The Council Answers: What The August 26 Scheduling Order Actually Covers — And What It Does Not

Since Wednesday, this publication has seen the August 26 federal action described, in coverage and in store-counter conversation, as everything from “the 7-OH ban” to “the kratom ban.” It is neither. This piece answers, in plain language, what the order does, what remains pending, and where natural leaf stands — with each answer tied to the underlying federal document.

What Did The DEA Actually Schedule On August 26

Three compounds: mitragynine pseudoindoxyl, MGM-15 and MGM-16. A Drug Enforcement Administration temporary scheduling order, Docket DEA-1644, published in the Federal Register on Wednesday, August 26 and took effect on publication. It places all three in Schedule I of the Controlled Substances Act — the category for substances with no accepted medical use — and runs from August 26, 2026 until August 26, 2028.

These are the compounds that appeared over the past year in products marketed as successors to concentrated 7-hydroxymitragynine — often sold as “pseudo” tablets and extracts. The compounds also moved under retail trade names of their own — MGM-15, for one, was sold as “Oxonol,” and at least one retailer has already posted a notice that, with the compound in Schedule I, it can no longer sell the product. Since Wednesday, distributing them is a federal offense in every state, regardless of any state's own rules.

What Are These Compounds, And How Strong Are They

All three are semi-synthetic: laboratory modifications of a kratom alkaloid rather than constituents of the leaf, and their origin is academic pharmacology rather than any plant. MGM-15 and MGM-16 were synthesized from 7-hydroxymitragynine by a Japanese research group led by Kenjiro Matsumoto and characterized in a 2014 paper in the Journal of Pharmacology and Experimental Therapeutics, as candidate analgesics for acute and nerve-injury pain. MGM-15 is a reduction product of 7-OH; MGM-16 is MGM-15 carrying a single fluorine atom at the position the chemists number C10. Mitragynine pseudoindoxyl, the third scheduled compound, is a separate rearrangement product of the same alkaloid rather than a parent of either.

That paper is also the origin of the potency figures now circulating in the trade, and they are worth stating precisely, because the form of the dose matters. In its mouse experiments, taken by mouth, the antinociceptive effect of MGM-16 — its pain-blocking effect in a tail-flick test — measured approximately 240 times that of morphine; given by injection, approximately 71 times. MGM-15 measured roughly 50 times morphine by mouth. The same group had earlier placed 7-hydroxymitragynine itself at approximately 14 times morphine on the same oral measure. The median effective oral doses put the progression in plain numbers: about 63 milligrams per kilogram for morphine, 4.4 for 7-OH, 1.3 for MGM-15, and 0.26 for MGM-16.

Those are measurements of one effect in one animal assay, published as drug-development research more than a decade before any of these compounds reached an American store shelf. They are not statements about what any product does in a person, and this publication has located no human clinical data on these compounds. What the numbers do convey is the distance traveled from the leaf — and they put the August 26 order's structure in context: there is no naturally occurring background level of these compounds for a concentration threshold to be written around.

Is There A Threshold, Like The 7-OH Proposal Has

No. This is the order's sharpest edge, and the least reported. The pending proposal on 7-OH itself would apply only above a line — material exceeding “0.050 percentage of 7-hydroxymitragynine on a dry weight basis,” or processed articles containing “greater than 1.00 milligram of 7-hydroxymitragynine.” The August 26 order on the three analog compounds contains no such threshold. Any amount, in any product, is Schedule I.

So Is 7-OH Itself Now A Schedule I Drug

Not as of this publication's last verified check of the Federal Register. The DEA's July 6 notice of intent proposed placing 7-hydroxymitragynine above the thresholds described above into Schedule I on a temporary basis. The thirty-day statutory minimum elapsed on August 5, which means the final order can publish on any day, without further warning, and would take effect immediately. As of the most recent check this publication could verify, it had not.

Separately, the Department of Health and Human Services extended the comment period on its related 7-OH docket to September 10, 2026, in a notice published the same Wednesday morning. Nothing in either document states how, or whether, the extended comment window bears on the timing of the DEA's order, and this publication declines to guess.

Does Any Of This Reach Natural Kratom Leaf

No federal scheduling action currently covers natural kratom leaf. The three compounds scheduled August 26 are not the alkaloids of the unprocessed plant as sold in leaf and powder form. On the pending 7-OH proposal, the Food and Drug Administration has stated the action is “not intended to apply to natural kratom leaf containing only naturally occurring trace levels of 7-OH” — the threshold exists precisely because published analyses place naturally occurring 7-OH in leaf below the 0.050 percent line.

State law is a separate matter entirely. A number of states prohibit kratom in all forms, and more regulate it; a federal decision not to schedule the leaf does not disturb those rules. This publication's coverage of individual state actions is collected in its Regulation section.

What Does “Temporary” Scheduling Mean

The emergency mechanism the DEA used lets a substance be placed in Schedule I quickly, for two years, with a possible extension of an additional year, while the government pursues permanent scheduling through the full rulemaking process. Temporary does not mean tentative: for its duration, a temporarily scheduled substance carries the same federal status as any other Schedule I substance.

The Short Version

Scheduled as of August 26: mitragynine pseudoindoxyl, MGM-15, MGM-16 — any amount, nationwide, through at least August 2028. Pending: 7-OH above the 0.050 percent / 1.00 milligram thresholds, with an order that can issue any day. Not covered by either federal action: natural kratom leaf. Still governing everywhere: each state's own kratom law.