Sourcing Exosomes in North Carolina
Licensed North Carolina practices order Kimera exosome material from ExaVeyra for topical aesthetic use, shipped frozen from Florida with lot traceability on every vial and a certificate of analysis issued for every lot and provided on request. North Carolina buyers need their own professional license and NPI; the out-of-state pharmacy registration and the wholesale distributor license the state issues sit with the entity that ships into the state rather than with the purchasing practice.
Two North Carolina points are worth settling early. Part 2 of the Right to Try Act restricts the sale and transfer of adult stem cells for investigational treatment and makes a violation a criminal offense, and it defines the term around cells that renew and differentiate. And the two licenses a supplier needs come from two different agencies, one of them the Commissioner of Agriculture rather than the pharmacy board.
At a glance
| Question | Answer |
|---|---|
| Does ExaVeyra ship to North Carolina? | Yes. Shipped frozen from Florida, as we do to all 50 states |
| Cold-chain shipping from Florida | Overnight shipping; arrival can take 1 to 3 business days |
| State regenerative-medicine statute | HB 934 (2019) |
| Does that statute reach exosomes? | No. Its definition is written around cells; exosomes are acellular and governed federally |
| Physician delegation required to hand off medical acts | Yes |
| Who holds the licensure to ship into the state | The pharmacy partner and the tissue bank that ship, not the purchasing practice |
| What ExaVeyra supplies here | Kimera exosome material. Compounded preparations are not available in this state at this time |
| Last reviewed | 11 September 2026 |
Ordering from North Carolina
ExaVeyra ships to licensed practices in all 50 states, North Carolina included. Licensure for shipping into the state is held by the entities that ship: our 503A pharmacy partner holds nonresident pharmacy licenses in 33 jurisdictions, including Puerto Rico, and exosome material ships from a registered tissue bank licensed to ship to all 50 states and Puerto Rico. Your practice orders against its own professional license and NPI and needs no wholesale permit to purchase. What changes state to state is how the state regulates who performs a procedure and how the practice itself is owned, while federal law governs the product itself.
What your practice provides
- An active North Carolina professional license in good standing, verifiable through the licensing board for the profession.
- A valid NPI, which ExaVeyra verifies at account setup.
- A signed professional-use acknowledgment on file for exosome material.
- A North Carolina Certificate of Exemption, Form E-595E, if the practice is purchasing for resale rather than for use in its own operations.
How the state permits wholesale distribution
North Carolina splits supplier licensing across two agencies, and both licenses sit with the supplier rather than with the purchasing practice. Under G.S. 90-85.21A any pharmacy operating outside the state that ships, mails or delivers a dispensed legend drug into North Carolina must register annually with the Board of Pharmacy. The registration is not a formality: the pharmacy certifies that it employs a pharmacist responsible for dispensing into the state who meets licensure requirements equivalent to North Carolina’s, and that pharmacist must agree in writing to submit to the jurisdiction of the Board. If the Board revokes that certification the pharmacy loses its authority to ship into the state at all. The statute also bars any out-of-state pharmacy from shipping a dispensed legend drug into North Carolina unless the drug was lawfully dispensed by a licensed pharmacist in the state where the pharmacy sits, and lets the Board refuse a registration where the pharmacy has been formally disciplined at home over compounding or dispensing. Separately, under G.S. 106-145.3 every wholesale distributor engaged in the wholesale distribution of prescription drugs in interstate commerce in the state must hold a license from the Commissioner for each location it distributes from, renewed annually, and G.S. 106-140.1 provides a registration route for a distributor with no North Carolina facilities that holds a license from a state with substantially equivalent requirements.
G.S. 90-85.21A; G.S. 106-145.3; G.S. 106-140.1 · North Carolina Board of Pharmacy
North Carolina regenerative-medicine law
North Carolina enacted HB 934, codified at G.S. 90-325.15 through 90-325.22, effective 1 July 2019.
Session Law 2019-70 added Part 2 to the Right to Try Act, codified at G.S. 90-325.15 through 90-325.22. Its stated purpose is to authorize access to investigational adult stem cell treatment for patients with a severe chronic disease or terminal illness, to regulate the possession, use and transfer of adult stem cells, and to create a criminal offense for the purchase and sale of adult stem cells for certain investigational treatments. Access is tightly conditioned: under G.S. 90-325.17 the treatment must be administered directly by a physician certified by an institutional review board, overseen by that board, and provided at an accredited medical school in the state, an affiliated facility, or another facility the board approves. G.S. 90-325.19 then makes it unlawful to knowingly offer to buy, offer to sell, acquire, receive, sell or otherwise transfer adult stem cells for valuable consideration for use in an investigational adult stem cell treatment, subject to exceptions that include fees paid to a provider for services rendered in the usual course of medical practice and conduct by a provider, researcher or biosciences professional engaged in review-board-approved or otherwise legal research, clinical trials or investigational treatment. A violation is a Class A1 misdemeanor.
- Authorizes eligible patients to access investigational adult stem cell treatment
- Treatment administered by a physician certified by an institutional review board
- Treatment provided at an accredited North Carolina medical school, an affiliated facility, or a facility the review board approves
- Written informed consent signed before treatment, with contents the statute specifies
- Purchase or sale of adult stem cells for investigational treatment is a Class A1 misdemeanor
“an undifferentiated cell that is (i) found in postnatal differentiated tissue and (ii) able to renew itself and differentiate to yield all or nearly all of the specialized cell types of the tissue from which the cell originated”
How this applies to exosomes
This is the one statute in this series that reaches buying and selling, so a supplier and a purchasing practice both need to read what it covers rather than assume. Two limits sit in the statute’s own text. First, the definition: G.S. 90-325.16(1) defines an adult stem cell as an undifferentiated cell found in postnatal differentiated tissue that is able to renew itself and differentiate to yield the specialized cell types of the tissue it came from. Exosomes are acellular extracellular vesicles. They are not cells, they do not renew themselves and they do not differentiate, so they do not meet that definition on its plain terms. Second, the scope: the prohibition in G.S. 90-325.19 applies to adult stem cells transferred for use in an investigational adult stem cell treatment, which G.S. 90-325.16(4) defines as treatment under investigation in a clinical trial and not yet approved by the FDA. Neither point is a legal opinion and neither makes any transaction lawful. Exosome products remain governed by federal law, under which no exosome product has been approved by the FDA for administration to humans. Whether Part 2 reaches a particular purchase, and what a practice must do about it, is a question for that practice and its North Carolina counsel. ExaVeyra supplies Kimera material for topical aesthetic use by licensed practitioners, with lot documentation and a certificate of analysis for every lot.
Who can handle product in a North Carolina practice
North Carolina runs everything through a registered relationship with a physician. A physician assistant has a primary supervising physician and a signed supervisory arrangement on file at each site; a nurse practitioner has a registered primary supervising physician and a collaborative practice agreement approved through both boards; a registered nurse acts on an order and, for cosmetic and aesthetic dermatological procedures, with on-site supervision under the Board of Nursing’s position statement. There is no route in this state by which a non-physician reaches a medical act on their own license alone. Confirm your own protocols with North Carolina counsel.
| Role | Scope under state law |
|---|---|
| MD / DO | Physicians licensed by the North Carolina Medical Board perform medical acts within their scope and are the source of both routes by which a non-physician reaches one. A physician registers with the Board as a primary supervising physician for a physician assistant, and a physician enters the collaborative practice agreement a nurse practitioner must hold. Under Part 2 of the Right to Try Act, an investigational adult stem cell treatment may be administered only by a physician certified by an institutional review board, at a facility the statute or the board allows. |
| NP / APRN | Nurse practitioners do not practice independently in North Carolina. Under 21 NCAC 32M .0110 an NP registers a primary supervising physician and holds a mutually agreed collaborative practice agreement with a physician licensed by the North Carolina Medical Board. The approval is joint: nurse practitioner practice is overseen by the Medical Board and the Board of Nursing together, which is why an NP-led aesthetic practice in this state is a different proposition from one in a full practice authority state. |
| PA | Physician assistants practice under an individualised supervisory arrangement with a primary supervising physician under 21 NCAC 32S .0213. The arrangement is a written statement describing the medical acts, tasks and functions delegated, including prescriptive authority instructions, appropriate to the physician assistant’s qualification, training, skill and competence. Both parties sign and date it, it is kept on file at every practice site, and it is produced to the Board on request. The primary supervising physician is responsible for ensuring the scope is clearly identified and that what is delegated is appropriate to the competencies of both. |
| RN | Registered nurses work within the Board of Nursing’s scope rules and to an order from an authorized practitioner. The Board’s position statement on cosmetic and aesthetic dermatological procedures, published in February 2024, adds a supervision condition for this setting: to perform prescribed or ordered cosmetic and aesthetic dermatological procedures, there must be on-site presence and supervision by an appropriately qualified practitioner. Confirm the current text of that position statement with the Board before building a protocol on it. |
Good faith examination
North Carolina does not use the phrase “good faith examination” as a statutory term. The functional requirement follows from the supervision rules: the delegated task must be named in the physician assistant’s supervisory arrangement or fall within the nurse practitioner’s collaborative practice agreement, and a registered nurse acts on an order from a practitioner authorized to give it. Confirm current expectations with the North Carolina Medical Board and the Board of Nursing.
Ownership and clinic licensing
North Carolina is a strict corporate practice state and the Medical Board polices the structure directly. A business practicing medicine must be owned in its entirety by holders of active North Carolina licenses, and shares in a professional corporation may be held only by a licensee qualified to render the same professional services the corporation renders. G.S. 55B-14(c) permits certain combinations, and physician assistants and nurse practitioners may hold stock alongside physicians in defined circumstances. The arrangement the Board names and warns about is straw ownership, where a licensed physician is made the shareholder on paper while real control and decision-making sit with a non-physician; the Board treats the physician in that position as aiding and abetting the unlicensed practice of medicine and subject to discipline. The Board recognizes exceptions for hospitals and health maintenance organizations. Structure the entity with North Carolina counsel before opening.
Cold chain into North Carolina
Shipments leave Florida frozen under validated temperature monitoring. A package in transit over a weekend waits in the carrier network, so practices in North Carolina order around weekend and holiday closures.
| Metro | County | Notes |
|---|---|---|
| Charlotte | Mecklenburg | Largest concentration of aesthetic, dermatology and concierge practices in the state. |
| Raleigh | Wake | Capital market anchored by a dense professional population. |
| Durham and Chapel Hill | Durham and Orange | Research Triangle corridor with academic and research-adjacent practices. |
| Greensboro and Winston-Salem | Guilford and Forsyth | Triad market with a broad clinical mix. |
| Asheville | Buncombe | Western North Carolina market with a longevity and concierge concentration. |
| Wilmington | New Hanover | Coastal market with seasonal aesthetic demand and a year-round core. |
- North Carolina orders of fifteen or more cold-chain units ship free nationwide; see the volume program for current thresholds.
Practice types we supply in North Carolina
North Carolina licensing and verification
North Carolina Medical Board
Licenses physicians and physician assistants and registers supervising physicians.
North Carolina Board of Nursing
Licenses RNs and NPs, and publishes the position statement on cosmetic and aesthetic dermatological procedures.
North Carolina Board of Pharmacy
Registers the out-of-state pharmacy shipping dispensed legend drugs into the state.
NC Department of Agriculture and Consumer Services, Food and Drug Protection Division
The Commissioner licenses wholesale prescription drug distributors under G.S. 106-145.3.
North Carolina Department of Health and Human Services
State health agency. Facility licensure sits here rather than with the Medical Board.
North Carolina sourcing questions
- Does North Carolina’s adult stem cell law cover exosomes?
- The statute defines an adult stem cell at G.S. 90-325.16(1) as an undifferentiated cell found in postnatal differentiated tissue that can renew itself and differentiate into the specialized cell types of its tissue of origin. Exosomes are acellular extracellular vesicles, so they are not cells, do not self-renew and do not differentiate, and do not meet that definition on its plain terms. The prohibition in G.S. 90-325.19 is also scoped to adult stem cells transferred for use in an investigational adult stem cell treatment, a term the statute ties to a clinical trial. That is what the text says, not advice that any given transaction is lawful. Settle the question for your own purchasing with North Carolina counsel.
- Is it a crime to buy stem cell products in North Carolina?
- G.S. 90-325.19 makes it unlawful to knowingly offer to buy, offer to sell, acquire, receive, sell or otherwise transfer adult stem cells for valuable consideration for use in an investigational adult stem cell treatment, and a violation is a Class A1 misdemeanor. The statute carries exceptions, including fees paid to a health care provider for services rendered in the usual course of medical practice, and conduct by a health care provider, medical researcher or biosciences professional engaged in research, clinical trials or investigational treatment approved by a qualifying institutional review board or otherwise legal. Read the section with counsel before purchasing anything that could fall inside it.
- Does my North Carolina clinic need a pharmacy or distributor license to buy exosomes?
- No. Both sit with the out-of-state supplier and they come from two different agencies: the Board of Pharmacy registers the shipping pharmacy under G.S. 90-85.21A, and the Commissioner licenses the wholesale distributor under G.S. 106-145.3. Your practice orders against its own professional license and NPI, and ExaVeyra confirms destination licensure across its supply chain before a first order ships.
- Can my North Carolina practice source 503A compounded peptides through ExaVeyra?
- Not at this time. Compounded formulations are prepared by our 503A pharmacy partner, a compounding pharmacy licensed by the Texas State Board of Pharmacy, and its North Carolina registration is pending, so it is not currently licensed to dispense compounded preparations into the state. North Carolina requires any pharmacy operating outside the state to register with the Board of Pharmacy under G.S. 90-85.21A before shipping a dispensed legend drug in. What ExaVeyra supplies to North Carolina practices is Kimera exosome material. Submit an inquiry and we will set out the sourcing options currently open to a North Carolina practice.
- Can a nurse practitioner run an aesthetic practice in North Carolina?
- Not independently. Under 21 NCAC 32M .0110 a nurse practitioner registers a primary supervising physician and holds a collaborative practice agreement with a physician licensed by the North Carolina Medical Board, and nurse practitioner practice is approved through the Medical Board and the Board of Nursing together. Ownership is a separate and stricter question: a business practicing medicine must be owned entirely by North Carolina licensees, and the Medical Board treats straw ownership by a physician fronting for a non-physician as aiding the unlicensed practice of medicine.
- Who in a North Carolina practice can handle exosome material?
- Every route runs through a physician. A physician assistant acts under a written supervisory arrangement with a registered primary supervising physician under 21 NCAC 32S .0213, signed by both and kept at each practice site. A nurse practitioner acts under a collaborative practice agreement and a registered supervising physician. A registered nurse acts on an order, and the Board of Nursing’s February 2024 position statement adds on-site supervision for cosmetic and aesthetic dermatological procedures. Confirm your own protocols with North Carolina counsel.
- How should exosome material be handled on arrival?
- Check the temperature indicator included with the shipment before the vials go into storage, and move them to their storage condition promptly. If the indicator reads outside range, contact us before use rather than storing the shipment. Storage and handling conditions follow the manufacturer's handling instructions, which ship with each order, and every vial carries its lot number.
Sources
Last reviewed 11 September 2026 by ExaVeyra Sciences editorial team. Every claim above links to a primary source.
- G.S. Chapter 90, Article 23A, Right to Try Act (Part 2, investigational adult stem cell treatments) (accessed 11 September 2026)
- Session Law 2019-70, House Bill 934 (accessed 11 September 2026)
- G.S. 90-85.21A, applicability to out-of-state pharmacy operations (accessed 11 September 2026)
- G.S. 106-145.3, wholesale distributor must have license (accessed 11 September 2026)
- G.S. 106-140.1, registration of out-of-state wholesale distributors (accessed 11 September 2026)
- 21 NCAC 32M, approval of nurse practitioners (accessed 11 September 2026)
- 21 NCAC 32S .0213, physician assistant supervisory arrangement (accessed 11 September 2026)
- NC Board of Nursing, cosmetic and aesthetic dermatological procedures position statement (February 2024) (accessed 11 September 2026)
- NC Medical Board position statement 10.1.2, corporate practice of medicine (accessed 11 September 2026)
- NC Board of Pharmacy, pharmacy permits (accessed 11 September 2026)
- FDA Public Safety Notification on Exosome Products (accessed 11 September 2026)
These statements have not been evaluated by the FDA. This product is not intended to diagnose, treat, cure, or prevent any disease. There are no FDA-approved exosome products. Biomolecular signaling vesicle products distributed by ExaVeyra Sciences are supplied for topical aesthetic use by licensed practitioners and for laboratory and IND-authorized clinical research, and are not tissue products as defined by FDA guidelines.