Growth Hormone

What are the legal thresholds and import rules for peptides and GLP-1s in Germany, Austria and Switzerland?

Medically reviewed by Marko Maal · Sep 14, 2026

Reviewed by Marko Maal, MSc Pharmacy LinkedIn-verified

University of TartuPharmaceutical sciences — drug sourcing, formulation, regulatory reviewReviewed Sep 14, 2026

Reviewed for clinical and pharmacological accuracy by Marko Maal, MSc Pharmacy.

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The short answer

Germany publishes exact milligram thresholds above which possessing a doping substance becomes a crime. For most growth-hormone peptides those numbers are generous — 150 mg for secretagogues, 180 mg for GHRH analogues. For one category they are not. The threshold for growth hormone releasing peptides is 1.5 mg, a hundredth of the others, and a single research vial will usually exceed it.

That hundredfold gap sits inside one section of one annex, and it is the thing a German reader is least likely to know.

Evidence tier: Tier 1 — we obtained the full verbatim text of the Anti-Doping-Gesetz, its annex, the threshold regulation and the relevant Arzneimittelgesetz and SGB V provisions. Educational content, not medical or legal advice.

The key points:

  • GHRP threshold: 1.5 mg. GHS: 150 mg. GHRH: 180 mg. Somatropin: 16 mg.
  • Possession above threshold is criminal for anyone, not just athletes — up to 3 years.
  • BPC-157 is not in the German annex, despite being on the WADA list.
  • Postal import from outside the EU/EEA has no personal-use exception at any quantity.
  • Weight-loss GLP-1s are excluded from statutory insurance by statute, and courts keep upholding it.

The numbers that decide whether you have committed a crime

Evidence tier: 1 — statute and implementing regulation read in full.

German law works differently from the Nordic model. Where Denmark and Norway criminalise possession outright, Germany criminalises it above a published quantity, set substance by substance in the Dopingmittel-Mengen-Verordnung.

Substance category (AntiDopG Anlage)Threshold — *nicht geringe Menge*
GHRPs — GHRP-2 (pralmorelin), GHRP-6, hexarelin1.5 mg
GH secretagogues and mimetics — ipamorelin, MK-677, anamorelin, ghrelin, macimorelin, tabimorelin150 mg
GHRH and analogues — sermorelin, tesamorelin, mod-GRF, CJC-1295180 mg
Somatropin (human growth hormone)16 mg
GH fragments — AOD-9604, hGH 176-19116 mg
Testosterone (non-transdermal forms)632 mg
SARMs — ligandrol, ostarine, RAD-140, S-23, YK-11540 mg
Clenbuterol5.4 mg

Thresholds are per pure active substance, not per vial volume.

The GHRP line is the one to stop at. At 1.5 mg, a typical research presentation of GHRP-6 or hexarelin exceeds the threshold on its own — meaning a German user of those specific peptides is, on the face of the statute, in criminal-possession territory at essentially any quantity. Someone using ipamorelin or CJC-1295 has a hundredfold more headroom. Same annex section, same category of compound, completely different exposure.

The annex covers these peptides by category, not by name

Evidence tier: 1 — annex text read in full.

Section II.2.4 of the annex is headed "Wachstumshormon Releasingfaktoren" and sets out three sub-categories, each with named examples:

  • GHRH — "Zum Beispiel: Sermorelin, Somatorelin, Tesamorelin, mod-GRF, CJC-1295"
  • GH secretagogues and their mimetics — "Zum Beispiel: Anamorelin, Ipamorelin, Lenomorelin, synonym Ghrelin, Macimorelin, Ibutamoren, synonym MK-677, Nutrabol, Tabimorelin"
  • GHRPs — "Zum Beispiel: GHRP-2, synonym Pralmorelin, GHRP-2-Gly, GHRP-6, GHRP-6-Gly, Hexarelin"

Section II.2.3 covers growth hormone itself and its fragments. Section II.3 covers IGF-1, mechano growth factors and thymosin-beta-4 and its derivatives, naming TB-500.

Two features matter. The phrase "Zum Beispiel" means the named compounds are illustrative, not exhaustive — an unnamed peptide acting as a GHS, GHRH analogue or GHRP is caught by the category. And the annex closes by extending to "die verschiedenen Salze, Ester, Ether, Isomere, Mischungen von Isomeren, Komplexe oder Derivate".

BPC-157 is not in the German annex. We checked the full list. It is a WADA S0 substance but does not appear here — so it sits outside German criminal doping law while remaining an unauthorised medicine under the Arzneimittelgesetz. That is a real divergence, and it points the opposite way from Portugal, where BPC-157 is captured.

Possession is criminal for anyone, not just athletes

Evidence tier: 1 — § 4 read in full.

§ 4 Abs. 1 Nr. 3 makes acquiring, possessing or bringing in a listed substance above the threshold punishable by up to three years or a fine.

The detail that changes who this applies to: § 4 Abs. 7 does not reach Abs. 1 Nr. 3. The "elite athlete or person earning substantial income from sport" limitation applies only to the self-doping offences in Nr. 4, Nr. 5 and Abs. 2. Possession above the threshold is criminal for any person, including a recreational gym user with no competitive involvement.

Other tiers: attempt is punishable; negligent commission carries up to one year; and aggravated cases — endangering many people, exposing another to death or serious harm, or large-scale gain from gross self-interest — carry one to ten years. Objects can be confiscated under § 5.

There is one genuine ambiguity we are not going to smooth over. § 2 Abs. 3 requires the substance be held "zum Zwecke des Dopings beim Menschen im Sport" — for the purpose of doping in sport. Someone using GH peptides purely for cosmetic or anti-ageing reasons, outside organised sport, has an arguable defence on that subjective element. We found no case law resolving how German courts apply it to non-competitive users. The Arzneimittelgesetz offences apply regardless of purpose and are the more likely charge in that scenario.

Import: the postal route from outside the EU has no exception

Evidence tier: 1 — § 73 AMG read in full.

The baseline is that private importation is prohibited: § 73 Abs. 1 restricts bringing in authorised medicines to pharmaceutical entrepreneurs, wholesalers, pharmacies and hospitals. A private individual is none of those. Two exceptions carve out personal use.

Inside EU/EEAOutside EU/EEA
Hand-carried on entryPermitted — § 73 Abs. 2 Nr. 6, personal-need quantityPermitted — same provision
By post or ordered remotelyPermitted — § 73 Abs. 2 Nr. 6a, if lawfully marketable in the source country, no commercial intermediary, personal-need quantityNo exception exists. Nr. 6 requires the person to physically enter; Nr. 6a is confined to the EU/EEA

The widely-quoted "three months' supply" is real but weaker than people think. It is not in the statute. Customs describes it as the interpretation of the Länder health authorities, and North Rhine-Westphalia's health agency states the point bluntly: "Ein Rechtsanspruch auf diesen Dreimonatsbedarf besteht aber nicht" — there is no legal entitlement to it. The quantity is calculated against the package insert's dosing recommendation, which a research peptide does not have. With no insert, there is no figure to compute against, and the assessment falls to the officer.

A prescription does not help here. Neither exception mentions one; the criteria are quantity and, for the EU route, lawful marketability and absence of commercial intermediation. A German prescription does not authorise private importation of a product unauthorised in Germany. The route that does use a prescription is the Einzelimport under § 73 Abs. 3, where a pharmacy imports on a named patient's order.

One structural feature of Germany is regularly misread. Germany is unusual in the EU in permitting mail order of prescription medicines, including from pharmacies in recognised states — currently Iceland, the Netherlands, Sweden (prescription medicines only) and Czechia (non-prescription only). That channel requires a licensed pharmacy, a recognised state, a valid prescription, and a medicine authorised in Germany. Unapproved peptides fail the last limb no matter who ships them.

Enforcement reaches the buyer

Evidence tier: 1 — customs press release.

A 2025 Munich investigation gives the clearest picture of how this works in practice. Twelve accused, four arrested and remanded, 15,156 ampoules and 152,829 tablets of anabolic substances seized, on charges of commercial and gang-organised trafficking in doping agents and prescription medicines.

The line that matters for readers is further down: "Bei den weiteren Beschuldigten besteht der Verdacht, dass diese als Endabnehmer Dopingmittel erworben haben." End-buyers were themselves made suspects in the same investigation. Further parcels were intercepted at a postal service provider.

One caution on numbers. The only seizure statistics we could obtain are from a single regional customs investigation office — Dresden reported 144 cases in 2025, with 20,041 tablets and 8,941 ml of doping substances. That is one of eight offices, not a national total, and we are not going to extrapolate it.

Weight-loss GLP-1s are excluded by statute

Evidence tier: 1 — statute; case law via legal trade press.

Germany does not refuse GLP-1 reimbursement for obesity as a matter of assessment. It is excluded by primary legislation.

§ 34 Abs. 1 Satz 8 SGB V excludes medicines serving predominantly "zur Abmagerung oder zur Zügelung des Appetits, zur Regulierung des Körpergewichts" — for slimming, appetite suppression or body-weight regulation. Satz 7 sets the general rule for medicines whose use is primarily about improving quality of life.

Note what triggers the exclusion: the therapeutic purpose of the prescription, not the molecule. The same active substance is reimbursable within its approved type-2 diabetes indication and excluded when prescribed for weight loss.

The courts have repeatedly upheld this. In LSG Niedersachsen-Bremen, 28 April 2026 (L 16 KR 161/26 B ER), a 24-year-old with a hormone disorder and severe obesity was refused interim relief for tirzepatide; the court held the statutory rules are exhaustive, leaving no room for an individual-case assessment, and found no unconstitutional discrimination between self-payers and benefit recipients. Earlier decisions at Sozialgericht level reached the same result.

One correction worth making. Several commercial sites assert a Federal Social Court ruling that a BMI over 40 with severe comorbidities creates no entitlement. We could not locate any such case number and do not believe it exists. The confirmed authority is at regional and first-instance level, and all of it is interim relief rather than final merits judgments.

Austria and Switzerland

Evidence tier: 2 — verified in earlier research; less detail than Germany.

Switzerland is neither in the EU nor the EEA, which changes the regulatory route entirely: Swissmedic authorises independently rather than recognising EU centralised approvals, and every consignment crosses a customs frontier. Switzerland operates a personal-import allowance commonly described as one month's supply.

Austria regulates import under the Arzneiwareneinfuhrgesetz, with BASG/AGES as the medicines authority, and has an anti-doping regime comparable in structure to Germany's.

We are giving these two less space than Germany deliberately. Our verification on Austrian Grenzmengen and the Swiss implementing article under the Heilmittelgesetz is thinner than the German material above, and we would rather be visibly shorter than pad them out to look symmetrical.

What we could not verify

  • Thresholds for IGF-1, MGF and TB-500. They are in the annex; the threshold table section was not retrievable. TB-500 in particular is unresolved.
  • National customs seizure totals. Only one regional office's figures were obtainable.
  • The administrative sequence for an intercepted parcel — notification, destruction versus return, whether an administrative offence is opened.
  • Whether the G-BA has formally listed Wegovy or Mounjaro in Anlage II of the Arzneimittel-Richtlinie.
  • Case law on the "for the purpose of doping in sport" element as applied to non-competitive users. A real gap, not a formality.
  • Whether the July 2026 health savings package touches § 34 SGB V.
  • Currency of the four-country mail-order list, which rests on a 2011 notice.
  • Austrian threshold quantities and the Swiss implementing article.

Limitations

This is educational content. It is not legal advice, and it is not medical advice.

  • Thresholds are per pure active substance. Do not reason from vial volume or solution concentration.
  • We describe what the statute says, not what to do. Nothing here is guidance on obtaining unapproved medicines, and we name no vendors or routes.
  • The German annex is explicitly non-exhaustive — absence of a compound's name is not absence from the category.
  • Austria and Switzerland are covered more thinly than Germany, deliberately.
  • Marko Maal, MSc Pharmacy reviewed this article. Reviewer attribution does not constitute a doctor-patient relationship.

The bottom line

Germany is the most legible peptide jurisdiction in Europe, because it publishes the numbers. It is also, for one specific class of compound, among the harshest: 1.5 mg for GHRPs, against 150 mg for secretagogues and 180 mg for GHRH analogues. If you are in Germany and using GHRP-6 or hexarelin, that number is the single most important fact on this page, and the gap between it and the neighbouring categories is not intuitive from the pharmacology.

The second point is that possession here is not an athlete's offence. The elite-athlete limitation in § 4 Abs. 7 does not reach the possession provision, so a recreational user above the threshold is exposed in the same way as a competitor — and a 2025 Munich investigation shows end-buyers being made suspects rather than treated as bystanders.

And on reimbursement, Germany has settled the question at the level of primary legislation rather than case-by-case. Weight-loss prescribing is excluded by name in § 34 SGB V, courts have repeatedly declined to carve out exceptions, and the exclusion turns on the purpose of the prescription rather than the drug.

References

  • Anti-Doping-Gesetz, consolidated text including § 2 Abs. 3, § 4 and the Anlage (current annex per BGBl. 2023 I Nr. 67). Consolidated text
  • Dopingmittel-Mengen-Verordnung (DmMV 2023), Anlage — threshold quantities per pure active substance. Official text · Consolidated
  • Arzneimittelgesetz § 73, including Abs. 2 Nr. 6 and Nr. 6a and Abs. 3. Official text
  • Zoll guidance on import prohibitions and exceptions, including the three-month interpretation and the recognised mail-order states. Zoll
  • Landesamt NRW on the absence of a legal entitlement to the three-month quantity. LZG NRW
  • SGB V § 34, Abs. 1 Satz 7–9 — the lifestyle-medicines exclusion. Official text
  • LSG Niedersachsen-Bremen, 28 April 2026, L 16 KR 161/26 B ER — tirzepatide interim relief refused; statutory rules held exhaustive. Reported by LTO (legal trade press).
  • Zollfahndungsamt München / Staatsanwaltschaft München I, 2025 — nationwide arrests and searches; 15,156 ampoules and 152,829 tablets seized; end-buyers treated as suspects. Zoll press release
  • Zollfahndungsamt Dresden, Jahresbilanz 2025 — 144 cases; regional figures only. Release

Frequently asked questions

At what quantity does possessing a GH peptide become a crime in Germany?
It depends sharply on which class. The Dopingmittel-Mengen-Verordnung sets 1.5 mg for growth hormone releasing peptides such as GHRP-2, GHRP-6 and hexarelin; 150 mg for GH secretagogues including ipamorelin and MK-677; 180 mg for GHRH analogues including sermorelin, tesamorelin and CJC-1295; and 16 mg for somatropin itself. Thresholds are per pure active substance, not per vial volume. The GHRP figure is roughly a hundredth of the neighbouring categories, and a typical research vial will exceed it on its own.
Does German doping law only apply to athletes?
Not for possession. Section 4(1)(3) of the Anti-Doping-Gesetz punishes acquiring, possessing or importing a listed substance above the threshold with up to three years or a fine, and the elite-athlete limitation in section 4(7) applies only to the self-doping offences in 4(1)(4), 4(1)(5) and 4(2). A recreational gym user above the threshold is exposed in the same way as a competitor. One open question: section 2(3) requires a purpose of doping in sport, and we found no case law on how courts apply that to non-competitive users.
Can I have peptides posted to Germany?
From inside the EU or EEA, section 73(2)(6a) of the Arzneimittelgesetz permits it if the product may lawfully be marketed in the source country, there is no commercial intermediary, and the quantity matches ordinary personal need. From outside the EU or EEA there is no exception at all — the hand-carry exception requires the person to physically enter, and the postal exception is confined to the EU and EEA. A prescription does not change either position.
Is the German 'three months' supply' rule actually law?
No. It is an interpretation of the Länder health authorities, not a statutory figure, and North Rhine-Westphalia's health agency states there is no legal entitlement to it. The quantity is calculated against the package insert's dosing recommendation — which a research peptide does not have, so there is no figure to compute against and the assessment falls to the customs officer.
Is BPC-157 covered by German doping law?
No. We checked the full annex to the Anti-Doping-Gesetz and BPC-157 does not appear, despite being a WADA S0 substance. It therefore sits outside German criminal doping law while remaining an unauthorised medicinal product under the Arzneimittelgesetz, which is a real but different legal problem. This diverges from Portugal, where the prohibited list expressly names BPC-157 and the criminal provision has no quantity threshold at all.
Will German statutory insurance pay for a GLP-1 for weight loss?
No, and it is excluded by primary legislation rather than by assessment. Section 34(1) sentence 8 of SGB V excludes medicines serving predominantly for slimming, appetite suppression or body-weight regulation. The exclusion turns on the purpose of the prescription rather than the molecule, so the same drug is reimbursable within its approved type-2 diabetes indication. Courts have repeatedly refused to carve out exceptions, most recently the Landessozialgericht Niedersachsen-Bremen in April 2026.

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