The 7-OH scheduling action, and the crisis behind it
A dated briefing for clinicians, administrators, journalists, and policymakers: what is proposed, what remains pending, and why an enforcement change requires a treatment bridge.
What 7-OH actually is
The word “kratom” now covers pharmacologically different exposures. That shorthand is convenient for marketing and unsafe for clinical reasoning. The four categories below should not be used interchangeably.
| Exposure | What it is | Why it matters |
|---|---|---|
| Botanical kratom leaf | Leaf or ground leaf from Mitragyna speciosa, a mixture of dozens of alkaloids usually dominated by mitragynine. | Whole-leaf exposure has a different alkaloid mixture and time course from concentrated 7-OH products. |
| Mitragynine | The principal alkaloid in botanical kratom and a metabolic precursor of 7-OH and other active metabolites. | It is not another name for 7-OH. |
| 7-hydroxymitragynine (7-OH) | A trace botanical alkaloid, an active mitragynine metabolite, and a directly sold enriched or semisynthetic opioid product. | Direct ingestion bypasses the low natural abundance and metabolic bottleneck of leaf exposure. |
| Semisynthetic analogues | Mitragynine pseudoindoxyl (MP), MGM-15, and MGM-16 are deliberately modified compounds related to the 7-OH scaffold. | They are not established routine human metabolites, and human pharmacokinetic and safety data are very limited or absent. |
Mitragynine’s conversion to 7-OH is established in preclinical work, while MP can form from 7-OH in pooled human plasma. Those findings do not define the amount formed, the half-life, or the clinical effect after direct high-dose product use.E16E18
MGM-15 has been documented in commercial tablets, but controlled human pharmacokinetic, metabolism, safety, and withdrawal studies are not available.E39
A purified 7-OH tablet does not reproduce every effect of botanical kratom. It removes much of the plant’s chemical context while increasing exposure to one opioid-active component. Ask about tablets, films, shots, gummies, pseudoindoxyl, MGM-15, and MGM-16—not simply “kratom.”
The semisynthetic retail market
A molecule can occur in a plant at trace concentration and still be manufactured, enriched, oxidised, or sold at exposure levels that traditional leaf use did not deliver. Commercial analyses have found high 7-OH content and alkaloid profiles inconsistent with authentic kratom leaf.E09
A 2026 quantitative analysis found substantial label disagreement, oxidation byproducts, and evidence of semisynthetic origin in more than 98% of the 7-OH-labelled products examined. This was a product sample, not a prevalence estimate for the whole market.E10
A six-month market survey identified 304 semisynthetic 7-OH and MP products, most marketed as 7-OH-only tablets, shots, or gummies. The survey describes an online market snapshot; it does not measure sales, users, or clinical incidence.E11
Label-content disagreement and undeclared active compounds have been documented. When clinical management or reporting depends on exposure, preserve the package and photograph both sides of the label; record the product name, lot, route, labelled amount, actual units used, and dosing interval.E09E10
What is proposed federally
On 6 July 2026, DEA published two Notices of Intent to temporarily place specified substances in Schedule I. A Notice of Intent is not the temporary scheduling order. Each notice says an order may be published on or after 5 August 2026 and, if published, takes effect on the date of Federal Register publication.E02E03E04
As of 8 August 2026, no final temporary scheduling order was located in the official DEA or Federal Register material reviewed. The federal action remains pending; this page does not describe the proposed federal controls as already in force.E03E04
| Notice | Material or substance | Proposed threshold |
|---|---|---|
| DEA-1570 | Mitragyna speciosa botanical material | More than 0.050% 7-OH by dry weight |
| DEA-1570 | Synthetic or further-processed articles, including extracts, concentrates, processed edibles, and pressed pills | More than 0.050% by the applicable weight or volume measure, or more than 1.00 mg 7-OH per article |
| DEA-1644 | MP, MGM-15, and MGM-16, including specified chemical forms | No concentration threshold |
The federal timeline
Dates below describe the official action located as of 8 August 2026. The order itself has not been located.
DEA withdrew its notice proposing temporary Schedule I placement of both mitragynine and 7-OH; neither compound was controlled by that withdrawn action.
FDA described concentrated 7-OH as a regulatory and public-health concern and supported action focused on enhanced products rather than ordinary botanical leaf.
The notices concern 7-OH above specified thresholds and, separately, MP, MGM-15, and MGM-16.
The published notices state that a temporary order may issue on or after 5 August 2026.
As of 8 August 2026, the official material reviewed still showed Notices of Intent rather than a published temporary scheduling order. If an order is published, it takes effect upon publication.
The notices describe a two-year temporary placement, with a possible one-year extension while permanent proceedings are pending.
State-level variation
Federal status is not the only legal question. States are using different mechanisms: controlled- substance schedules, food-and-drug enforcement, emergency rules, pending sales restrictions, and public-health advisories. This is a selected, date-stamped tracker—not a fifty-state legal survey.
| Jurisdiction | Current selected development | Important limitation |
|---|---|---|
| California | CDPH reports active food-and-drug enforcement against kratom- and 7-OH-containing products sold for consumption, including more than $5 million in seizures, and has reported six Los Angeles County deaths linked to 7-OH. | This is not a statement that every possession of kratom or trace 7-OH is a California Schedule I offence. |
| Connecticut | Mitragyna speciosa, including leaves, stems, extracts, and 7-OH, was designated Schedule I; guidance identifies 25 March 2026 as the effective enforcement date. | Check the current rule and penalties before legal reliance. |
| Florida | Emergency Rule 2ER26-1, announced 22 June 2026 and effective 1 July 2026, placed 7-OH and named related compounds — including MP, MGM-15 and MGM-16 — in state Schedule I, with stated concentration and ratio limits. | Emergency-rule duration, replacement, and current status require review. |
| Ohio | Rule 4729:9-1-01.1, effective 19 May 2026, classifies named mitragynine-related compounds including 7-OH and MP as Schedule I. | The rule excludes natural leaf and ground natural leaf. |
| New York | S8925A had passed both chambers but had not been shown as delivered to or signed by the governor on the official tracker reviewed. | It is inaccurate to call the bill effective until enacted and assigned an effective date. |
| Texas | The state issued a health advisory regarding serious illnesses associated with concentrated 7-OH. | The advisory is not itself statewide Schedule I control. |
The surveillance picture
U.S. Poison Centers reported 593 7-OH exposures in calendar year 2025 and 901 from 1 January through 30 June 2026. The average monthly number reported in 2026 was 102% higher than in the second half of 2025.E01
593 reports
Reported 7-OH exposures.
901 reports
Reported 7-OH exposures in the first six months.
38.8% serious
63.8% received healthcare-facility care; 20.5% were hospitalised.
Poison-centre reports are exposure reports, not prevalence estimates. They likely undercount use and cannot establish causation in every event because reporting, product verification, and coexposures are incomplete. They are nevertheless a rapidly growing safety signal.E01
Why a scheduling action becomes a clinical crisis
Scheduling can remove supply much faster than a dependent person can obtain addiction-medicine care. The predictable transition risks are abrupt withdrawal, stockpiling and erratic dosing, delayed disclosure, treatment bottlenecks, and substitution with counterfeit tablets, fentanyl, or borrowed prescriptions.E03E04
- Withdrawal without a pathway. Dependence may be hidden by the product’s retail presentation. Reported symptoms include anxiety, restlessness, sweating, chills, myalgias, gastrointestinal symptoms, insomnia, dysphoria, and craving. There is no validated universal 7-OH withdrawal clock.E25E28
- Capacity that does not exist. People may present to emergency, detoxification, primary-care, and addiction settings at the same time, including people who do not identify themselves as opioid users.
- Substitution into an illicit supply. Replacing a retail product with a counterfeit pill, fentanyl, or another street opioid is a foreseeable overdose risk. It is not a treatment plan.
The question is not whether 7-OH should be scheduled. It is whether treatment is ready on the day an order is published.
What a competent transition looks like
The response should use the least intensive setting that is safe: preserve residential and inpatient capacity for people who need it, while making timely medication treatment available in primary care, emergency departments, telehealth, and addiction practices. In a nine-patient retrospective series, both standard and low-dose clinician-directed buprenorphine initiations were used; eight patients initiated and stabilised. The small, uncontrolled series does not create a universal protocol.E26
- Identify and engage people before supply disruption. Add 7-OH and related product names to intake screening, and make rapid-access appointments visible.
- Make naloxone routine. Pair enforcement messaging with naloxone distribution and a clear message that respiratory depression and overdose need emergency response.
- Use clinician-directed treatment. Do not publish a fixed-hour self-initiation instruction. Direct high-dose 7-OH human pharmacokinetics are insufficient to define one; standard initiation is based on convincing clinical withdrawal, with low-dose approaches considered by a clinician when appropriate.E26E28
- Improve surveillance. Document the actual product and dosing pattern; routine opioid immunoassays often do not test for 7-OH.
- Speak to users, not only retailers. The public message should say that withdrawal is treatable, that street opioids are not a safe substitute, and where to obtain help.
Find the practical treatment and safety information
This page is educational and is not medical advice. It does not create a physician—patient relationship or provide legal advice. Anyone experiencing withdrawal from or toxicity due to kratom or 7-OH products should be evaluated by an addiction medicine professional; start with the buprenorphine prescriber finder.