On April 9, 2025, the U.S. International Trade Commission issued a general exclusion order covering tirzepatide and terminated the investigation the same day. Coverage at the time centered on the companies Eli Lilly had named in its complaint. The order's more consequential feature drew less attention: unlike the other remedies issued alongside it, a general exclusion order attaches to goods rather than to parties.
What that means in practice depends entirely on which goods it covers, and that is the part most often summarized away. This page sets out the record, the order's scope as the Commission wrote it, and what tirzepatide pricing has looked like across our index in the months since.
What the Commission ordered
The investigation is No. 337-TA-1377, "Certain Products Containing Tirzepatide and Products Purporting To Contain Tirzepatide," on a complaint by Eli Lilly and Company. It was instituted on November 27, 2023, at 88 FR 82914, not in 2024 as several accounts of it state.
The Commission announced its remedy on April 9, 2025 and terminated the investigation the same day. Three separate orders issued:
- A general exclusion order barring entry of covered tirzepatide products, regardless of who imports them.
- A limited exclusion order reaching covered products imported by or for three defaulting respondents: Super Human Store, AustroPeptide and Arctic Peptides.
- Cease and desist orders directed to exactly three companies: Arctic Peptides, Triggered Brand and Strate Labs.
Covered goods could enter under a bond of 100 percent of entered value during the Presidential review period that follows any section 337 remedy.
Why the general order is the part that matters
A limited exclusion order reaches goods imported by or for named respondents. A general exclusion order attaches to the goods themselves, so its reach does not depend on which companies appeared in the docket. Section 337 permits one only on specific statutory findings, which the Commission made here.
That is why the roster of respondents is the least informative part of the record. Of the eleven companies originally named, three were terminated from the case in March 2024, eight were found in default in May 2024, and Strate Labs has since closed. The order's scope is unchanged by any of it.
What "covered" means, and does not
The order does not exclude tirzepatide. It excludes products containing or purporting to contain tirzepatide that infringe U.S. Trademark No. 6,809,369 or include a false designation of origin.
Lilly's complaint alleged false designation of source, false and misleading advertising, and trademark infringement. It was not a patent case about the molecule, and the Commission's remedy tracks the case it was given. The question the order asks is how a product is marked and how it is advertised, not what the vial contains.
That distinction is the part that gets lost when the decision is summarized as an import ban.
What the price record shows
Every figure here is drawn from our own index and is current as of August 5, 2026. Methodology is on /methodology.
- All 24 vendors we index list tirzepatide, across 94 in-stock listings.
- The median listing is $3.60 per milligram, against a $4.50 median across every compound we index.
- Listings run from $0.87 to $11.00 per milligram, a 12.7-fold gap that is the second widest among the 47 compounds five or more vendors carry, where the median gap is 4.0-fold.
Holding the comparison to the 46 listings priced on both May 1 and August 5, 2026, the median moved from $3.71 to $3.67 per milligram, and 31 of those 46 did not change price at all. Our price archive does not reach back to April 2025, so this says nothing about what the order did on issuance. It does say that over the three months we can measure, this is not a market under visible supply pressure.
Where enforcement has landed since
The enforcement actions that followed the order came from state consumer-protection law rather than from the border.
- Connecticut's attorney general sued Triggered Brand, a cease and desist recipient in the ITC case, on May 21, 2025, alleging violations of the state's Unfair Trade Practices Act and sale of prescription drugs without a pharmacy license.
- That suit settled on August 5, 2025: the company and its chief executive agreed to stop selling the products, paid $18,500, and face a $300,000 judgment suspended on compliance.
- On May 6, 2026, the same office announced a settlement with the trade platform Made-in-China, which agreed to bar manufacturers from advertising or selling GLP-1 products to United States customers and to run a monitoring system that removes such listings, under a $300,000 penalty with $270,000 suspended.
In both matters the state's theory turned on marketing prescription-only drugs to consumers for human use, without a prescription or a pharmacy license.
What a price listing does not tell you
The order turns on trademark and designation of origin, which are questions about how a product is labeled and advertised. Price and availability data speaks to neither, and this page draws no inference from one to the other.
One naming caution, because the record invites it: Strate Labs, a respondent here, is a different company from Slate Research, whose domain went offline in June 2026. The names are one letter apart and are routinely conflated.
Sources
- Federal Register, 90 FR 15720 (April 15, 2025), notice of issuance of the general exclusion order, limited exclusion order and cease and desist orders.
- Federal Register, 88 FR 82914 (November 27, 2023), notice of institution of Investigation No. 337-TA-1377.
- Federal Register, 90 FR 8299 (January 28, 2025), determination not to review the initial determination finding a violation.
- Connecticut Attorney General, May 2025, suit against Triggered Brand.
- Connecticut Attorney General, August 5, 2025, settlement terms.
- Connecticut Attorney General, May 6, 2026, agreement with Made-in-China.
Price figures are from the PeptideScouter index as of August 5, 2026, covering 24 vendors.