Does your extract clear the 7-OH threshold?
The federal threshold for 7-OH has two tests, and a product is caught if it fails either one. Here is how to read your own COA against both, with worked examples.
On 14 October 2026 the DEA published a notice of intent (91 FR 65370) covering 7-hydroxymitragynine (7-OH) and mitragynine pseudoindoxyl (MGPI) above a specified threshold, withdrawing an earlier notice from July. The notice states an order may be published on or after 13 November 2026 and takes effect on publication.
Summarized 12 November 2026 from published reporting on the notice. Confirm the operative text and current status against the Federal Register.
Fail either one and the product is covered.
Both tests look at 7-OH and MGPI. Neither sets a limit on mitragynine itself — mitragynine appears only as the numerator in the second test.
Test A — concentration
This is an absolute ceiling. It does not matter how much mitragynine is present alongside it. For most concentrated extracts this is the test that decides the answer.
Test B — ratio
In other words, a product needs at least 100 times as much mitragynine as 7-OH and MGPI together. A high-assay MIT extract has a large numerator, so this test is usually easier to pass than Test A.
Running the numbers on a COA.
Take the 7-OH figure and the mitragynine assay from the same lot report, then check both tests.
| Material | MIT | 7-OH | Test A | Test B |
|---|---|---|---|---|
| Concentrated 7-OH tablet | 2% | 1.5% (15 mg/g) | Fails | Fails (1.3) |
| Extract at 0.5% 7-OH | 80% | 0.5% (5 mg/g) | Fails | Passes (160) |
| Extract at 0.08% 7-OH | 80% | 0.08% (0.8 mg/g) | Passes | Passes (1,000) |
| Our freebase extract | 80%+ | Non-detect | Passes | Passes |
Note the second row. An extract can pass the ratio test comfortably and still be caught by the concentration ceiling. Check both.
Four traps worth avoiding.
Most of the confusion we hear from buyers comes down to one of these.
Testing the input, not the output
Compliance is judged on the finished product. Everything else in your formula counts toward the same totals.
Assuming a high MIT assay is enough
A strong mitragynine number helps with the ratio test and does nothing for the concentration ceiling.
Reading a spec sheet instead of a COA
A spec sheet states a minimum. Only the lot COA tells you what is actually in the drum you received.
Ignoring detection limits
Non-detect is relative to the lab's method. Ask what the limit of detection was and keep the report on file.
A short procedure.
If you hold extract or finished goods and are not certain where they sit, this is the order to work through.
- Pull the lot COA for every material you hold, not the spec sheet.
- Find the 7-OH figure and convert it to mg/g. A percentage multiplied by 10 gives mg/g.
- Apply Test A to each material and to each finished product.
- Divide the MIT figure by the combined 7-OH and MGPI figure and apply Test B.
- Where a COA does not report 7-OH at all, treat that as unknown and have the lot tested.
- Take anything close to the line to your regulatory counsel before you ship it.
This page explains how the published tests are structured so you can check your own documentation. It is general information, not legal advice, and we are not in a position to assess your products. Thresholds and scheduling status can change. Confirm the operative text in the Federal Register and work with your own counsel on anything that matters.
See the numbers before you order.
Business buyers can request the current lot COA, with the mitragynine assay and the 7-OH figure, before committing to anything.
Request the current COA