The Record

On the docket.

A living scoreboard for the question this whole site is watching: whether legitimate melanocortin photoprotection reaches people faster than the gray market can sell the counterfeit. The dated catalysts ahead, the ones already settled, and where Melanotan II legally stands right now.

Last reviewed October 4, 2026. Analysis, not legal or medical advice. Dates are targets and can slip. For how these routes fit together, read The three doors.

On the calendar

Dated decisions and readouts still ahead, soonest first.

Nov 2026Clinuvel · CUV107

Pivotal vitiligo trial (CUV107) set to begin

The confirmatory study of around 300 patients, planned for the second half of 2026, meant to underpin regulatory filings across Europe, North America and Africa. Its design received final EMA scientific advice in April 2026.

Dec 2026Clinuvel · CUV105

Phase III vitiligo readout for afamelanotide

Topline from the 200-patient CUV105 trial of SCENESSE in vitiligo — the approved MC1R agonist reaching for its second indication. A positive result widens the beachhead.

~ Feb 2027FDA · PCAC

Advisory committee weighs Melanotan II for the compounding list

The FDA’s Pharmacy Compounding Advisory Committee is due to consider whether MT-II can move off the restricted Category 2 list and become compoundable. The first time its U.S. legitimacy is formally on a calendar — and the single most consequential date here.

~ end Feb 2027FDA · Tanabe

FDA decision on dersimelagon, the first oral MC1R agonist

The New Drug Application for dersimelagon (MT-7117) in EPP and X-linked protoporphyria has been accepted under priority review, with a decision expected around the end of February 2027. If approved, melanocortin photoprotection reaches patients as a once-daily pill for the first time — still for a rare disease, not a tan. Context in The pipeline right now.

Already settled

The milestones that shaped the picture above, most recent first.

17 Aug 2026TGA · Australia

Lab-tested nasal sprays: 22 mg to 54 mg in bottles labelled 30 mg

Five seized ‘Pure Tans Triple Strength’ bottles from the same NSW seller already fined $101,412 in May. The label was not a specification.

Jul 2026Health Canada

SCENESSE approved for EPP in Canada

Afamelanotide adds another country — the first systemic photoprotectant keeps spreading through the front door.

Apr 2026EMA · Clinuvel

EMA signs off on the pivotal vitiligo trial design

Final scientific advice from the European regulator on the CUV107 pivotal study — the step that turns a vitiligo programme into a filing path. Afamelanotide’s second indication now has a regulator’s fingerprints on its design.

27 Feb 2026HHS · FDA

Peptide reshuffle — Melanotan II stays restricted

HHS moved roughly 14 of 19 restricted peptides back toward the compoundable Category 1; Melanotan II was among the ~5 held back. The door stayed shut.

Feb 2026TGA · Australia

Australia reclassifies MT-II to Schedule 9 — the strictest in the world

Placed alongside heroin and LSD; possession without a research licence becomes a criminal offence. Triggered by 89 adverse-event reports (2022–25), including two melanoma cases within 18 months of use.

Jan 2026Tanabe · MT-7117

Oral MC1R agonist posts positive Phase 3

Dersimelagon — a once-daily pill, not an implant — met its primary endpoint in the 165-patient INSPIRE study in EPP and X-linked protoporphyria. Melanocortin photoprotection escaping the needle is the clearest sign yet the class is advancing; the FDA has since accepted the filing under priority review (see the calendar above).

1 Dec 2025UK · DHSC

Parliament told: nasal tanners sit outside medicines law

A written answer: injectables are unlicensed medicines; nasal sprays without medical claims are not regarded as medicinal products, so they are not in the MHRA’s remit. The gap, on the record.

23 Sep 2025EMA · EU

EMA approves year-round SCENESSE dosing

Europe widens the approved use of the first systemic photoprotectant.

Sep 2023FDA

MT-II placed in compounding Category 2

Designated a bulk substance that “may present significant safety risks” — which is what closed the compounding door in the first place.

8 Oct 2019FDA

FDA approves SCENESSE (afamelanotide) for EPP

The first melanocortin agonist approved in the U.S. for a photoprotective use. Proof the approval door opens.

22 Dec 2014European Commission

EU approves SCENESSE — the world’s first systemic photoprotectant

Afamelanotide authorised for EPP under exceptional circumstances; the class’s first market approval anywhere.

Where Melanotan II stands

The unapproved compound, jurisdiction by jurisdiction.

United States

Unapproved · not compoundable

No approved indication; Category 2, so licensed pharmacies can’t compound it; illegal to market for human use. The FDA has sent warning letters to distributors. Compounding status under review in 2027.

United Kingdom

Illegal to sell · legal to possess

An unlicensed medicine the MHRA bars from sale — it warned the public in 2008 and later helped suspend over 100 trading websites. Sold instead as a “cosmetic” nasal spray through a gap between the rulebooks that the DHSC confirmed to Parliament in Dec 2025. Selling is illegal; using is not.

Australia

Schedule 9 · prohibited

Since Feb 2026, the strictest classification there is — the same schedule as heroin and LSD. Possession without a research licence is a criminal offence. The toughest market in the world for MT-II.

EU & Nordics

Unapproved · banned as cosmetic

No approved indication anywhere in the EU; banned as a cosmetic in Denmark and others. Ireland’s HPRA warns it is not authorised to treat anything and ordered more than 500 online ads removed between 2020 and 2022. Country by country: The enforcement map.

The approved side

The counterweight to all that restriction: the legitimate melanocortin agonists that reached patients the right way — and the pipeline behind them.

Afamelanotide (SCENESSE)

MC1R agonist · subcutaneous implant

Approved for EPP in the EU (2014), U.S. (2019), Australia (2020), Israel, and Canada (2026). Now in Phase III for vitiligo, with a readout due Dec 2026.

Dersimelagon (MT-7117)

MC1R agonist · once-daily oral pill

Positive Phase 3 (INSPIRE) in EPP and X-linked protoporphyria (Jan 2026); New Drug Application accepted by the FDA under priority review, decision expected around the end of Feb 2027. The first oral entrant in the class — no needle, no implant.

The through-line: as the legitimate technology keeps advancing — approvals, new indications, an oral entrant — Melanotan II keeps getting walled off further. Those two trends are the whole story. For how a legitimate melanocortin sun drug actually reaches Americans, readThe three doors; for the gray market it competes with, The Barbie drug; for what the warnings actually did, a decade of enforcementand the enforcement map; for where the legitimate programs stand, the pipeline right now; for the full arc, the timeline.