What China actually changed
China introduced a new pharmaceutical export inspection and certification framework on January 1, 2026. It covers manufacturing standards, export records and oversight of domestic storage and transport. Article 42 retains the special rules for anabolic agents and peptide hormones. Final Chinese regulation.
Hormone export controls were already established. A 2013 notice required an export permit before specified overseas contract manufacture of peptide hormones; the current regulator’s interpretation still cites that requirement. The restriction concerns that manufacturing arrangement, rather than all HGH production. Original notice, NMPA interpretation, section XI.
The stated goals were export quality, support for compliant pharmaceutical trade and closer alignment with international regulatory standards. Drafts appeared in 2024 and 2025. A separate revision to China’s broader drug regulations took effect on May 15, 2026; it was not an HGH-specific ban. Official explanation, May regulations.
Nor was growth hormone newly added to China’s doping catalogue: it appears at entry 130, page 9, in both 2025 and 2026. Changchun High-Tech’s August 21 filing also describes subsidiary GenSci’s HGH business and manufacturing operations in the first half of 2026. That contradicts the idea that China simply stopped making HGH. 2025 catalogue, 2026 catalogue, company filing, pages 10–11 and 16–17.
Why would gray-market vendors withdraw HGH?
More explicit oversight of manufacturing and domestic logistics could make undocumented supply harder or less attractive. That is a plausible explanation, not a confirmed finding about a particular vendor. The local inspection records we captured do not establish a nationwide HGH factory shutdown. Shanghai inspection plan, Baotou inspection report.
Public MESO discussions describe uneven disruption. On May 27, a member attributed some withdrawals to increased risk while reporting that another supplier intended to continue. On July 14, another member reported a restocking message and mixed replies from other sellers. These secondhand accounts show market concern, but cannot identify the legal trigger or measure the whole market. May discussion, July discussion.
To establish cause, we still need an attributable supplier notice, a carrier refusal naming the rule, or an enforcement case linked to the seller. Timing alone does not provide that link.
Which tracked vendors still list HGH?
QSC accounts for all 19 HGH offers in the selected September 11 snapshot of vendor listings tracked by TitrateLab. We track vendors’ inventory and pricing; these are their listings. The underlying stock observation is September 7 at 20:33 UTC. Capturing the records later does not refresh that stock check.
| Vendor | Observed | HGH evidence |
|---|---|---|
| QSC | Sep 7 | 19 selected vendor offers; all overseas dispatch |
| PPHK | Aug 24 | Two positive stock flags in a separate inventory view |
| ERP | Sep 11 | No HGH found in four checked public warehouse catalogs |
| UTHER | Sep 11 | Former product page removed; public HGH search empty |
QSC’s dispatch locations were Australia and the US (seven offers each), the EU and UK (two each), and Canada (one). Offers are strength/package/dispatch combinations, not physical stock counts. Overseas listings could reflect earlier inventory or later replenishment; they reveal neither shipment dates nor manufacturing origin. We have no documented explanation of QSC’s supply arrangements.
The older PPHK flags also prevent a broader claim that QSC is the only tracked vendor with any HGH availability signal. The selected inventory and pricing records cover only part of the market. ERP and UTHER checks cover their public listings, not every sales channel. ERP China, US A, US B, Canada, UTHER search.
What about COAs, purity and prices?
Our reviewed archive contains 101 historical HGH report groups across 26 vendor identities, including 20 attributed to QSC. QSC’s latest retained test is dated August 2, 2026. Across the full archive, only seven groups fall within June 14–September 11; six include numerical purity results.
Those reports have not been matched to currently offered batches. They cannot establish who now has the highest-purity HGH, and purity alone does not establish biological activity, sterility or endotoxin status.
Prices need the same date discipline. UTHER’s September 1 record listed ten 10-IU vials for $68, marked in stock. By September 11, the product page returned 404 and its public HGH search was empty. That is a historical price, not a current quote. Ambiguous package quantities elsewhere prevent a defensible per-IU ranking, and our snapshots do not establish a regulation-driven price trend. Former listing, catalog search.
Methods & original sources How we checked the records · 18 preserved documents
Scope and method
Evidence reviewed September 11, 2026. We preserved 18 original government and company files with URLs, retrieval times and integrity hashes; compared the 2025 and 2026 doping catalogue pages; and separated policy, company reporting and public forum accounts. Translations and reprints are not independent corroboration. One inaccessible GLP-1 Forum page and notices with unresolved supplier attribution were excluded.
The nonrandom full-length HGH archive contains 101 report groups across 26 vendor identities. Its 121 eligible result objects matched the September 9 extraction; we reused the source-checked exclusions of 18 duplicate rows and two unavailable-artifact rows. This was not a fresh authentication of every certificate. A report group is not necessarily a unique batch.
Inventory and price records were read without modification on September 11 at approximately 19:40–19:41 UTC. Stock dates below refer to source observations, not extraction time. The 119-row US-destination price baseline was unchanged from September 9 and cannot establish a marketwide price trend. The June 14–September 11 testing window is an editorial recency convention, not a product expiry period.
Vendor profiles identify evidence records, not present control of a website or representative. Laboratory reports do not authenticate contacts; the FBI documents business impersonation through search advertisements. No vendor contacts are reproduced here.
Rules and their development
- CFDA notice 226: overseas contract manufacture of peptide hormones — October 29, 2013; government reprint January 24, 2014.
- Order 9: anabolic-agent and peptide-hormone import/export administration — 2014, amended 2017.
- The preceding export-certificate framework — November 9, 2018; superseded.
- First export-manufacturing consultation draft — August 2024, original Word attachment.
- State Council reform policy, paragraph 21 — signed December 30, 2024.
- Second consultation notice and revised draft — February 8, 2025.
- Final export inspection and certification framework — effective January 1, 2026.
- NMPA interpretation in Chinese and English — November/December 2025 publications.
- State Council Order 828 and official explanation — January 2026 publications; effective May 15.
- Earlier online-drug sales rules — effective December 1, 2022.
Classification, enforcement and manufacturing
- 2025 doping catalogue and 2026 doping catalogue — GH appears at entry 130, page 9, in each.
- Shanghai inspection plan — March 11, 2026.
- Baotou's sports-event inspection report — April 27, 2026.
- Changchun High-Tech's 2026 semiannual report — exchange filing August 21, 2026; company-reported evidence.
TitrateLab Research Desk · reviewed September 11, 2026. AI-assisted documentary and archive analysis; no new laboratory testing. TitrateLab offers paid evidence products and order-routing services. The vendor listings analyzed here are selected using package, validation and commercial criteria. Inclusion is not a vendor endorsement. Methodology and corrections.