"Food and drug manufacturers must reveal all chemical and mineral ingredients. Although they are not required to reveal trade secrets and the manner the ingredients are formulated, the base chemical compounds and any added mineral content must be released. Manufacturers are not required to list ingredients in all advertising, but labeling laws require that graphic packaging used to market products have all ingredients clearly listed."
Layman's view... Acthar is neither a chemical or a mineral. As for trade secrets, I have no idea. Thoughts?