Is 9-OH (9-hydroxycorynantheidine) Legal in Arkansas? (2026)

Gray area

As of November 8, 2026, 9-OH (9-hydroxycorynantheidine) is in a legal gray area (sold in practice, exposed to an interpretive ban theory) in Arkansas. Not named; mitragynine and 7-OH are Schedule I, and the analog statute (Ark. Code 5-64-414) may reach 9-OH intended for consumption. Controlling source: Arkansas Department of Health, List of Controlled Substances, Schedule I(c)(24)-(25) (5 CAR pt. 22).

Verified November 8, 2026 · confidence: under review

Is 9-OH Legal? Every state and federal law

WatchNo pending legislation, deadlines or enforcement actions on file for 9-OH in Arkansas.
Rule type
permanent
Tier
Under review

What the record says

The Arkansas Department of Health List of Controlled Substances places Mitragynine (item 24) and 7-Hydroxymitragynine (item 25) in Schedule I among the opium derivatives (Schedule I(c), dated 11-2015), under a chapeau that reaches each listed derivative and its salts, isomers and salts of isomers. 9-OH (9-hydroxycorynantheidine, 9-O-demethylmitragynine) is not named, and the list as amended through Ark. R. 2026-126 (effective September 28, 2026) has no kratom alkaloid class entry. 9-OH is not a salt or isomer of either listed compound (different molecular formula), and the heading word 'opium derivatives' names the category rather than extending each entry to its derivatives, so the listings do not reach it by their terms. The remaining route is the controlled substance analog statute, Ark. Code 5-64-414: a substance whose chemical structure is substantially similar to a Schedule I or II substance, or whose central nervous system depressant effect is substantially similar, or which a person represents or intends to have that effect, is treated as Schedule I to the extent intended for human consumption. 9-OH differs from Schedule I mitragynine by one methyl group, so the structural prong is a serious argument, but no prosecution or ruling applying it to 9-OH was found, so reach is interpretive. A semi-synthetic 9-OH tablet or liquid that retains detectable mitragynine or 7-hydroxymitragynine contains a listed Schedule I substance, which is an express exposure apart from the analog question. Kratom leaf itself is controlled through the mitragynine listing. Arkansas has no kratom consumer protection act (SB 534 of 2025 failed), so there are no age, label or form rules. Ark. Code 5-64-201(d) adopts federal designations 30 days after a final federal order unless the Director objects (read on a mirror); 9-OH has no federal designation. 9-OH is not federally scheduled; federal Analogue Act and FDA exposure are interpretive.

Controlling language, verbatim

(c) Opium derivatives: (Narcotic Drugs) Unless specifically excepted or unless listed in another schedule, any of the following opium derivatives, its salts, isomers, and salts of isomers whenever the existence of such salts, isomers, and salts of isomers is possible within the specific chemical designation: ... (24) Mitragynine -------------------------------------------------------------------------------------- (11-2015) ... (25) 7-Hydroxymitragynine---- ------------------------------------ ---------------------------------(11-2015) ... (a)(1) “Controlled substance analog” means a substance the chemical structure of which is substantially similar to the chemical structure of a controlled substance in Schedule I or II or which has a stimulant, depressant, or hallucinogenic effect on the central nervous system substantially similar to the stimulant, depressant, or hallucinogenic effect on the central nervous system of a controlled substance included in Schedule I or II; or with respect to a particular individual, which the individual represents or intends to have a stimulant, depressant, or hallucinogenic effect on the central nervous system substantially similar to the stimulant, depressant, or hallucinogenic effect on the central nervous system of a controlled substance included in Schedule I or II. ... (b) A controlled substance analog, to the extent intended for human consumption, shall be treated for the purposes of this chapter as a substance included in Schedule I.

Source of excerpt

Citations

  1. Arkansas Department of Health, List of Controlled Substances, Schedule I(c)(24)-(25) (5 CAR pt. 22) (Arkansas Secretary of State, Code of Arkansas Rules, 2026-11-08) PRIMARYOFFICIAL
  2. Acts 2005, No. 1994, Sec. 306 (Ark. Code 5-64-414, controlled substance analog) (Arkansas General Assembly, 2026-11-08)OFFICIAL
  3. Code of Arkansas Rules, Part 22 history page (Ark. R. 2026-126, eff. Sept. 28, 2026) (Arkansas Secretary of State, 2026-11-08)OFFICIAL
  4. Ark. Code 5-64-414 (mirror, undated) (onecle (mirror), 2026-11-08)OFFICIAL
  5. SB 534 (2025), Arkansas Kratom Consumer Protection Act (Arkansas General Assembly, 2026-11-08)OFFICIAL

Where 9-OH (9-hydroxycorynantheidine) stands across the country

LegalRestrictedGray areaIllegalNot yet verified

Among Arkansas's 6 neighbors, Louisiana and Tennessee are illegal; Mississippi, Oklahoma and Texas are gray area; Missouri is legal.

Open the interactive map · Every compound in Arkansas · Where 9-OH is banned · Embed this map

Federal posture

Not federally scheduled. Not federally scheduled: absent from 21 CFR 1308.11 and every DEA kratom-alkaloid order and notice; Analogue Act exposure is interpretive Federal detail

Verbatim law on file for Arkansas

5 instruments on file for this compound’s framework in Arkansas; 5 of 5 citations above are official sources. Each text carries its source and a fingerprint that changes when the law does.

AR ADH Sched I (c) + (d) limiter; Ark. Code 5-64-101 · Arkansas Schedule I opium-derivatives chapeau (unqualified isomers) + hallucinogen paragraph optical/positional/geometric limiter (scoped away)OFFICIAL
Instrument
Arkansas Schedule I opium-derivatives chapeau (unqualified isomers) + hallucinogen paragraph optical/positional/geometric limiter (scoped away)
Source
https://healthy.arkansas.gov/wp-content/uploads/Controlled-Substances-List-7.3.25.pdf
Retrieved
2026-07-06
Fingerprint
62ad8446e3007192
Arkansas Dept. of Health, List of Controlled Substances (rule; auth. Ark. Code Ann. 5-64-216 & 5-64-101 et seq.), Schedule I:
(c) Opium derivatives (Narcotic Drugs) - governing chapeau for the mitragynine listing:
"(c) Opium derivatives: (Narcotic Drugs) Unless specifically excepted or unless listed in another schedule, any of the following opium derivatives, its salts, isomers, and salts of isomers whenever the existence of such salts, isomers, and salts of isomers is possible within the specific chemical designation:"
Entries:
"(24) Mitragynine (11-2015)"
“(25) 7-Hydroxymitragynine (11-2015)”

(d) Hallucinogenic substances chapeau - the optical/positional/geometric limiter, expressly scoped to (d) ONLY (does NOT govern the (c) mitragynine listing):
"...(for purposes of this paragraph only, the term \"isomer\“ includes the optical, position and geometric isomers):”

Ark. Code Ann. 5-64-101 (Definitions): no general definition of "isomer."
Ark. Code 5-64-414 · Controlled substance analogMIRROR
Instrument
Controlled substance analog
Source
https://law.onecle.com/arkansas/title-5/5-64-414.html
Retrieved
2026-10-28
Fingerprint
47e5ce6e9fe57a81
(a)

(1)
 “Controlled substance analog” means a substance:

(A)
 The chemical structure of which is substantially similar to the chemical structure of a controlled substance in Schedule I or Schedule II or that has a stimulant, depressant, or hallucinogenic effect on the central nervous system substantially similar to the stimulant, depressant, or hallucinogenic effect on the central nervous system of a controlled substance included in Schedule I or Schedule II; or

(B)
 With respect to a particular individual, that the individual represents or intends to have a stimulant, depressant, or hallucinogenic effect on the central nervous system substantially similar to the stimulant, depressant, or hallucinogenic effect on the central nervous system of a controlled substance included in Schedule I or Schedule II.

(2)
 “Controlled substance analog” does not include:

(A)
 A controlled substance;

(B)
 A substance for which there is an approved new drug application;

(C)
 A substance with respect to which an exemption is in effect for investigational use by a particular person under § 505 of the Federal Food, Drug, and Cosmetic Act, 21 U.S.C. § 355, to the extent conduct with respect to the substance is pursuant to the exemption; or

(D)
 Any substance to the extent not intended for human consumption before an exemption takes effect with respect to the substance.
(b)
 A controlled substance analog, to the extent intended for human consumption, is treated for the purposes of this chapter as a substance included in Schedule I.
(c)
 Within ten (10) days after the initiation of prosecution with respect to a controlled substance analog by indictment or information, the prosecuting attorney shall notify the Director of the Department of Health of information relevant to emergency scheduling as provided for in § 5-64-201(d).
(d)
 After final determination that the controlled substance analog should not be scheduled, no prosecution relating to that substance as a controlled substance analog may continue or take place.
Ark. Code 5-64-414 as enacted by Acts 2005, No. 1994, Sec. 305 (subsection (c) since amended by Acts 2019, No. 910, Sec. 4844) · Controlled substance analogOFFICIAL
Instrument
Controlled substance analog
Source
https://www.arkleg.state.ar.us/Home/FTPDocument?path=%2FACTS%2F2005%2FPublic%2FACT1994.pdf
Retrieved
2026-10-29
Fingerprint
cfa185d5722e7286
(a)(1)  “Controlled substance analog” means a substance the chemical

26

structure of which is substantially similar to the chemical structure of a

27

controlled substance in Schedule I or II or which has a stimulant,

28

depressant, or hallucinogenic effect on the central nervous system

29

substantially similar to the stimulant, depressant, or hallucinogenic effect

30

on the central nervous system of a controlled substance included in Schedule

31

I or II; or with respect to a particular individual, which the individual

32

represents or intends to have a stimulant, depressant, or hallucinogenic

33

effect on the central nervous system substantially similar to the stimulant,

34

depressant, or hallucinogenic effect on the central nervous system of a

35

controlled substance included in Schedule I or II.

36

            (2)  The term does not include:

238

03-31-2005 14:29  GRH242

As Engrossed: H3/31/05

SB984

1

2

3

4

5

6

7

8

9

                  (A)  A controlled substance;

                  (B)  A substance for which there is an approved new drug

application;

                  (C)  A substance with respect to which an exemption is in

effect for investigational use by a particular person under section 505 of

the Federal Food, Drug and Cosmetic Act to the extent conduct with respect to

the substance is pursuant to the exemption; or

                  (D)  Any substance to the extent not intended for human

consumption before an exemption takes effect with respect to the substance.

10

(b)  A controlled substance analog, to the extent intended for human

11

consumption, shall be treated, for the purposes of subchapters 1-6 of this

12

chapter, as a substance included in Schedule I.

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(c)  Within ten (10) days after the initiation of prosecution with

14

respect to a controlled substance analog by indictment or information, the

15

prosecuting attorney shall notify the Director of the Department of Health of

16

information relevant to emergency scheduling as provided for in § 5-64-

17

201(d).

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(d)  After final determination that the controlled substance analog

19

should not be scheduled, no prosecution relating to that substance as a

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controlled substance analog may continue or take place.
Show 2 more laws on file
Ark. Dept. of Health List of Controlled Substances, Schedule I(c)(24)-(25); Ark. Code 5-64-414 (Acts 2005, No. 1994, Sec. 306) · Schedule I opium derivatives (mitragynine, 7-hydroxymitragynine); controlled substance analogOFFICIAL
Instrument
Schedule I opium derivatives (mitragynine, 7-hydroxymitragynine); controlled substance analog
Source
https://codeofarrules.arkansas.gov/Rules/PartDocument?partID=705
Retrieved
2026-11-08
Fingerprint
6706c069ea223aaa
(c) Opium derivatives: (Narcotic Drugs) Unless specifically excepted or unless listed in another
schedule, any of the following opium derivatives, its salts, isomers, and salts of isomers whenever the
existence of such salts, isomers, and salts of isomers is possible within the specific chemical
designation:

(24) Mitragynine -------------------------------------------------------------------------------------- (11-2015)

(25) 7-Hydroxymitragynine---- ------------------------------------ ---------------------------------(11-2015)

(a)(1)     “Controlled substance analog” means a substance the chemical
structure of which is substantially similar to the chemical structure of a
controlled substance in Schedule I or II or which has a stimulant,
depressant, or hallucinogenic effect on the central nervous system
substantially similar to the stimulant, depressant, or hallucinogenic effect
on the central nervous system of a controlled substance included in Schedule
I or II; or with respect to a particular individual, which the individual
represents or intends to have a stimulant, depressant, or hallucinogenic
effect on the central nervous system substantially similar to the stimulant,
depressant, or hallucinogenic effect on the central nervous system of a
controlled substance included in Schedule I or II.

(2)      The term does not include:

(A)   A controlled substance;
(B)   A substance for which there is an approved new drug
application;
(C)   A substance with respect to which an exemption is in
effect for investigational use by a particular person under § 505 of the
federal Food, Drug, and Cosmetic Act to the extent conduct with respect to
the substance is pursuant to the exemption; or
(D)   Any substance to the extent not intended for human
consumption before an exemption takes effect with respect to the substance.

(b)    A controlled substance analog, to the extent intended for human
consumption, shall be treated for the purposes of this chapter as a substance
included in Schedule I.

(c)    Within ten (10) days after the initiation of prosecution with
respect to a controlled substance analog by indictment or information, the
prosecuting attorney shall notify the Director of the Department of Health of
information relevant to emergency scheduling as provided for in § 5-64-
201(d).
(d)    After final determination that the controlled substance analog
should not be scheduled, no prosecution relating to that substance as a
controlled substance analog may continue or take place.
Ark. Dept. of Health, List of Controlled Substances, Schedule I(c) (opium derivatives), items (24)-(25) · Schedule I opium derivatives: Mitragynine and 7-HydroxymitragynineOFFICIAL
Instrument
Schedule I opium derivatives: Mitragynine and 7-Hydroxymitragynine
Source
https://www.sos.arkansas.gov/uploads/rulesRegs/Arkansas%20Register/2015/1115reg/007.07.15-002.pdf
Retrieved
2026-10-29
Fingerprint
08a699111a5d9b03
(c)  Opium derivatives:  (Narcotic Drugs)  Unless specifically excepted or
unless listed in another schedule, any of the following opium derivatives, its
salts, isomers, and salts of isomers whenever the existence of such salts,
isomers, and salts of isomers is possible within the specific chemical
designation:
          (1)  Acetorphine -------------------------------------- 9319*
          (2)  Acetyldihydrocodeine ----------------------------- 9051*
          (3)  Benzylmorphine ----------------------------------- 9052*
          (4)  Codeine methylbromide ---------------------------- 9070*
          (5)  Codeine-N-Oxide ---------------------------------- 9053*
          (6)  Cyprenorphine ------------------------------------ 9054*
          (7)  Desomorphine ------------------------------------- 9055*
          (8)  Dihydromorphine ---------------------------------- 9145*
          (9)  Drotebanol --------------------------------------- 9335*
         (10)  Etorphine (except hydrochloride salt) ------------ 9056*
         (11)  Heroin ------------------------------------------- 9200*
         (12)  Hydromorphinol ----------------------------------- 9301*
         (13)  Methyldesorphine --------------------------------- 9302*
         (14)  Methyldihydromorphine ---------------------------- 9304*
         (15)  Morphine methylbromide --------------------------- 9305*
         (16)  Morphine methylsulfonate ------------------------- 9306*
         (17)  Morphine-N-Oxide --------------------------------- 9307*
         (18)  Myrophine ---------------------------------------- 9308*
         (19)  Nicocodeine -------------------------------------- 9309*
         (20)  Nicomorphine ------------------------------------- 9312*
         (21)  Normorphine -------------------------------------- 9313*
         (22)  Pholcodine --------------------------------------- 9314*
         (23)  Thebacon ----------------------------------------- 9315*
         (24)  Mitragynine
         (25)  7-Hydroxymitragynine

9-OH (9-hydroxycorynantheidine) in neighboring states

9-OH in 44 other states

Closest to 9-OH in Arkansas

36 other compounds in Arkansas

Cite this page

Compound Analytics. “Is 9-OH Legal in Arkansas? Updated Nov 2026.” Compound Laws, https://compoundlaws.com/compounds/9-oh/arkansas/. Accessed November 13, 2026.

Compound Laws, published by Compound Analytics, reports the record: statutes verbatim, official citations, enforcement facts and verification dates. Nothing here is legal advice and nothing here describes how to get around a law. A jurisdiction with no verified row is reported as not yet verified, never as legal. Found an error? Corrections policy.

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