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HB4036 • 2026

bulk drug substances; prohibitions

HB4036 - bulk drug substances; prohibitions

Passed Legislature

This bill passed both chambers and reached final enrollment, even if later executive action is not shown here.

Sponsor
Michele Peña
Last action
2026-02-10
Official status
House second read
Effective date
Not listed

Plain English Breakdown

The bill summary and text do not provide specific details on enforcement mechanisms or funding.

Bulk Drug Substances; Prohibitions

This bill makes it illegal to sell or distribute certain bulk drug substances used in compounded medications unless strict quality control measures are followed.

What This Bill Does

  • Makes it unlawful for any person or entity to engage in the sale, transfer, or distribution of a drug compounded using specific bulk drug substances without proper verification and documentation of their quality.
  • Requires compounders to use only pharmaceutical-grade bulk drug substances that meet certain standards and come with a certificate of analysis.
  • Mandates that manufacturers and wholesalers provide written proof that the bulk drug substance is pharmaceutical grade before selling it for compounding purposes.
  • Requiring those who sell compounded drugs to keep detailed records about the bulk drug substances used, including testing results, for at least two years after the last batch expires.
  • Gives the Arizona State Board of Pharmacy and its agents the authority to inspect facilities that compound medications or supply bulk drug substances.
  • Imposes penalties on anyone who violates these rules, such as fines up to $1,000 per dose and suspension or revocation of licenses.

Who It Names or Affects

  • Pharmacies and pharmacists who compound medications
  • Manufacturers and wholesalers selling bulk drug substances for compounding purposes

Terms To Know

Bulk Drug Substance
A substance intended to be used in making a finished drug product, providing pharmacological activity or another direct effect.
Pharmaceutical Grade Product
A product that meets the quality standards set by regulatory bodies for use in medications.

Limits and Unknowns

  • The bill does not specify how it will be enforced or funded.
  • It is unclear what specific penalties will apply to those who refuse inspections.

Bill History

  1. 2026-02-10 House

    House second read

  2. 2026-02-09 House

    House Rules: None

  3. 2026-02-09 House

    House International Trade: FAILED

  4. 2026-02-09 House

    House Health & Human Services: W/D

  5. 2026-02-09 House

    House first read

Official Summary Text

HB4036 - 572R - House Bill Summary

ARIZONA HOUSE OF REPRESENTATIVES

57th
Legislature, 2nd Regular Session

Majority Research Staff

HB4036
:
bulk drug substances; prohibitions

Sponsor:
Representative Pe�a, LD 23

Committee
on International Trade

Overview

Regulates
compounded medications and bulk drug substances.

History

It is unlawful for any person to compound, sell or dispense
any drugs or to dispense or compound the prescription orders of a medical
practitioner, unless that person is a pharmacist or a pharmacy intern acting
under the direct supervision of a pharmacist. A pharmacy technician or support
personnel is not prevented from assisting in the dispensing of drugs if this is
done pursuant to rules adopted by the Arizona State Board of Pharmacy (Board)
and under the direct supervision of a licensed pharmacist or under remote
supervision by a pharmacist (
A.R.S. �
32-1961
).

Compounding pharmacies licensed in this state must have
access to active pharmaceutical ingredients for use in compounding that meet
United States pharmacopeia monographs, if the active pharmaceutical ingredient:
1) is prepared for use by a United States Food and Drug
Administration-registered (FDA) active pharmaceutical ingredient manufacturer
or packager; and 2) is shipped into this state in compliance with state law and
arrives with a certificate of analysis detailing quality specifications, in
order to provide chronically ill patients and terminally ill patients with the
prescribed individual course of treatment (
A.R.S. �
32-1971
).

Provisions

1.

Mandates
that is it unlawful for any person or entity to engage in the sale, transfer or
distribution of a drug compounded under the Federal Food, Drug, and Cosmetic
Act (FD&C Act) using a drug substance that is a glucose-dependent
insulinotropic polypeptide receptor or glucagon-like peptide-1 receptor agonist
used for obesity or weight management or a drug substance component of a
similar drug approved by the FDA for obesity or weight management. (Sec. 1)

2.

Allows the
drug compounder to be sold, transferred or distributed only if the compounder:

a.

uses bulk
drug substances that comply with the standards of a United States pharmacopoeia
or national formulary monograph and the United States pharmacopoeia chapter on
pharmacy compounding, as prescribed;

b.

confirms
that any bulk drug substance used was manufactured according to the process
prescribed by federal law;

c.

ensures that
the bulk drug substance is a pharmaceutical grade product;

d.

verifies
that the bulk drug substance is accompanied by a valid certificate of analysis;

e.

conducts and
documents quality control testing of any bulk drug substance before its use in
a compounded drug, as outlined;

f.

conducts and
documents quality control testing of the finished drug product compounded, as
prescribed;

g.

obtains
proof that the manufacture of the bulk drug substance took place in an
establishment that meets listed requirements; and

h.

complies
with the FD&C Act. (Sec. 1)

3.

Stipulates
that it is unlawful for any manufacturer or wholesaler to sell, transfer or
distribute a bulk drug substance for use in compounding without providing to
the purchaser written verification that the substance is pharmaceutical grade
and meets sourcing requirements and documentation of any quality control
testing as outlined. (Sec. 1)

4.

Requires any
person or entity engaging in the sale, transfer or distribution of compounded
drugs to maintain all records related to the acquisition, examination and
testing of the bulk drug substance for at least two years after the expiration
date of the last lot of drug substance, as prescribed. (Sec. 1)

5.

Authorizes
the Board or the Board's authorized agent to inspect any person or entity
engaging in compounding drugs, as well as any domestic supplier, wholesaler,
repackager or other provider of the drug substance. (Sec. 1)

6.

Asserts that
refusal to allow the Board access to conduct an inspection constitutes a
violation. (Sec. 1)

7.

Mandates
that it is unlawful for any person to advertise or otherwise promote compounded
medications unless the advertisement is truthful and not misleading as
outlined. (Sec. 1)

8.

Subjects a
person or entity in violation to a civil penalty of $1,000 per dose of the
illegally compounded drug sold, transferred or distributed and a suspension or
revocation of the licensee's or permittee's license or permit. (Sec. 1)

9.

Allows the
Board to adopt rules as necessary to implement regulation on compounded
medications. (Sec. 1)

10.

Defines
pertinent terms. (Sec. 1)

11.

Contains
legislative findings. (Sec. 1)

12.

13.

14.

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FOOTER ---------

15.

Initials LM���������������������� HB
4036

16.

2/13/2026� Page 0 International
Trade

17.

18.

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Current Bill Text

Read the full stored bill text
HB4036 - 572R - I Ver

REFERENCE TITLE:
bulk drug substances; prohibitions

State of Arizona

House of Representatives

Fifty-seventh Legislature

Second Regular Session

2026

HB 4036

Introduced by

Representative
Pe�a

AN
ACT

AMending title 32, chapter 18, article 3,
Arizona Revised Statutes, by adding section 32-1971.01; relating to the Arizona
state board of pharmacy.

(TEXT OF BILL BEGINS ON NEXT PAGE)

Be it enacted by the Legislature of the State of Arizona:

Section 1. Title 32, chapter 18, article 3,
Arizona Revised Statutes, is amended by adding section 32-1971.01, to read:

START_STATUTE
32-1971.01.

Compounded medications; records; inspections; bulk drug
substances; prohibitions; deceptive advertising; penalties; rules; definitions

A. It is unlawful for any person or
entity to engage in the sale, transfer or distribution of a drug compounded
under section 503A of the federal food, drug, and cosmetic act (21 United
States Code section 353
a
) using a drug substance that is
a glucose-dependent insulinotropic polypeptide receptor or glucagon-like
peptide-1 receptor agonist used for obesity or weight management or a
drug substance that is a component of a similar drug approved by the united
states food and drug administration for obesity or weight management unless the
compounder of the drug:

1. Uses bulk drug substances that
comply with the standards of an applicable United States pharmacopoeia or
national formulary monograph, if a monograph exists, and the United States
pharmacopoeia chapter on pharmacy compounding or, If a national formulary
monograph does not exist, the bulk drug substances either:

(
a
) Are drug
substances that are components of drugs approved by the United States food and
drug administration.

(
b
) Appear on
the list developed by the United States food and drug

administration
pursuant to

21 United States Code section 353
a
(
b
)(1)(A)(
i
)(III)
.

2. If the labeling of a drug approved
by the united states food and drug administration specifies a process for
manufacturing the bulk drug substance, confirms that any bulk drug substance
used was manufactured according to the process prescribed by federal law.

3. Ensures that the bulk drug
substance is a pharmaceutical grade product.

4. Verifies that the bulk drug
substance is accompanied by a valid certificate of analysis.

5. Conducts and documents quality
control testing of any bulk drug substance before its use in a compounded drug
to confirm the identity and content of the bulk drug substance and the name and
quantity of each impurity present in the bulk drug substance in an amount that
exceeds one-tenth of one percent.

6. Conducts and documents quality
control testing of the finished drug product compounded in batches before
release and at expiry for any impurities derived from the use of the bulk drug
substance, including the chemical name and quantities of any such impurities.

7. Obtains proof that the manufacture
of the bulk drug substance took place in an establishment that meets all of the
following:

(
a
) Is duly
registered with the United States food and drug administration pursuant to 21
United States code section 360.

(
b
) Has
undergone an inspection by the United States food and drug administration as a
human drug establishment within the last two years.

(
c
) Is not
subject to an import alert by the United States food and drug administration.

8. Complies with the federal food,
drug, and cosmetic act.

B. It is unlawful for any
manufacturer or wholesaler to sell, transfer or distribute a bulk drug
substance in this state for use in compounding without providing to the
purchaser:

1. written verification that the bulk
drug substance is pharmaceutical grade and meets the sourcing requirements.

2. documentation of any quality
control testing and the valid certificate of analysis as required by subsection
A, PARAGRAPH 4 of this section.

C. Any person or entity engaging in
the sale, transfer or distribution of compounded drugs pursuant to subsection A
of this section shall maintain all records related to the acquisition,
examination and testing of the bulk drug substance for at least two years after
the expiration date of the last lot of drug containing the bulk drug substance
and, on request by the board, shall furnish the records to the board within one
business day after receiving the request or within a reasonable time as
determined by the board based on the circumstances of the request.

D. The board or the board's
authorized agent has the authority to inspect any person or entity that engages
in compounding drugs, as well any domestic supplier, wholesaler, repackager or
other provider of the bulk drug substance for compounding, for compliance with
the requirements prescribed in subsection A of this section.� Refusal to allow
the board or the board's authorized agent access to conduct an inspection
constitutes a violation of this section.

E. It is unlawful for any person to
advertise or otherwise promote compounded medications unless the advertisement
is truthful and not misleading. An advertisement is not truthful and
is misleading if it includes any unsubstantiated claim with respect to the
product. An advertisement is misleading unless it contains all of
the following:

1. A disclosure of the potential side
effects, adverse reactions, contraindications, precautions and warnings
associated with active ingredients in the medication, including any noted from
clinical trials, research and other appropriate information sources.

2. A summary of the specified risk
information in the labeling of the United States food and drug administration-approved
drug, if applicable, if the compounded drug contains an active ingredient that
is named as an active ingredient in a United States food and drug
administration-approved drug.

3. if applicable, A clear,
conspicuous statement that the product is a compounded medication, has not been
approved by the United States food and drug administration and has not been
evaluated by the United States food and drug administration for safety or
efficacy.

F. In addition to any other penalties
prescribed in this chapter, a person or entity that violates this section may
be subject to:

1. A civil penalty of $1,000 per dose
of the illegally compounded drug sold, transferred or distributed.

2. A suspension or revocation of the
licensee's or permittee's license or permit, as applicable.

G. The board shall adopt rules as
necessary to implement this section.

H. For the purposes of this section:

1. "Bulk drug substance":

(
a
) Means any
substance that is intended for incorporation into a finished drug product and
that is intended to furnish pharmacological activity or another direct effect
in the diagnosis, cure, mitigation, treatment or prevention of a disease, or to
affect the structure or any function of the body.

(
b
) Does not
include intermediates used in the synthesis of the substance.

2. "Person" means any
individual, partnership, firm, corporation or other legal entity.

3. "Unsubstantiated claim"
means any statement, representation or assertion concerning the safety,
efficacy or other attributes of a drug that is not supported by competent and
reliable scientific evidence.
END_STATUTE

Sec. 2.
Legislative findings

The legislature finds the following:

1. The safety and integrity
of compounded medications are paramount for the health and well-being of residents
of this state.

2. The United States food
and drug administration sets internationally recognized standards for drug
approval and regulatory oversight.� However, there have been increasing
attempts by unscrupulous actors to circumvent these regulations, undermining
public trust and patient safety.

3. Foreign entities,
including those from countries such as China, have exploited regulatory gaps to
introduce inferior or contaminated active pharmaceutical ingredients into the
supply chain for medications intended for compounding.

4. Recent cases, such as
those involving medications for weight loss, have demonstrated that high demand
can lead to the proliferation of use of illicit, substandard and potentially
harmful active pharmaceutical ingredients, also known as bulk drug substances,
jeopardizing patient health and safety.

5. While the United States
food and drug administration bears responsibility for enforcing federal laws to
protect citizens from misbranded and adulterated pharmaceutical ingredients,
enforcement has proven insufficient to curtail the influx of these substances.

6. Even after the United
States food and drug administration took some action to curb imports of active
pharmaceutical ingredients for weight loss medications from entities that are
not compliant with current good manufacturing practice requirements, patients
in this state remain at risk of receiving compounded medications containing
active pharmaceutical ingredients produced by entities that the United States
food and drug administration found to not be compliant with those requirements,
including active pharmaceutical ingredients imported into the United States
before the United States food and drug administration took action.

7. Therefore, it is
necessary for this state to take action to protect its residents by ensuring
that all active pharmaceutical ingredients used in compounding are sourced from
reputable, registered and inspected establishments, and that only pharmaceutical
grade, safe and pure ingredients are used in medications for weight loss.