MGM-15, MGM-16 and Pseudoindoxyl: What the DEA's August 2026 Order Covers

On August 26, 2026, three compounds that most kratom shoppers had never heard of two years ago became Schedule I controlled substances: mitragynine pseudoindoxyl, MGM-15 and MGM-16. There was no grace period and no minimum amount. Since that date, possessing any quantity without a DEA registration has been a federal crime.

If you've seen "pseudo," "MGM" or "dihydro" on a label at a smoke shop, or you're trying to work out whether this order affects 7-OH or regular kratom, this post covers what the order includes, what it leaves out, and what to check before you buy anything in this category.

The Short Answer

• Schedule I since August 26, 2026: mitragynine pseudoindoxyl, MGM-15 (dihydro-7-hydroxymitragynine) and MGM-16 (9-fluoro-dihydro-7-hydroxymitragynine), including their isomers, esters, ethers and salts. Any amount counts.
• Proposed but not final: 7-OH above a set threshold, under a separate DEA docket.
• Still federally uncontrolled: mitragynine and kratom (Mitragyna speciosa) leaf. State and local rules vary.

What MGM-15, MGM-16 and Pseudoindoxyl Actually Are

None of the three are things you'd get from chewing kratom leaves or brewing tea. According to the DEA's order, all three are made by chemically modifying purified mitragynine or 7-OH.

Mitragynine pseudoindoxyl, often shortened to "pseudo" or "MP," is a rearranged form of 7-OH. Scientists first described it in 1974 as a breakdown product of mitragynine. The DEA says it first appeared in consumer products in 2024.

MGM-15 is dihydro-7-hydroxymitragynine, a derivative of 7-OH. Researchers developed it in 2014 as part of pain drug research. It reached retail products in September 2025.

MGM-16 is a fluorinated version of MGM-15. Depending on the numbering system a chemist uses, it's called 9-fluoro-dihydro-7-hydroxymitragynine or 10-fluoro-dihydro-7-hydroxymitragynine. The DEA found no evidence it's being sold to consumers yet. It did find a vendor listing it for "upcoming sale," and it scheduled MGM-16 at the same time so sellers couldn't simply swap one compound for the other.

Those potency numbers come from preclinical animal research, not human trials. They still explain why regulators treated this as urgent.

Why the DEA Moved So Fast

The order lays out its evidence in unusual detail. These are the figures that stand out.

• DEA toxicology testing identified mitragynine pseudoindoxyl in at least 56 overdose cases between February 2025 and May 2026. Forty-eight of them were fatal.
• MGM-15 showed up in 17 overdose cases between February and April 2026. Sixteen were fatal.
• A review of 51 pseudoindoxyl products sold online found that 76% were chewable tablets, 35 came in candy-style flavors, and 71% also contained 7-OH.
• US poison centers logged 3,434 kratom-related exposure calls in 2025, up from 258 in 2015, according to a CDC report cited in the order.

The DEA was just as pointed about marketing. It called out products printed with "for research purposes only" or "not for human consumption" while being sold as fruit-flavored chewables, and products promoted for stress, calm or "mental clarity" despite having no approved medical use.

The order also cites a published case of a 34-year-old man who moved from kratom powder to 7-OH tablets and then to pseudoindoxyl tablets. He worked up to nine 20 mg doses a day, couldn't cut back on his own because of withdrawal, and needed several days of medically managed withdrawal treatment.

What the Order Says, Step by Step

The timeline from first notice to Schedule I took about eight months.

What that means in practice:

• There's no threshold. Unlike the 7-OH proposal, any detectable amount is covered.
• Related forms count too. The listing covers isomers, esters, ethers and salts. The DEA also wrote the chemical names so that a different atom-numbering convention can't be used as a loophole.
• Retail sale is over. Schedule I substances can't legally be sold to the public, and possession without authorization since August 26 can lead to prosecution.
• Businesses had to surrender stock. Anyone holding these compounds without a Schedule I registration was required to give up what they had.
• The order can't be challenged in court during its term. As attorneys at Vicente LLP point out, temporary scheduling orders issued under this part of the law aren't subject to judicial review.

How This Differs From the 7-OH Proposal

The two actions were announced together on July 1 and published together on July 6. Then they split.

The 7-OH proposal, Docket DEA-1570, would place 7-OH in Schedule I above a threshold. For botanical material, that's more than 0.050% 7-OH by dry weight. For synthetic or processed products, it's more than 0.050% or more than 1.00 mg per article. HHS extended its comment period on the threshold to September 10, 2026. As of September 29, 2026, the 7-OH order hasn't been published.

When it is, it takes effect that day. Nearly every 7-OH tablet and shot on the market, which commonly contain 20 mg or more per piece, would sit far above the 1 mg line. The threshold exists mainly to separate those products from plain kratom leaf, where 7-OH shows up only in trace amounts.

Where "Dihydro Mitragynine" and "DHM" Fit In

This is where labels get messy. MGM-15's full name is dihydro-7-hydroxymitragynine, but some products are sold as "dihydro mitragynine" or just "DHM." From the name alone, you can't tell exactly which compound is in the bottle. To add to the confusion, DHM is also the usual abbreviation for dihydromyricetin, an unrelated supplement sold for hangovers.

Two things to keep in mind.

• If the lab report shows dihydro-7-hydroxymitragynine, that's MGM-15. It is Schedule I, regardless of what the front of the package calls it.
• A compound that isn't named in the order isn't automatically in the clear. Under the federal Controlled Substance Analogue Act, a substance that is chemically and pharmacologically similar to a Schedule I drug can be treated as controlled when it's intended for human consumption. Every new Schedule I listing gives prosecutors another point of comparison.

We're not lawyers, and this isn't legal advice. But if a product is pitched as "the next MGM" or "stronger than 7-OH," treat that as a warning sign, not a selling point.

How to Spot These Compounds on a Label or COA

Names to watch for on packaging or a Certificate of Analysis:

• Mitragynine pseudoindoxyl, pseudoindoxyl, "pseudo" or "MP"
• MGM-15, dihydro-7-hydroxymitragynine or dihydro-7-OH
• MGM-16, 9-fluoro-dihydro-7-hydroxymitragynine or 10-fluoro-dihydro-7-hydroxymitragynine

Other red flags the DEA described:

• "For research purposes only" or "not for human consumption" printed on a flavored chewable
• Claims that a product treats stress, pain or any other health condition
• No batch-specific lab report at all

One more thing about COAs. A lab report only lists the compounds the lab was asked to test for. A report that shows mitragynine and 7-OH results tells you nothing about whether pseudoindoxyl or MGM-15 is present. If that matters to you, ask the seller whether the testing panel screens for them. Our guide on how to read a Certificate of Analysis walks through the rest of the report, and why third-party testing matters covers what to expect from an honest brand.

If You Have These Products Right Now

• Stop using them, and don't sell or give them away. Passing them on is distribution of a Schedule I substance.
• Ask about disposal. Your local pharmacy or police non-emergency line can tell you what options exist in your area. Businesses should talk to a lawyer.
• Don't quit cold turkey on your own if you've been using them daily. Withdrawal from potent opioids can be severe. Talk to a doctor, or call the free, confidential SAMHSA National Helpline at 1-800-662-4357. It's open 24 hours a day.
• Know the signs of an opioid overdose: slow or stopped breathing, blue or gray lips, pinpoint pupils, and not waking up when shaken. Call 911 right away. Naloxone (Narcan) is sold over the counter, acts on the same receptor these compounds target, and can reverse an opioid overdose.

What's Still Legal at the Federal Level

As of September 29, 2026:

• Mitragynine: federally uncontrolled
• Kratom leaf: federally uncontrolled
• 7-OH: federally uncontrolled for now, with the threshold order pending
• Mitragynine pseudoindoxyl, MGM-15, MGM-16: Schedule I

State and local laws are a separate question. Several states and counties already ban or restrict kratom products. We don't ship to Alabama, Arkansas, Connecticut, Florida, Indiana, Louisiana or Wisconsin, or to the counties listed in our shipping policy.

If you use mitragynine products, the habit that protects you most is reading the lab report for every batch before you buy. Ours are posted publicly on our Lab Reports page. If you're new to mitragynine tablets, our MIT tablet strength guide explains the 40, 80 and 120 mg options and where to start, and What Are MIT Tablets? covers the basics.

MGM-15 and Pseudoindoxyl FAQ

Is MGM-15 legal?

No. MGM-15 has been a Schedule I controlled substance since August 26, 2026. Any amount is covered, and the temporary order runs until at least August 26, 2028.

Is mitragynine pseudoindoxyl the same as 7-OH?

No. It's a chemically rearranged form of 7-OH. In animal studies cited by the DEA, it's about 100 times more potent than mitragynine at the mu-opioid receptor. Pseudoindoxyl is Schedule I. 7-OH is not, at least for now.

Is dihydro mitragynine the same as MGM-15?

Not necessarily. MGM-15 is specifically dihydro-7-hydroxymitragynine. Products labeled "dihydro mitragynine" or "DHM" may or may not contain it, so check the lab report for the exact compound name. Compounds closely related to a Schedule I drug can also fall under the federal Analogue Act.

Did the DEA ban 7-OH?

Not as of September 29, 2026. The DEA has proposed placing 7-OH above 1.00 mg per product (or 0.050% by weight) in Schedule I, and that order would take effect the day it's published.

Is kratom illegal now?

Not federally. Kratom leaf and mitragynine remain uncontrolled at the federal level, but some states and counties ban or restrict kratom products.

How long does the temporary scheduling order last?

Two years, through August 26, 2028. The DEA can extend it by one more year if permanent scheduling proceedings are underway.

The Bottom Line

The August order drew a hard line around the most potent semi-synthetic compounds in the kratom market, and it did it without a threshold, a phase-in or a way to challenge it in court. For shoppers, the useful lessons are simple: learn the exact chemical names, read the full lab report rather than the front of the box, and be wary of any product sold as the next, stronger version of something that just got scheduled.