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7-0H
- Purpose
This memorandum summarizes the current federal and Pennsylvania regulatory status of 7-hydroxymitragynine or synthetic 7-0H (“7-OH”), a concentrated kratom-derived compound, as of the date above.
- Summary
The federal government announced plans to move synthetic 7-OH to schedule I[1], making it illegal to sell or use. The federal plan has not yet been enacted but is expected to be any day. Pennsylvania has not yet made synthetic 7-0H illegal, but there are multiple bills traveling through the legislature that do just that. Bottomline, I would not recommend retaining synthetic 7-0H product on your shelves as they are likely to be illegal within days.
This prohibition does not apply to botanical kratom products that naturally contain 7-OH below the specified threshold.[2] The maximum threshold is .05% by dry weight for botanical material. Any manufactured, extracted, or enhanced products (such as tablets, liquid shots, gummies, or strips) containing more than .05% concentration or exceeding 1.0 milligram of 7-0H per single unit will be illegal.
If your supplier advised that it has changed its formula to allow it to be legal, you will want to get the specific formula checked by a professional laboratory.
III. Federal Status
On July 1, 2026, the Drug Enforcement Administration (“DEA”) filed two Notices of Intent to temporarily place 7-OH above a 0.05% concentration threshold (or 1.00 mg per article for processed products), along with three related synthetic compounds (mitragynine pseudoindoxyl, MGM-15, and MGM-16), into Schedule I of the Controlled Substances Act. The notices were published in the Federal Register on July 6, 2026 (Docket Nos. DEA-1570 and DEA-1644).
The Department of Health and Human Services (“HHS”), under Secretary Robert F. Kennedy Jr., issued findings supporting the action and stated that synthetic 7-OH and the related compounds have no accepted medical use and a high potential for abuse. HHS and FDA have both indicated the action is not intended to reach natural, unadulterated kratom leaf below the specified threshold.
The temporary scheduling order became eligible to take effect on or after August 5, 2026, following the statutory 30-day waiting period, and reporting as of mid-August 2026 indicates enforcement authorities are treating concentrated 7-OH as a Schedule I substance.
Note: the temporary order is time-limited (up to two years, with a possible one-year extension) pending a permanent scheduling determination. This is a fast-moving regulatory posture and could change.
- Pennsylvania Status
Pennsylvania has not enacted a state-specific statute regulating or banning 7-OH or kratom as of this writing. Two legislative efforts are pending but not yet law:
- Senate Bill 233 (Sen. Pennycuick), which would ban products exceeding a 2% 7-OH concentration, passed the Senate Health and Human Services Committee in December 2025.
- A companion House measure has been announced to schedule synthetic kratom and 7-OH as Schedule I substances under Pennsylvania’s Controlled Substance, Drug, Device and Cosmetic Act, referencing an August 2025 Department of Health advisory on rising poison-control incidents.
Because federal Schedule I placement now applies regardless of state action, concentrated 7-OH is reported to be treated as illegal to manufacture, distribute, or possess in Pennsylvania under federal law. The Pennsylvania Attorney General’s Office has publicly stated it is prepared to enforce the federal change.
- Preliminary Observations
- Natural kratom leaf below the 0.05% threshold appears to remain outside the federal scheduling action and outside current Pennsylvania law.
- Anyone currently manufacturing, distributing, or selling concentrated 7-OH products in or into Pennsylvania faces potential federal Schedule I exposure as of the reported effective date.
- State-level exposure may expand if SB 233 or the companion House bill.
- Product reformulation strategies intended to evade the threshold (e.g., altering concentration or chemical structure) carry independent legal risk and should not be recommended without further analysis.
- Status of Sources and Next Steps
Should your 7-0H products not be natural and under the caps discussed above, you should destroy these products and request a refund from your supply chain. If you are unsure whether any products you are currently are natural and fit within the stated limitations, you should destroy them.
[1] Schedule I contains other highly addictive and dangerous drugs such as heroine and LSD.
[2] Targeted Compounds: High-concentration 7-OH products and three specific synthetic derivatives—mitragynine pseudoindoxyl (MP), dihydro-7-hydroxymitragynine (MGM-15), and the 9-fluoro derivative (MGM-16)
