RUO Compliance Audit Report
Point-in-time audit of the research-use-only business model against FTC advertising rules, Stripe restricted-business/peptide policy, and FDA intended-use concerns. Technical fixes are marked Resolved/Partially addressed; items needing legal, regulatory, or Stripe decisions are marked Flagged for review. This report does not constitute a determination of legal compliance or Stripe approval.
An exportable review package is available from the Applications tab ("Export Review Package"). It should be supplemented with: the actual product catalog (with real substance names), the researcher verification process and sample decisions, fulfillment and shipping procedures, and the customer-facing policies. Card payments must remain disabled until Stripe completes its own review.
QC-RTT did not identify its actual contents (retatrutide) anywhere in the catalog.
Location: Product "QC-RTT" (slug: qc-rtt) — name, short_description, description
Source: User directive; FDA intended-use / objective-intent principle (FDA RUO guidance).
Change: Renamed to "QC-RTT (Retatrutide)" and added explicit retatrutide identification to the description. Order records and emails now carry the transparent name.
Test: Re-read product record; name and description now identify retatrutide.
Remaining: None technical. Confirm physical vial label includes the generic substance name alongside the QC R3 brand — front-label mockups do not by themselves satisfy labeling requirements.
Tirzepatide, Tesamorelin, MOTS-c, NAD+, and Bacteriostatic Water already name their actual contents.
Location: Product records (slugs: tirzepatide, tesamorelin, mots-c, nad-plus, bacteriostatic-water)
Source: User directive.
Change: No change needed; verified transparent.
Test: Inspected DB descriptions — actual contents identified.
Remaining: None.
Payment processor descriptions (Wix checkout) use a generic "QC Labs Order {number}" line item and do not itemize actual products or contents.
Location: base44/functions/create-checkout/entry.ts — cart item name
Source: User directive: do not conceal identities in processor disclosures.
Change: No change made — card/Apple Pay is currently disabled ("Coming Soon").
Test: N/A (function not active in checkout flow).
Remaining: Before enabling card payments, itemize actual product names (including retatrutide) in the checkout session line items. Requires legal/Stripe review.
Scope & Limitations
- Technical completion is separate from legal compliance and from Stripe authorization.
- Off-site channels (social media, ads, chatbots, affiliate content) were not accessible and require manual review.
- Physical vial labeling must be reviewed by a qualified party; front-label mockups do not satisfy labeling requirements.
- RUO disclaimers and product renaming do not, by themselves, resolve FDA intended-use concerns if the overall sales context implies human use.
- This report is not legal advice. Consult qualified counsel for FDA, FTC, and Stripe matters.