Is Testosterone a Controlled Substance? Schedule III Rules
Testosterone controlled substance status is Schedule III under the Controlled Substances Act, so prescriptions expire after six months or five refills, and New York classifies it more strictly in Schedule II.
By Sunil Kumar, Managing Director - Sales · Updated 9 Oct 2026

Key takeaways
- Testosterone is a Schedule III controlled substance under federal law. Its entry is number (84) in 21 CFR 1308.13(f), and that listing is unchanged as of October 2026.
- A prescription ends at six months from its written date or after the fifth refill, whichever comes first. In our model, 90-day fills hit the date limit after three fills.
- New York lists testosterone in Schedule II, a stricter tier, so the federal refill arithmetic should not be assumed there.
- The FDA's June 2026 label changes did not reschedule testosterone. Rescheduling requires a final Drug Enforcement Administration (DEA) rule or an Act of Congress, and neither has happened as of October 2026.
In this article
- 1Is testosterone a controlled substance under federal law?
- 2How long does a testosterone prescription last under Schedule III rules?
- 3How do you make sure a testosterone refill never lapses?
- 4Does the Schedule III listing cover testosterone esters, gels and creams?
- 5Does state law change how testosterone is classified or refilled?
- 6Could testosterone be removed from Schedule III?
- 7What should a buyer settle before ordering testosterone API?
- 8Frequently asked questions
Testosterone prescribing is growing, which puts more people up against its legal status. State prescription drug monitoring data show 27% more people were treated with testosterone in 2022 than in 2018, according to a PLOS ONE study published in August 2024.
The schedule usually becomes visible at a pharmacy counter, when a refill is refused or a prescription has run out. The label "Schedule III" answers the search, but it does not tell you when your supply stops or who decides on an early refill. It also does not say whether the same rules apply to a gel, an ester (a chemically modified form of testosterone, such as cypionate or enanthate, used in injections), or a prescription written in New York.
This page gives the federal rule and a refill calendar we worked out for common fill sizes. It then explains where state law differs, what the Food and Drug Administration's (FDA) 2026 labeling changes did and did not change, and what bulk-ingredient buyers must settle before ordering testosterone active pharmaceutical ingredient (API) material.
Is testosterone a controlled substance under federal law?
Yes. Testosterone is a Schedule III controlled substance, entry (84) among the anabolic steroids in 21 CFR 1308.13(f) (title 21 of the Code of Federal Regulations). A Schedule III prescription cannot be filled or refilled more than six months after it was written, and cannot be refilled more than five times (21 CFR 1306.22). As of October 2026 the listing is unchanged.
Schedule III is the tier for drugs with an accepted medical use and a lower abuse potential than Schedules I and II, according to the DEA's schedules page. An anabolic steroid is any drug or hormonal substance chemically and pharmacologically related to testosterone, other than estrogens, progestins, corticosteroids and dehydroepiandrosterone (DHEA), under 21 CFR 1300.01.
Congress put anabolic steroids into Schedule III through the Anabolic Steroids Control Act of 1990, a law aimed at steroid misuse in sport. It amended the Controlled Substances Act. The schedule did not stop testosterone from being a medicine. The FDA approves testosterone products for men whose low testosterone is linked to a medical condition, and prescribers write for them under controlled-substance rules.
How long does a testosterone prescription last under Schedule III rules?
A Schedule III prescription ends six months after the date written or after the fifth refill, whichever comes first. That is one original fill plus five refills, six fills in all. The prescriber sets the number of refills, up to five, on the original prescription. Only a new prescription can continue treatment past either limit.
The size of each fill decides which limit you hit first. This is our own calculation from 21 CFR 1306.22, not an official figure. Assumptions: the prescription is written on January 1 of a non-leap year, so six months is 181 days. The prescriber authorizes five refills, and each fill is taken the day the previous supply ends. Real timing can be earlier or later depending on state law, pharmacy policy and your insurer.
| Supply per fill | Fills the refill count allows | Fills that fit inside six months | Fill days (day 0 = written date) | Days of therapy covered |
|---|---|---|---|---|
| 28 days | 6 | 6 | 0, 28, 56, 84, 112, 140 | 168 (6 × 28) |
| 30 days | 6 | 6 | 0, 30, 60, 90, 120, 150 | 180 (6 × 30) |
| 90 days | 6 | 3 | 0, 90, 180 | 270 (3 × 90) |
- 28-day fills: the refill count runs out first. Supply ends on day 168, about 13 days before the six-month date (day 181).
- 30-day fills: both limits arrive almost together. Supply ends on day 180, one day before the six-month date.
- 90-day fills: the date limit binds. The third fill falls on day 180, and a fourth would land on day 270, long after the prescription expired.
Our inference: larger fills cover more days per prescription, because the date limit, not the refill count, caps them. They are only possible if the prescriber writes that quantity and your state and insurer allow it.
How do you make sure a testosterone refill never lapses?
Run five checks, each with a clear pass or fail, about two weeks before your next fill is due. Fourteen days is our recommendation, not a legal threshold. It leaves time for a prescriber to review the request and send a new prescription.

- Find the written date.Pass: you can name it and add six months. Fail: you only know the date of your last pickup. The clock runs from the written date, not the pickup.
- Count the refills left.Pass: the label shows at least one. Fail: none remain, so you need a new prescription, not a refill.
- Compare your next due date with the six-month date.Pass: the due date falls on or before it. Fail: the due date falls after it. Ask the pharmacist for the exact last valid date.
- Check the margin on the refill count.Pass: the label shows two or more refills. Fail: one or none remain. Book the prescriber visit or labs now.
- Ask the pharmacy for the earliest fill date and which rule sets it.Pass: you get a date and a named rule (state law, pharmacy policy or your insurer). Fail: the date does not match your calculation. Recheck the written date and refill count on the label.
Federal law sets only the five-refill and six-month limits. It does not set an earliest refill date. A pharmacy that refuses an early refill is applying state law, its own policy or your insurer's rules, so ask which one applies.
Does the Schedule III listing cover testosterone esters, gels and creams?
Yes. The federal listing covers testosterone and, by definition, its esters, ethers, isomers and salts, so cypionate and enanthate are included. The entry names the substance, not a dosage form, so a gel or cream containing testosterone does not change the listing.
The definition in 21 CFR 1300.01 reaches those variants "whenever the existence of such isomers, esters, ethers, and salts is possible." It excludes estrogens, progestins, corticosteroids and DHEA. Prednisone and hydrocortisone, for example, belong to a different drug class and are not covered. Nothing in entry (84) separates injections from topical products. For how the esters differ once you are choosing one for a formulation, see our guide to which testosterone ester fits your formulation.
Does state law change how testosterone is classified or refilled?
Yes. New York lists testosterone in Schedule II, and California ties its schedule to the federal one. States, insurers and pharmacies can also add rules the federal text does not contain, so the federal calendar above is a starting point, not a guarantee.
- New York. New York Public Health Law §3306 lists anabolic steroids in Schedule II, subdivision (h), with testosterone as item (60). Schedule II is a stricter tier, so a New York prescription should not be assumed to follow the six-month, five-refill pattern. Ask the prescriber how yours works.
- California. AB 1778, approved August 24, 2026, ties California's classification to the federal one. If testosterone is rescheduled or exempted federally, California follows.
Could testosterone be removed from Schedule III?
Not yet. As of October 2026, 21 CFR 1308.13 still lists testosterone in Schedule III. An FDA expert panel on testosterone replacement therapy met on December 10, 2025, and trade reporting says it recommended removing the Schedule III designation. That recommendation is advisory. It is not FDA or DEA action and does not change the schedule.
In June 2026 the FDA requested that manufacturers update testosterone prescribing information, including removing the limitation of use for age-related low testosterone and revising prostate-related safety information. Those are labeling changes, not scheduling changes.
Rescheduling requires a final DEA rule or an Act of Congress, and neither has happened as of October 2026. Our expectation: if DEA moves, it will publish a proposed rule in the Federal Register and take comments before any final change. Until a final rule is published, plan around the Schedule III limits.
What should a buyer settle before ordering testosterone API?
A buyer needs to settle the exact product, the import authorization and the permitted end use before any commercial order. At Aarise Pharmaceuticals, in Haridwar, India, we supply bulk APIs and raw materials, including testosterone derivatives, to qualified business-to-business (B2B) buyers: generic drug manufacturers, contract formulators, distributors and importers. We do not sell to individual patients or consumers. For the wider supplier checks a US manufacturer should run, see our guide on how to qualify a hormone API supplier for US manufacturing.
Our quotation starts from these inputs:
- Product or CAS number. The Chemical Abstracts Service registry number identifies the exact ester.
- Quantity and destination country.
- Grade or purity and the documents you need. These can include a certificate of analysis (COA), specifications and a safety data sheet (SDS), where applicable.
- Payment terms and Incoterms. These are the international trade terms that set who handles shipping and risk.
We confirm price, minimum order quantity and lead time product by product in the quotation, and we do not publish a single price for the portfolio. We can support evaluation quantities for qualified buyers before you commit to bulk.
For a US importer, the federal import rules sit in 21 CFR Part 1312. Importers must be registered with DEA or exempt. Testosterone is a non-narcotic Schedule III substance, so it needs an import declaration, not a permit. Section 1312.18 requires DEA Form 236, filed no later than 15 calendar days before the anticipated customs release, and the filing is valid only after DEA issues a transaction identification number. A separate declaration is required for each shipment. Confirming local registration, import authorization and permitted end use is the buyer's responsibility before commercial supply. We review availability and documentation for your destination. Our recommendation is to confirm your registration status and filing timing with the DEA Diversion Control Division before you order.
To request a quotation, use the product inquiry option on our contact form, or write to sunil@aarisepharma.com or message +91 9899783330 on WhatsApp. Send the API name, CAS number, quantity and destination country.

Frequently asked questions
Yes. 21 U.S.C. § 844 makes it unlawful to knowingly possess a controlled substance not obtained from a practitioner or under a valid prescription. A first offense can bring up to one year in prison and a fine of at least $1,000. State penalties vary.
Sources
- 1.21 CFR 1308.13, Schedule III (Cornell LII)
- 2.21 CFR 1300.01, definition of "anabolic steroid" (Cornell LII)
- 3.21 CFR 1306.22, refilling of prescriptions (Cornell LII)
- 4.21 CFR 1312.11, requirement of authorization to import (Cornell LII)
- 5.21 CFR 1312.18, import declaration (Cornell LII)
- 6.21 U.S.C. § 844, penalties for simple possession (Cornell LII)
- 7.Controlled Substances Act, 21 U.S.C. chapter 13 (GovInfo)
- 8.DEA Diversion Control Division, drug schedules
- 9.DEA Diversion Control Division
- 10.FDA, testosterone information for patients and providers
- 11.FDA Expert Panel: Testosterone Replacement Therapy for Men, December 10, 2025
- 12.Healio, FDA panel on testosterone therapy, December 2025 (secondary report)
- 13.Selinger and Thallapureddy, cross-sectional analysis of national testosterone prescribing through prescription drug monitoring programs, 2018 to 2022, PLOS ONE, August 2024
- 14.New York Public Health Law §3306
- 15.California AB 1778, controlled substances: testosterone



