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The MHRA position, summarised by Lynda Scammell (head of borderline products at the MHRA) and reported in The Guardian on 4 April 2026, is that products which are sold for human use or which carry medicinal claims fall inside the Human Medicines Regulations 2012, and that the MHRA is investigating UK clinics making such claims about unregulated peptide products

Annals of dermatology , 28 (4), 438.

Hairgenetix GHK-Cu Shampoo vs Ketoconazole Shampoos (Nizoral) Hairgenetix: Uses GHK-Cu copper peptides to stimulate follicle growth, promote angiogenesis, and provide anti-inflammatory protection

We next examined whether the vascular remodeling observed during the anagen growth phase was temporally associated with increases in the size of hair follicles and in the thickness of the overlying epidermis or of the dermis and subcutis