The DEA 7-OH threshold, explained for extract buyers
DEA's October 14, 2026 notice proposes temporary Schedule I control of 7-hydroxymitragynine (7-OH) and mitragynine pseudoindoxyl (MP) when either exceeds 1 mg per gram of product, or when the ratio of mitragynine to 7-OH plus MP falls below 100. Concentrated MIT extracts must be tested for both on every lot.
What the notice says
On October 14, 2026, DEA withdrew its July notice on 7-OH and published a new notice of intent (FR Doc 2026-20943, Docket DEA-1570). It would temporarily place 7-OH and MP in Schedule I when they are present above a threshold, instead of scheduling all 7-OH regardless of amount.
A temporary scheduling order can be issued no earlier than 30 days after publication, so mid-November 2026 at the earliest. Mitragynine and kratom leaf themselves are not scheduled by the notice.
The two tests
A product that fails either test would fall under the temporary order. Both values must therefore appear on the certificate of analysis.
| Test | Threshold | Applies to |
|---|---|---|
| Concentration | More than 1 mg/g (solids) or 1 mg/mL (liquids) of 7-OH, MP, or both combined | Any product form |
| Ratio | Mitragynine : (7-OH + MP) below 100 | Any product form |
Why concentrated extracts are most exposed
Concentrating the leaf's alkaloids concentrates any 7-OH with them. In a 60% mitragynine extract, 7-OH at just 0.1% by weight equals 1 mg/g, which is the limit. The ratio test is easier to pass for a high-mitragynine extract, but the concentration test is not.
7-OH also forms when mitragynine oxidizes, so heat, light and air during extraction, drying and storage all matter. A lot that tests clean at release can drift if it is stored badly.
What to check on a COA
- 7-OH reported in mg/g (or % w/w you can convert: 0.1% = 1 mg/g), with the method's limit of quantitation
- MP reported, or stated as not detected with the detection limit
- Mitragynine on the same basis, so you can calculate the ratio
- Lab name, ISO/IEC 17025 accreditation and a lot number that matches your packaging
- A test date recent enough to reflect the material you receive
How we apply it
Every Rams Exotics lot is tested for 7-OH and MP by a named independent laboratory, and the result is published in the COA library with the calculated ratio. Our internal release limit is set below the federal threshold, so that normal storage drift cannot push a lot over it.