The DEA's 7-OH Threshold Explained: 0.05% and 1mg in Plain English

The most important number in the DEA's July 2026 filing is not a date. It is a threshold. The agency did not propose scheduling 7-hydroxymitragynine outright; it proposed scheduling 7-OH above a specified threshold, and that qualifier does a great deal of work.

Understanding the threshold is what separates an accurate reading of the action from a headline. This post lays out both prongs of the test, works through the arithmetic with concrete numbers, and explains why a pressed tablet and a spoonful of leaf powder land on opposite sides of the same line. For the timeline and the broader legal mechanics, see our companion piece, Is 7-OH Banned?

The Threshold Has Two Prongs

The filing draws a distinction between two categories of material, and applies a different test to each.

For kratom plant material, the threshold is a single percentage: 0.05% 7-OH. Material at or below that concentration is outside the scope. Material above it is captured.

For synthetically produced or further-processed articles — extracts, concentrates, processed edibles, and pressed pills — the test has two triggers joined by or: 0.05% 7-OH, or 1 milligram of 7-OH per article.

That "or" is the detail most summaries drop, and it matters enormously. An article does not need to fail both tests. Failing either one is enough. A product can sit comfortably below 0.05% by weight and still exceed the threshold on a per-article basis, and vice versa.

The primary text is available in the Federal Register notice published July 6, 2026, and the DEA's own summary is in its July 1 press release.

What 0.05% Actually Looks Like

Percentages are abstract. Grams and milligrams are not. Here is the conversion that makes 0.05% concrete:

0.05% means five hundredths of one percent, or 0.0005 as a decimal. Multiply any weight by 0.0005 and you get the threshold amount for that weight.

• 1 gram (1,000 mg) of material → 1,000 × 0.0005 = 0.5 mg of 7-OH at the threshold
• 5 grams of material → 5,000 × 0.0005 = 2.5 mg at the threshold
• 100 grams of material → 100,000 × 0.0005 = 50 mg at the threshold
• 1 kilogram of material → 1,000,000 × 0.0005 = 500 mg at the threshold

So a full gram of plant material sitting exactly at the line contains half a milligram of 7-OH. That is a useful anchor to keep in mind for everything that follows.

Why Ordinary Leaf Falls Below the Line

7-hydroxymitragynine occurs naturally in kratom leaf, but only in trace quantities. It is a minor constituent, present at levels well beneath the 0.05% mark in ordinary, unenhanced botanical leaf material.

This is precisely why the DEA structured the action around a threshold rather than around the molecule by name. A flat prohibition on 7-OH would have swept in every leaf that ever grew, because the compound is naturally present in all of it. A threshold-based approach lets the agency target material where the compound has been deliberately elevated while leaving trace-level natural occurrence outside the scope.

The agency has been explicit that the action is aimed at enhanced, concentrated, synthetic, and semi-synthetic 7-OH, not at ordinary botanical leaf containing only trace naturally-occurring amounts below the threshold.

Worked Example: A 40mg Tablet

Now apply the test to a concentrated product. Suppose a pressed tablet is labeled as containing 40 mg of 7-OH.

Per-article prong. The threshold is 1 mg per article. The tablet contains 40 mg. That is 40 times the threshold. The per-article test is exceeded before the percentage test is even reached.

Percentage prong. Suppose that tablet weighs 500 mg in total. 40 ÷ 500 = 0.08, or 8%. The threshold is 0.05%. Eight percent is 160 times the threshold.

The tablet fails both prongs, and not by a narrow margin. This is the shape of the entire concentrated-tablet category: these products are formulated to milligram figures that sit one to two orders of magnitude above the line.

The arithmetic is not close in any of these cases. There is no plausible reading of the threshold under which a tablet formulated to tens or hundreds of milligrams of 7-OH lands beneath it.

The Case Where the Two Prongs Diverge

The "or" construction becomes most interesting in products where the two tests disagree.

Consider a processed edible weighing 50 grams that contains 3 mg of 7-OH. Run the percentage test: 3 ÷ 50,000 = 0.006%. That is comfortably below 0.05%. On percentage alone, it passes.

Now run the per-article test: 3 mg against a 1 mg threshold. It is triple the limit. The article is captured.

This is the point of including a per-article prong at all. Without it, a manufacturer could dilute a meaningful dose of 7-OH into a heavy gummy or a large beverage and dodge a percentage-only test purely through bulk. The 1 mg figure closes that path. For anything sold as a discrete unit — a tablet, a capsule, a shot, a single edible — the practical question is simply how many milligrams of 7-OH are in that unit.

How to Read a Certificate of Analysis Against the Threshold

If you want to evaluate a specific product yourself, the document to look at is the certificate of analysis. Three things to check:

1. Is 7-OH reported at all? Some panels test only for total alkaloids or for mitragynine. A COA that does not itemize 7-OH cannot answer the threshold question.
2. What units are used? A result reported as a percentage of dry weight and a result reported in milligrams per serving are different measurements. Convert before comparing, using the 0.0005 multiplier above.
3. What is the article? The per-article prong applies to the unit as sold. For a bottle of 10 tablets, the article is generally the individual tablet, not the bottle.

Third-party testing is the only way to answer these questions with confidence, which is why we publish batch documentation for everything we carry on our certificate of analysis page. Cat's Claw (Uncaria tomentosa) is an entirely different botanical from a different plant family and contains no mitragynine or 7-OH whatsoever, so the threshold does not apply to it — but transparent testing is still the standard we hold ourselves to. You can read more in what is Cat's Claw or browse the Cat's Claw collection.

Frequently Asked Questions

Does the 1 mg limit apply to plant material too?

No. For kratom plant material the filing specifies the 0.05% concentration test. The per-article prong appears in the standard for synthetically produced or further-processed articles.

What counts as "further-processed"?

The filing points to extracts, concentrates, processed edibles, and pressed pills as the categories in view. In general, if 7-OH has been isolated, elevated, or formulated to a target amount rather than left at its natural trace level, the article is in that category.

Is 0.05% a large or a small number?

Small. It works out to 0.5 mg of 7-OH per gram of material. It was chosen to sit above trace natural occurrence in ordinary leaf and below the levels found in enhanced or concentrated products.

If a product is at 0.04%, is it definitely fine?

Not necessarily, and this is where the "or" matters. A processed article below 0.05% can still exceed 1 mg per article and be captured on that basis. Both prongs need to be checked. Separately, state law operates independently of federal scheduling.

Where can I read the primary sources?

The Federal Register notice (91 FR 40917, Docket No. DEA-1570) contains the operative text. The DEA press release summarizes it, and the Congressional Research Service has published a legal sidebar on the scheduling mechanism.

These statements have not been evaluated by the U.S. Food and Drug Administration. This product is not intended to diagnose, treat, cure, or prevent any disease. For adults 21+. Consult a qualified healthcare professional before use.