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ProPeptideGuide

Synthetic ACTH fragment analog; investigational neuropeptide

Semax

Also known as ACTH(4-7)-PGP, ACTH 4-10 analog, MEHFPGP

Not FDA-approved and not currently on the FDA 503A or 503B bulks lists. FDA removed Semax (heptapeptide) from 503A Category 2 on April 22, 2026 because nominations were withdrawn; PCAC review scheduled for July 24, 2026.

Not currently legal in the US
Editorially verified

What it is

Semax is a synthetic peptide derived from the ACTH(4-10) region, modified with a Pro-Gly-Pro extension. Russian-language literature often describes it as a neuropeptide or nootropic compound studied for cerebral ischemia, optic nerve disease, posthypoxic encephalopathy, and other neurologic conditions[913 ].

Chemical structure

Semax is a synthetic heptapeptide commonly described as ACTH(4-7)-Pro-Gly-Pro with the sequence Met-Glu-His-Phe-Pro-Gly-Pro[1 ]. PubChem’s Semax trifluoroacetate record lists the sequence MEHFPGP and a molecular formula for that salt form of C39H52F3N9O12S[1 ].

Mechanism — neuroprotection rationale

The proposed rationale is neuroprotection rather than classic adrenal stimulation. Semax is discussed in relation to melanocortin/ACTH fragment biology, nitric oxide signaling, oxidative stress, neurotrophic gene expression, and inflammatory pathways[1112 ]. These mechanisms are mostly supported by animal and molecular studies rather than large independently replicated Western clinical trials.

Semax is commonly sold online as a nasal “nootropic” peptide for focus, cognition, stroke recovery, migraine, mood, or neuroprotection. These consumer claims often go well beyond the cited evidence. No FDA-approved Semax product exists in the United States, and there is no approved route, dose, indication, contraindication profile, drug-interaction framework, or FDA-reviewed long-term safety label[27 ].

The FDA’s July 2026 PCAC agenda identifies cerebral ischemia, migraine, and trigeminal neuralgia as reviewed uses for Semax-related bulk substances[4 ]. That agenda item does not mean FDA has approved Semax or concluded that it is safe or effective; it means FDA plans to seek advisory input on possible 503A bulks-list inclusion[24 ].

Regulatory status

Semax is not FDA-approved for any indication. No FDA-approved prescription product containing Semax was identified in FDA materials reviewed for this draft[27 ].

April 2026 503A removal — procedural, not authorization

Under section 503A, state-licensed pharmacies and physicians may compound with bulk drug substances only if statutory conditions are met, including use of a substance with an applicable USP/NF monograph, a component of an FDA-approved drug product if no monograph exists, or a substance on FDA’s 503A bulks list[3 ]. FDA’s April 22, 2026 update states that “Semax (heptapeptide)” was removed from Category 2 because nominations were withdrawn, and that FDA intends to consult PCAC on July 24, 2026 regarding possible inclusion of Semax acetate and Semax free base on the 503A bulks list[2 ,4 ].

Removal from Category 2 is not FDA approval and does not itself authorize routine compounding. Semax is not listed in Category 1 in the April 22, 2026 document and was not identified on the 503A bulks list reviewed for this draft[23 ].

503B and FDA safety-risk listing

For 503B outsourcing facilities, FDA states that a bulk substance may be used only if it appears on the 503B bulks list or the compounded drug appears on FDA’s shortage list at the relevant time[5 ]. Semax was not identified on the FDA 503B bulks list reviewed for this draft[6 ].

FDA’s safety-risk page lists Semax among withdrawn nominated substances and states that compounded drugs containing semax may pose immunogenicity risk for certain routes of administration due to aggregation and peptide-related impurities. FDA also states that it has no or limited safety-related information for proposed routes and lacks sufficient information to know whether the drug would harm humans[7 ].

Semax was not identified in the federal controlled-substance schedules in 21 CFR Part 1308 as reviewed for this draft[8 ]. Date of last regulatory verification: May 5, 2026.

Research summary

Human clinical literature for Semax is mostly Russian-language and older. Polunin and colleagues evaluated Semax in optic nerve disease and partial optic nerve atrophy, comparing different administration approaches with a control group as part of a therapeutic complex[9 ]. The abstract reports improvement in visual acuity, visual fields, optic nerve electrophysiologic measures, and color vision[9 ]. Because the publication is in Russian and appears to involve combination therapy rather than a modern placebo-controlled registration trial, the findings should be treated as preliminary.

Posthypoxic encephalopathy — safety signal

Alekseeva and colleagues studied Semax in 73 patients with posthypoxic encephalopathy during follow-up[10 ]. The abstract reported that therapy was effective in patients with mnestic disorders and noted EEG episodes of paroxysmal activity after Semax injection in some cases[10 ]. This safety signal should be preserved in any medical-review discussion[10 ].

Motor neuron disease exploratory study

Serdiuk and colleagues studied Semax in 27 patients with motor neuron disease using needle electromyography and quality-of-life measures[13 ]. This exploratory setting should not be generalized to claims that Semax treats ALS or motor neuron disease.

Preclinical ischemia models

Preclinical ischemia literature is more mechanistic. Bashkatova and colleagues reported that Semax affected nitric oxide generation in rat cerebral cortex after incomplete global ischemia[11 ]. Sudarkina and colleagues reported brain protein-expression findings consistent with a protective effect in a rat cerebral ischemia-reperfusion model[12 ]. These studies support biological plausibility but do not establish clinical efficacy in human stroke, migraine, trigeminal neuralgia, cognitive enhancement, or recovery.

Overall, Semax has a notable Russian research history but lacks FDA approval-quality evidence in the United States. The strongest editorial framing is that Semax has been studied for neurologic and ischemic conditions, with limited and geographically concentrated clinical evidence and preclinical support.

Public discourse

The FDA Pharmacy Compounding Advisory Committee scheduled Semax-related substances for review and identified the proposed indications[4 ].

Cerebral ischemia, migraine, and trigeminal neuralgia
FDA Pharmacy Compounding Advisory Committee , July 23–24, 2026 agenda FDA April 15, 2026

The FDA human drug compounding safety-risk page summarized Semax safety concerns for withdrawn nominations[7 ].

limited safety-related information
FDA — Bulk Substances Significant Safety Risks , Compounding policy page FDA April 22, 2026

G. S. Polunin and colleagues, ophthalmology researchers, described Semax use in optic nerve disease[9 ].

new Russian drug semax
Polunin GS et al. , Ophthalmology researchers (Russian) Vestn Oftalmol (PubMed) January 1, 2000

Olga Yu. Sudarkina and colleagues, neurobiology researchers, studied Semax in a rat ischemia-reperfusion model[12 ].

Rat Model of Cerebral Ischemia-Reperfusion
Sudarkina OY et al. , Neurobiology researchers Int J Mol Sci — Brain Protein Expression Profile (rat ischemia-reperfusion) January 1, 2021

Public discourse reflects the views of the speakers cited and does not represent medical advice or the editorial position of ProPeptideGuide.

Side effects and safety

Semax has no FDA-approved prescribing information. There is no FDA-reviewed label establishing contraindications, common adverse reactions, pregnancy or lactation safety, drug interactions, carcinogenicity data, or monitoring recommendations[27 ].

FDA’s compounding safety concerns include potential immunogenicity, aggregation, peptide-related impurities, and limited route-specific safety information[7 ]. These issues are relevant to nasal and injectable products sold as research peptides.

Paroxysmal EEG activity

The posthypoxic encephalopathy abstract reported EEG episodes of paroxysmal activity after Semax injection in some cases[10 ]. This does not establish causality or quantify risk, but it is important because Semax is commonly marketed for neurologic use.

Theoretical concerns

Theoretical concerns include use in seizure disorders, migraine, psychiatric disease, stroke, anticoagulation contexts, pregnancy, pediatric populations, and concurrent neurologic medications. These are not defined by FDA labeling because no FDA label exists.

Long-term safety data are insufficient. Products sold online as Semax may vary in sequence, salt form, concentration, sterility, and impurities.

Available through

Semax is not currently available through routine FDA-compliant prescription or compounding channels in the United States as of 2026-05-05[27 ]. It is not FDA-approved, is not on the 503A or 503B bulks lists, and awaits PCAC review scheduled for July 24, 2026[2 ,4 ].

ProPeptideGuide does not link to or endorse grey-market vendors, research-chemical sellers, imported products, online peptide shops, or clinics advertising Semax for cognition, focus, stroke recovery, migraine, trigeminal neuralgia, mood, or neuroprotection.

Frequently asked questions

Is Semax FDA-approved?
No. Semax is not FDA-approved for any indication in the United States.
Can Semax be legally compounded?
Current FDA materials do not support routine compliant compounding. Semax was removed from 503A Category 2 because nominations were withdrawn, but it has not been added to the 503A bulks list.
What is Semax being reviewed for by FDA's PCAC?
FDA's July 2026 PCAC agenda lists cerebral ischemia, migraine, and trigeminal neuralgia as reviewed uses for Semax-related bulk substances.
Is Semax proven for stroke recovery?
No FDA approval-quality evidence was identified. Russian clinical and preclinical studies exist, but they are not sufficient to establish a US-approved treatment claim.
Is Semax a nootropic?
It is often marketed that way online, and some literature describes nootropic or neuroprotective properties. These claims are not FDA-approved and should be treated as investigational.
Is Semax a controlled substance?
Semax was not identified in the federal controlled-substance schedules in 21 CFR Part 1308 as reviewed for this draft. That does not make it FDA-approved or legally available for human use.
What is the biggest safety concern?
The main concern is lack of FDA-reviewed safety data. FDA notes immunogenicity, impurity, aggregation, and limited safety-information concerns.

References

  1. National Center for Biotechnology Information. PubChem Compound Summary for Semax, CID 71312027 . Accessed 2026-05-05 . Source
  2. U.S. Food and Drug Administration. Bulk Drug Substances Nominated for Use in Compounding Under Section 503A . Updated April 22, 2026 . Source
  3. U.S. Food and Drug Administration. Bulk Drug Substances Used in Compounding Under Section 503A of the FD&C Act . Source
  4. U.S. Food and Drug Administration. July 23-24, 2026: Meeting of the Pharmacy Compounding Advisory Committee . Source
  5. U.S. Food and Drug Administration. Bulk Drug Substances Used in Compounding Under Section 503B of the FD&C Act . Source
  6. U.S. Food and Drug Administration. 503B Bulk Drug Substances List . Content current as of May 16, 2024 . Source
  7. U.S. Food and Drug Administration. Certain Bulk Drug Substances for Use in Compounding that May Present Significant Safety Risks . Content current as of April 22, 2026 . Source
  8. 21 CFR Part 1308 — Schedules of Controlled Substances . Code of Federal Regulations . Accessed 2026-05-05 . Source
  9. Polunin GS, Nurieva SM, Baiandin DL, Sheremet NL, Andreeva LA. Evaluation of therapeutic effect of new Russian drug semax in optic nerve disease . Vestn Oftalmol . 2000;116(1):15-18 . PMID: 10741256
  10. Alekseeva GV, Bottaev NA, Goroshkova VV. Use of semax at a follow-up of patients with posthypoxic encephalopathy . Anesteziol Reanimatol . 1999;(1):40-43 . PMID: 10199046
  11. Bashkatova VG, Koshelev VB, Fadyukova OE, et al.. Novel synthetic analogue of ACTH 4-10 (Semax) but not glycine prevents the enhanced nitric oxide generation in cerebral cortex of rats with incomplete global ischemia . Brain Res . 2001;894(1):145-149 . doi:10.1016/s0006-8993(00)03324-2 PMID: 11245825
  12. Sudarkina OY, Filippenkov IB, Stavchansky VV, et al.. Brain Protein Expression Profile Confirms the Protective Effect of the ACTH(4-7)PGP Peptide (Semax) in a Rat Model of Cerebral Ischemia-Reperfusion . Int J Mol Sci . 2021;22(12):6179 . doi:10.3390/ijms22126179 PMID: 34201112
  13. Serdiuk AV, Levitskii GN, Miasoedov NF, Skvortsova VI. The study of chronic partial denervation and quality of life in patients with motor neuron disease treated with semax . Zh Nevrol Psikhiatr Im S S Korsakova . 2007;107(4):29-39 . PMID: 18379501

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