7-OH, MGM-15, MGM-16 & Pseudoindoxyl Explained

If you sell, distribute, or stock kratom-category products, the fastest way to get the July 2026 DEA action wrong is to treat it as one thing. It is not. The agency filed two separate Notices of Intent covering four separate substances with different chemistry and different origins. Retailers who can name and define each one — and who understand what is not on the list — are the ones who will make correct purchasing and compliance decisions in the weeks ahead.

This is a definitional explainer, written for retailers and distributors. It contains no health, effect, or medical claims of any kind. It covers what each substance is, which docket names it, and what the notices actually say. For current legal status, always verify against the Federal Register and your state statute.

What substances did the DEA move to schedule?

On July 1, 2026, the DEA filed two Notices of Intent to temporarily place concentrated 7-OH and three analogues into Schedule I. Those notices publish in the Federal Register on July 6, 2026. Here is the full roster in one place.

What is 7-hydroxymitragynine (7-OH)?

7-hydroxymitragynine, abbreviated 7-OH, is an alkaloid found naturally in the Mitragyna speciosa (kratom) plant, where it typically occurs only in trace amounts. The products at issue in docket DEA-1570 are not raw leaf; they are articles in which 7-OH has been concentrated, isolated, or otherwise processed to levels far above what the plant produces on its own — extracts, concentrates, edibles, beverages, and pressed tablets or pills.

The distinction between trace-level leaf and concentrated 7-OH is the entire architecture of the notice, so the DEA drew it with a numeric threshold rather than a name. We cover that threshold below.

What are MGM-15 and MGM-16, and is MGM-15 / MGM-16 legal?

MGM-15 is dihydro-7-hydroxymitragynine, and MGM-16 is 9-fluoro-7-hydroxymitragynine. Both are structural analogues of 7-OH — laboratory-produced modifications of the 7-OH molecule. MGM-16 in particular carries a fluorine substitution (the "9-fluoro" in its name), a hallmark of a designed synthetic rather than a plant constituent.

On the legal question retailers keep asking: as of July 4, 2026, MGM-15 and MGM-16 are not yet federally scheduled. They are named in docket DEA-1644 with a temporary Schedule I placement pending, which cannot take effect until on or after approximately August 5, 2026 (see timeline below). Because they are synthetic analogues rather than naturally occurring alkaloids, they do not benefit from the natural-leaf exclusion that applies to raw kratom. Retailers should also confirm state law, which in several jurisdictions already reaches "7-OH and analogues" language.

What is mitragynine pseudoindoxyl?

Mitragynine pseudoindoxyl (sometimes abbreviated MP) is a rearrangement product derived from the kratom alkaloid framework. Like MGM-15 and MGM-16, it appears in docket DEA-1644 (91 FR 40909) alongside the two synthetic analogues, and it is not named in the separate 7-OH docket (DEA-1570). It is the third of the three "analogue" substances covered by that second notice.

What does "concentrated" actually mean? The 0.050% threshold

The notices do not ban a plant — they target concentration. Per the intent as filed, a product is covered if it is either:

• Mitragyna speciosa plant material containing more than 0.050% 7-OH by dry weight; OR
• any synthetic or processed article (extract, concentrate, edible, beverage, pressed pill/tablet) containing more than 0.050% 7-OH by weight (w/w, w/v, or v/v); OR
• any article containing more than 1.00 mg of 7-OH per package/article.

Natural kratom leaf, which carries only low trace 7-OH, is explicitly excluded and remains federally legal. This is the single most important line for retailers to internalize: the action is about concentrated and synthetic 7-OH articles, not about kratom as a category.

When does this take effect?

The mechanism is emergency scheduling under 21 U.S.C. 811(h). The temporary Schedule I order cannot take effect until at least 30 days after the July 6, 2026 Federal Register publication — i.e., on or after roughly August 5, 2026. The initial term is two years, extendable to three. A permanent placement would require a separate rulemaking, which has not started.

Separately, a related HHS Request for Information (docket HHS-OASH-2026-0232; 91 FR 41049) is accepting public comments through July 31, 2026. As of July 4, 2026, no lawsuit challenging the scheduling has been filed; industry groups have stated they are reviewing options.

What should retailers and distributors do now?

Two practical takeaways. First, know your product's 7-OH content. The threshold is numeric, which means the only defensible way to know where a SKU falls is a current Certificate of Analysis (COA) from a third-party ISO/IEC 17025-accredited laboratory. Ask every supplier for one, per lot. Second, watch payment risk: card-network rules (such as Mastercard BRAM) and individual processors have already restricted 7-OH transactions, and processors monitor merchant sites and can terminate accounts. That is a near-term business exposure independent of the scheduling timeline.

Wholesale buyers can review current lab documentation and category-compliant supply at 7ohblack.com. Retail-intent readers looking for lab-verified finished products can visit favordalkz.com, including lab results, tablets, and powder.

Frequently asked questions

How many substances are in the DEA notices, and what are they?

Four: 7-hydroxymitragynine (7-OH) under DEA-1570; and mitragynine pseudoindoxyl, MGM-15 (dihydro-7-hydroxymitragynine), and MGM-16 (9-fluoro-7-hydroxymitragynine) under DEA-1644.

Is 7-OH banned right now?

No. As of July 4, 2026 it is not federally scheduled. The temporary Schedule I order cannot take effect until on or after approximately August 5, 2026. Always verify current federal and state status before acting.

Are MGM-15 and MGM-16 the same as 7-OH?

No. They are synthetic analogues of 7-OH — MGM-15 is dihydro-7-hydroxymitragynine and MGM-16 is 9-fluoro-7-hydroxymitragynine. Unlike naturally occurring 7-OH in leaf, they are laboratory-produced and are covered under the separate DEA-1644 docket.

Does this ban natural kratom leaf?

No. Natural Mitragyna speciosa leaf, which contains only low trace 7-OH, is explicitly excluded from the notices and remains federally legal. The action targets concentrated and synthetic articles above the stated threshold.

What is the concentration threshold?

Coverage applies to plant material over 0.050% 7-OH by dry weight, to any synthetic or processed article over 0.050% 7-OH by weight, or to any article containing more than 1.00 mg of 7-OH per package.

These statements have not been evaluated by the Food and Drug Administration. This product is not intended to diagnose, treat, cure, or prevent any disease. For adults 21 and older, where legal.

This article is informational and not legal advice. Regulatory status changes quickly; verify the current Federal Register dockets and your state statute before making purchasing or compliance decisions.