Kratom, the psychoactive leaf that has been used for pain relief, mood elevation, and as a stimulant for hundreds of years in Southeast Asia, is now used by tens of millions of Americans every day. This plant’s effects are caused by dozens of alkaloids – nitrogen-containing molecules that induce psychoactive effects in drugs like caffeine and cocaine. The most abundant and well-studied of these alkaloids is mitragynine.
But recently, another kratom alkaloid has emerged into the spotlight: 7-hydroxymitragynine, also known as 7-OH.
Although first detected over 30 years ago, 7-OH extract products such as tablets, gummies, shots, and vapes began to widely proliferate more recently in 2023, and can now be found in smoke shops and gas stations across the country. The issue was recently pushed into the spotlight when the Food and Drug Administration (FDA) issued an emergency request on 29 July for the Drug Enforcement Agency (DEA) to criminalise it as a schedule I substance.
This recent FDA request has split kratom advocates. Right now, both kratom and 7-OH are federally legal, and the kratom plant is legal to purchase in all but seven states. Some advocates have chosen to draw a clear distinction between 7-OH and kratom, while others have taken the position that since kratom contains small quantities of 7-OH, it is misguided to draw a legal distinction between the two.
But regardless of the very real risks posed by high-potency 7-OH extracts, scheduling this molecule will only put 7-OH users at risk in the short term, and the legal status of the kratom plant in jeopardy in the long term.
An issue of potency
Compared to mitragynine, 7-OH binds much more strongly to the u-opioid receptor in the brain, meaning that it seems to share many of the properties of other opioids like morphine. This has made it a godsend for people living with chronic pain, or trying to wean themselves off of opioids like prescription painkillers, heroin or fentanyl. However, the media has published a series of alarming headlines on 7-OH use, highlighting widespread calls to poison centers after use. This stems from 7-OH seemingly being more habit forming than mitragynine. This is probably because marketed 7-OH products have as much as 100 times the concentration naturally found in a standard dose of leaf kratom. And while some 7-OH proponents argue that the risk of a lethal overdose is low to non-existent, the molecule has simply not been studied long enough to say for sure.
As a general rule, whole-plant drugs tend to be safer, less potent, and have a lower addictive potential than extracts made from their primary alkaloids, terpenes, and other psychoactive molecules. This is a lesson most evident with opiates. The scientist who first isolated morphine from opium poppies in 1804 believed that because a smaller quantity would be required to relieve pain, morphine would be less addictive than raw opium. He was wrong: morphine addiction spread like wildfire in the 19th century, often ending in overdose for those who self-administered. Heroin, developed almost a century later by boiling morphine with acetic anhydride, was marketed by the pharmaceutical company Bayer as a “non-addictive” alternative to morphine. The absurdity of that claim needs no further comments.
The idea that whole-plant drugs are safer than the concentrated extracts of their psychoactive principles is not limited to opiates, either. Coca leaves have been chewed and brewed as tea in South America for centuries; in fact, there’s growing evidence of coca’s health benefits for altitude sickness, indigestion, and other conditions. Coca leaves contain as little as 0.5% to 1% of cocaine, the psychoactive alkaloid so widely sold, inside them: about 450 to 600 kilos of fresh coca leaves are used to make a kilo of cocaine base. The process of refinement amplifies its effects.
Similarly, cannabis has been used for millenia around the world with minimal health risks. However, there have been growing health concerns about the use of high-THC-containing cannabis concentrates, which have been linked to conditions like cannabis hyperemesis syndrome, or even psychosis for those predisposed.
With 7-OH, it’s understandable that people are keen to draw a line between this much more potent substance and the kratom leaf from which it was originally derived.
However, kratom advocates celebrating the criminalisation of 7-OH should recognise that this decision would represent a continuation of the war on drugs, and both the kratom leaf and those who consume it are likely to end up in the crosshairs of prohibition as a result. Time and time again, evidence shows that criminalising certain substances does not necessarily reduce their use; instead, it makes it harder for people to access accurate health information, harm reduction resources, and support services.
Creeping prohibition
According to the FDA commissioner, kratom leaf will remain untouched by the scheduling of 7-OH. “We are not targeting the kratom leaf or ground-up kratom,” he said in a statement. “We are targeting a concentrated synthetic byproduct that is an opioid.”
Colour me suspicious. For one, across the media, 7-OH overdoses are being attributed to kratom, with no meaningful distinction made between plant and derivative. A handful of states around the country, most recently Louisiana, have already criminalised kratom, in spite of kratom advocates organising and sharing stories of how the drug has helped them.
Federal agencies like the FDA and the DEA have also had kratom in their sights for a long while. In 2016, the DEA wanted to federally criminalise kratom, only changing course in response to sustained advocacy by thousands of kratom consumers and advocacy groups like the American Kratom Association (AKA). As recently as 2018, then-FDA commissioner Scott Gottlieb was still calling for its ban, dismissing kratom’s well-documented use for treating opioid withdrawal. And while the Department of Health and Human Services (HHS) rescinded the DEA’s request to schedule kratom’s alkaloids in a 2018 letter to the DEA, the FDA failed to make that letter public.
The FDA’s comments on keeping kratom safe from criminalisation should be taken with a large pinch of salt, even if they’re directed at one specific alkaloid. Allowing the government to ban one of the most potent alkaloids that’s often found in kratom paves the way for a future kratom ban. After all, kratom does contain 7-OH; despite being found in trace quantities, a plant that contains a schedule I controlled substance in its chemistry is unlikely to be allowed to circulate for long.
This is especially the case when law enforcement agencies believe that a controlled substance could be synthesised from kratom. This is what happened with coca: although literally hundreds of kilos of coca are needed to make cocaine, it’s currently a Schedule II substance in the US – just as illegal to import or consume as cocaine. The main reason for its scheduling is the “ready extractability” of cocaine from coca leaf.
It is true that 7-OH poses specific risks that don’t exist with kratom leaf. But the harms of criminalising it as a Schedule I substance probably outweigh any benefits. 7-OH’s risks need to be studied; until it’s better understood, 7-OH products should be regulated under a framework which recognises its medical potential, and one that doesn’t risk criminalising whole-plant kratom in the process.
Given the Trump administration’s penchant for dealing with drug-related issues in a heavy-handed way, this careful approach is unlikely to happen. That’s why coordinated advocacy by kratom consumers and related businesses will be critical to shape its future policy. And yet, those advocates that protected kratom in 2016 from scheduling have largely been missing for 7-OH.
Most disappointingly, the American Kratom Association has come out in support of the 7-OH ban. Mac Haddow, AKA’s Senior Public Policy Fellow, has said that “every 7-OH sale is a public time bomb”. Haddow has publicly fought with prominent kratom experts like Dr. Kirsten Smith, who argues that there is not enough scientific evidence to support 7-OH’s scheduling.
If Haddow and similarly-minded kratom advocates think that their advocacy is meaningfully different from drug prohibition campaigns of years past, they are sorely mistaken. Abandoning 7-OH with the hope that it may protect kratom leaf in the long run may become a strategy that kratom advocates come to regret.
In today’s America, if you aren’t willing to stand on principle for something as important as cognitive liberty and the right to take a (regulated yet available) mind-altering substance, you don’t actually stand for anything at all.
