warehouse should be cross-checked monthly against new FDA warning letters, DEA schedules and the World Anti-Doping Agency’s prohibited list. Transparent labeling matters just as much. Publish ISO-17025 laboratory certificates that state exact milligram amounts and skip secret “proprietary blends” that hide dosages.
In marketing copy, drop words like “cures,” “heals” or “pharma-grade” and lean on structure-function claims that regulators allow for dietary supplements. On the operational side, reduce chargebacks with clear refund terms, gateway-triggered reminder emails before rebills and, where available, 3-D Secure authentication. Finally, choose an acquirer that understands the supplement space.
A Due Diligence Checklist
Ingredient Clearance. Cross-reference every raw material against FDA warning letters, DEA schedules and WADA’s list monthly.
Transparent Labeling. Use ISO-17025 lab COAs, disclose exact milligram amounts, and abandon proprietary blends that hide dosages.
Claim Discipline. Replace “heals,” “cures,” or “Pharma-grade” with structure-function language. Even truthful claims can violate processor rules if they imply drug use.
Chargeback Prevention. Post clear refund terms, gateway-triggered email reminders before rebills, and 3-D Secure where available.
Choose the Right Acquirer. Domestic specialists like Durango Merchant Services vet labels early, offer gateway filters to soft-decline risky orders, and can guide you to EU or LatAm banks when a product is legal abroad but restricted in the U.S.
8 | Flashpoints to Watch, 2025–2026
The compliance horizon is hardly static. Synthetic cannabinoids such as THC-JD and THCP-O sit on the DEA’s rule-making calendar. Bioregulator peptides delivered via exosome technology are appearing in anti-aging clinics and will likely draw the FDA’s scrutiny. Compounded GLP-1 agonists—especially semaglutide and tirzepatide—already face mounting enforcement as demand outstrips legitimate pharmacy supply. Meanwhile, formulators are using artificial-intelligence platforms to craft nootropic stacks; processors will move quickly to ban any AI-designed ingredient that derives from scheduled drugs. Here is a summary of things to look out for:
Next-gen cannabinoids (THC-JD, THCP-O) slated for DEA review.
Exosome-based “bioregulator” peptides entering the grey market.
Compounded GLP-1 agonists (semaglutide / tirzepatide) facing escalating FDA scrutiny.
AI-designed nootropic stacks—processors likely to ban models trained on scheduled compounds.
Expect VIRP and BRAM bulletins to grow by double digits each quarter as these niches explode.
9 | The Business Case for Zero-Tolerance Compliance
A single tainted SKU can cascade into processor termination, card-brand fines, frozen reserves and public recalls—wiping out margins earned on dozens of clean products. Conversely, brands that out-compete on safety and transparency see lower dispute ratios, faster funding, and better volume tiers from acquirers.
Durango Merchant Services has placed high-risk nutraceutical and wellness merchants for more than two decades. Our underwriting team maintains a live forbidden-ingredient matrix synced with FDA, DEA and card-brand updates—so you know exactly where the line is before you step over it.
Frequently Asked Questions
Not exactly, but the FTC wants comparable “time, burden, expense, and ease of use.” If steps 1-3 at sign-up are mandatory identity checks, you may ask the same on cancel. You may not add a “call retention” hurdle if one didn’t exist at purchase.
Only if they also used live chat to sign up. Otherwise, the rule bars forced human interaction.
Installment contracts with a fixed payment schedule typically aren’t “negative-option features,” but ancillary services (roadside assistance, credit monitoring) often are.
