WADA publishes 2025 prohibited list

Yesterday (25 September 2024), the World Anti-Doping Agency (“WADA”) released its revised 2025 edition of its List of Prohibited Substances and Methods. This blog sets out what the key changes are, and what steps those bound by the WADA Code can take to avoid breaches and/or sanctions.

The list can be read in full here: 2025 List of Prohibited Substances and Methods, and should be treated as compulsory reading anyone operating in the sports sector, whether as athletes, coaching staff, or as medical support. Importantly, athletes and their teams should take steps to review and (where necessary) amend their protocols and practices to ensure compliance before the revised list enters into force on 1 January 2025.

To assist athletes and the teams in adapting their protocols and practices, WADA has also published an Explanatory Note to be read in conjunction with the list (2025 Summary of Major Modifications and Explanatory Notes), which outlines the major changes and revisions when compared to the 2024 list currently in force, and its 2025 Monitoring Programme (2025 Monitoring Program), which indicates whether or not non-specified substances may be permitted in the context of Out-of-Competition use.

The List and Explanatory Notes should be read in full, but in brief we set out a few of the more broadly significant changes to the list below:

1.     Donation of blood by athletes is no longer prohibited, provided that the procedure is performed by an accredited collection centre. However, the administration or reintroduction of blood into the Athlete’s system remains prohibited.

2.     The stimulant Hydrafinil (also known as Fluorenol) has been elevated to the S6.A list of non-specified stimulants. This means that WADA considers that the most likely use of Hydrafinil is for the purpose of athlete performance enhancement as opposed to any other reason.

3.     The stimulant Guanfacine is confirmed to not be a prohibited substance.

The 2025 changes build on the changes to the 2024 Prohibited List which notably prohibited in-competition use of the opioid Tramadol and provided greater clarity on the prohibition of testosterone-stimulating peptides and growth hormone secretagogues.

As recent cases, such as the suspension and subsequent reinstation of the ATP Men’s Tennis Number 1, Jannik Sinner[1], have shown, international sporting bodies remain firmly focussed on preserving sporting integrity and taking action where necessary.

This means that even innocent, inadvertent or accidental use and/or presence of WADA prohibited substances in an athlete’s system (such as in the case of Mr Sinner) can expose them to the unwanted stress and scrutiny of appeals processes, and can render athletes ineligible for key events while investigations and appeals are dealt with.

It is worth noting that the presence of a prohibited substance in an athlete’s system is a strict liability offence. This means that, in any proceedings brought against an athlete by a sports governing body or national/international anti-doping organisation, the burden will be on the athlete to establish the origin of the substance and show that they bore no fault or negligence for the breach. This is a high bar and the best course of action for an athlete and their team is one of proactivity and caution.   This means being aware of revisions to the list and taking appropriate steps to alter protocols and procedures to avoid breach. Education to athletes by stakeholders and sports’ governing bodies remains key.

Where an athlete has a legitimate medical reason that requires the use of a prohibited substance or method, the athlete should apply for a Therapeutic Use Exemption in advance of competing to avoid being subjected to sanctions. Such Exemptions are beyond the scope of this article, but more information on whether you or your athlete qualifies for a Therapeutic Use Exemption can be found in the following WADA guidance document: International Standard for Therapeutic Use Exemptions.

If you, or an athlete you represent, would like to discuss the impact of the 2025 list and what it means in terms of their training programme and protocols, or if you would like to discuss how to seek a Therapeutic Use Exemption, please contact Carol Couse, Mark Hovell, Phil Hutchinson or another member of the Mills & Reeve Sport team.