As of November 12, 2026, 9-OH (9-hydroxycorynantheidine) is in a legal gray area (sold in practice, exposed to an interpretive ban theory) in California. Not scheduled; analog effect prong reach is interpretive (Health & Safety Code 11401); state health agency treats kratom-derived products as illegal. Controlling source: Cal. Health & Safety Code 11401 (controlled substance analog).
Verified November 12, 2026 (hash check) · confidence: under reviewIs 9-OH Legal? Every state and federal law
California's Schedule I (Health & Safety Code 11054) and the other schedules do not list 9-OH (9-hydroxycorynantheidine), mitragynine, 7-hydroxymitragynine or Mitragyna speciosa, and the Uniform Controlled Substances Act has no provision adopting federal scheduling automatically. No kratom statute is in force: AB 1088 (2025-2026), which would have regulated kratom products, stalled in the Senate in June 2026 and was not enacted. The state statutory route is the controlled substance analog provision. Section 11401(b) defines an analog as a substance whose chemical structure is substantially similar to a Section 11054 or 11055 substance, or one that has, is represented as having, or is intended to have a depressant effect on the central nervous system substantially similar to or greater than such a substance, and 11401(a) treats an analog like the listed substance for the Chapter 6 offenses. No kratom alkaloid is listed in 11054 or 11055, so the structural prong has no close anchor; the effect prong could be argued against listed opioids if a 9-OH product is represented as opioid-like, but no case applies 11401 to any kratom alkaloid, so reach is interpretive. A separate agency vector is active: on October 24, 2025 the Department of Public Health declared foods, dietary supplements and medical drugs containing kratom or 7-OH illegal to sell or manufacture in California, and the Department of Alcoholic Beverage Control enforces that position against its licensees with license suspension or revocation. That position rests on state food and drug law as read by the agencies, not on a statute naming 9-OH, so it does not set status, but a kratom-derived alkaloid tablet sold for consumption falls within its stated scope. Some cities and counties have adopted local kratom or 7-OH sale restrictions, which this state row does not cover. There are no state age, label or registration rules for kratom products. 9-OH is not federally scheduled; federal Analogue Act and FDA exposure are interpretive.
(b) Except as provided in subdivision (c), the term “controlled substance analog” means either of the following: ... (1) A substance the chemical structure of which is substantially similar to the chemical structure of a controlled substance classified in Section 11054 or 11055 or a synthetic cannabinoid compound defined in Section 11357.5. ... (2) A substance that has, is represented as having, or is intended to have a stimulant, depressant, or hallucinogenic effect on the central nervous system that is substantially similar to, or greater than, the stimulant, depressant, or hallucinogenic effect on the central nervous system of a controlled substance classified in Section 11054 or 11055 or a synthetic cannabinoid compound defined in Section 11357.5. ... (a) A controlled substance analog shall, for the purposes of Chapter 6 (commencing with Section 11350), be treated the same as the controlled substance classified in Section 11054 or 11055 or the synthetic cannabinoid compound defined in Section 11357.5 of which it is an analog.
Among California's 3 neighbors, Nevada and Oregon are restricted; Arizona is gray area.
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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
2 instruments on file for this compound’s framework in California; 5 of 5 citations above are official sources. Each text carries its source and a fingerprint that changes when the law does.
c448083a279f2060(a) The controlled substances listed in this section are included in Schedule I. (b) Opiates. Unless specifically excepted or unless listed in another schedule, any of the following opiates, including their isomers, esters, ethers, salts, and salts of isomers, esters, and ethers whenever the existence of those isomers, esters, ethers, and salts is possible within the specific chemical designation: (1) Acetylmethadol. (2) Allylprodine. (3) Alphacetylmethadol (except levoalphacetylmethadol, also known as levo-alpha- acetylmethadol, levomethadyl acetate, or LAAM). (4) Alphameprodine. (5) Alphamethadol. (6) Benzethidine. (7) Betacetylmethadol. (8) Betameprodine. (9) Betamethadol. (10) Betaprodine. (11) Clonitazene. (12) Dextromoramide. (13) Diampromide. (14) Diethylthiambutene. (15) Difenoxin. (16) Dimenoxadol. (17) Dimepheptanol. (18) Dimethylthiambutene. (19) Dioxaphetyl butyrate. (20) Dipipanone. (21) Ethylmethylthiambutene. (22) Etonitazene. (23) Etoxeridine. (24) Furethidine. (25) Hydroxypethidine. (26) Ketobemidone. (27) Levomoramide. (28) Levophenacylmorphan. (29) Morpheridine. (30) Noracymethadol. (31) Norlevorphanol. (32) Normethadone. (33) Norpipanone. (34) Phenadoxone. (35) Phenampromide. (36) Phenomorphan. (37) Phenoperidine. (38) Piritramide. (39) Proheptazine. (40) Properidine. (41) Propiram. (42) Racemoramide. (43) Tilidine. (44) Trimeperidine. (45) Any substance which contains any quantity of acetylfentanyl (N-[1-phenethyl-4-piperidinyl] acetanilide) or a derivative thereof. (46) Any substance which contains any quantity of the thiophene analog of acetylfentanyl (N-[1-[2-(2-thienyl)ethyl]-4-piperidinyl] acetanilide) or a derivative thereof. (47) 1-Methyl-4-Phenyl-4-Propionoxypiperidine (MPPP). (48) 1-(2-Phenethyl)-4-Phenyl-4-Acetyloxypiperidine (PEPAP). (c) Opium derivatives. 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 those salts, isomers, and salts of isomers is possible within the specific chemical designation: (1) Acetorphine. (2) Acetyldihydrocodeine. (3) Benzylmorphine. (4) Codeine methylbromide. (5) Codeine-N-Oxide. (6) Cyprenorphine. (7) Desomorphine. (8) Dihydromorphine. (9) Drotebanol. (10) Etorphine (except hydrochloride salt). (11) Heroin. (12) Hydromorphinol. (13) Methyldesorphine. (14) Methyldihydromorphine. (15) Morphine methylbromide. (16) Morphine methylsulfonate. (17) Morphine-N-Oxide. (18) Myrophine. (19) Nicocodeine. (20) Nicomorphine. (21) Normorphine. (22) Pholcodine. (23) Thebacon. (d) Hallucinogenic substances. Unless specifically excepted or unless listed in another schedule, any material, compound, mixture, or preparation, which contains any quantity of the following hallucinogenic substances, or which contains any of its salts, isomers, and salts of isomers whenever the existence of those salts, isomers, and salts of isomers is possible within the specific chemical designation (for purposes of this subdivision only, the term "isomer" includes the optical, position, and geometric isomers): (1) 4-bromo-2,5-dimethoxy-amphetamine—Some trade or other names: 4-bromo-2,5-dimethoxy-alpha-methylphenethylamine; 4-bromo-2,5-DMA. (2) 2,5-dimethoxyamphetamine—Some trade or other names: 2,5-dimethoxy-alpha-methylphenethylamine; 2,5-DMA. (3) 4-methoxyamphetamine—Some trade or other names: 4-methoxy-alpha-methylphenethylamine, paramethoxyamphetamine, PMA. (4) 5-methoxy-3,4-methylenedioxy-amphetamine. (5) 4-methyl-2,5-dimethoxy-amphetamine—Some trade or other names: 4-methyl-2,5-dimethoxy-alpha-methylphenethylamine; “DOM”; and “STP.” (6) 3,4-methylenedioxy amphetamine. (7) 3,4,5-trimethoxy amphetamine. (8) Bufotenine—Some trade or other names: 3-(beta-dimethylaminoethyl)-5-hydroxyindole; 3-(2-dimethylaminoethyl)-5 indolol; N,N-dimethylserolonin, 5-hydroxy-N,N-dimethyltryptamine; mappine. (9) Diethyltryptamine—Some trade or other names: N,N-Diethyltryptamine; DET. (10) Dimethyltryptamine—Some trade or other names: DMT. (11) Ibogaine—Some trade or other names: 7-Ethyl-6,6beta, 7,8,9,10,12,13-octahydro-2-methoxy-6,9-methano-5H-pyrido [1’,2’:1,2] azepino [5,4-b] indole; Tabernantheiboga. (12) Lysergic acid diethylamide. (13) Cannabis. (14) Mescaline. (15) Peyote—Meaning all parts of the plant presently classified botanically as Lophophora williamsii Lemaire, whether growing or not, the seeds thereof, any extract from any part of the plant, and every compound, manufacture, salts, derivative, mixture, or preparation of the plant, its seeds or extracts (interprets 21 U.S.C. Sec. 812(c), Schedule 1(c)(12)). (16) N-ethyl-3-piperidyl benzilate. (17) N-methyl-3-piperidyl benzilate. (18) Psilocybin. (19) Psilocyn. (20) Tetrahydrocannabinols. Synthetic equivalents of the substances contained in the plant, or in the resinous extractives of Cannabis, sp. and/or synthetic substances, derivatives, and their isomers with similar chemical structure and pharmacological activity such as the following: delta 1 cis or trans tetrahydrocannabinol, and their optical isomers; delta 6 cis or trans tetrahydrocannabinol, and their optical isomers; delta 3,4 cis or trans tetrahydrocannabinol, and its optical isomers. Because nomenclature of these substances is not internationally standardized, compounds of these structures, regardless of numerical designation of atomic positions covered. (21) Ethylamine analog of phencyclidine—Some trade or other names: N-ethyl-1-phenylcyclohexylamine, (1-phenylcyclohexyl) ethylamine, N-(1-phenylcyclohexyl) ethylamine, cyclohexamine, PCE. (22) Pyrrolidine analog of phencyclidine—Some trade or other names: 1-(1-phenylcyclohexyl)-pyrrolidine, PCP, PHP. (23) Thiophene analog of phencyclidine—Some trade or other names: 1-[1-(2 thienyl)-cyclohexyl]-piperidine, 2-thienyl analog of phencyclidine, TPCP, TCP. (e) Depressants. Unless specifically excepted or unless listed in another schedule, any material, compound, mixture, or preparation which contains any quantity of the following substances having a depressant effect on the central nervous system, including its salts, isomers, and salts of isomers whenever the existence of those salts, isomers, and salts of isomers is possible within the specific chemical designation: (1) Mecloqualone. (2) Methaqualone. (3) Gamma hydroxybutyric acid (also known by other names such as GHB; gamma hydroxy butyrate; 4-hydroxybutyrate; 4-hydroxybutanoic acid; sodium oxybate; sodium oxybutyrate), including its immediate precursors, isomers, esters, ethers, salts, and salts of isomers, esters, and ethers, including, but not limited to, gammabutyrolactone, for which an application has not been approved under Section 505 of the Federal Food, Drug, and Cosmetic Act (21 U.S.C. Sec. 355). (f) Unless specifically excepted or unless listed in another schedule, any material, compound, mixture, or preparation which contains any quantity of the following substances having a stimulant effect on the central nervous system, including its isomers: (1) Cocaine base. (2) Fenethylline, including its salts. (3) N-Ethylamphetamine, including its salts.
abcff0d3f9ecfe9d11401. (a) A controlled substance analog shall, for the purposes of Chapter 6 (commencing with Section 11350), be treated the same as the controlled substance classified in Section 11054 or 11055 or the synthetic cannabinoid compound defined in Section 11357.5 of which it is an analog. (b) Except as provided in subdivision (c), the term “controlled substance analog” means either of the following: (1) A substance the chemical structure of which is substantially similar to the chemical structure of a controlled substance classified in Section 11054 or 11055 or a synthetic cannabinoid compound defined in Section 11357.5. (2) A substance that has, is represented as having, or is intended to have a stimulant, depressant, or hallucinogenic effect on the central nervous system that is substantially similar to, or greater than, the stimulant, depressant, or hallucinogenic effect on the central nervous system of a controlled substance classified in Section 11054 or 11055 or a synthetic cannabinoid compound defined in Section 11357.5. (c) The term “controlled substance analog” does not mean any of the following: (1) A substance for which there is an approved new drug application as defined under Section 505 of the federal Food, Drug, and Cosmetic Act (21 U.S.C. Sec. 355) or that is generally recognized as safe and effective for use pursuant to Sections 501, 502, and 503 of the federal Food, Drug, and Cosmetic Act (21 U.S.C. Secs. 351, 352, and 353) and Section 330 and following of Title 21 of the Code of Federal Regulations. (2) With respect to a particular person, a substance for which an exemption is in effect for investigational use for that person under Section 505 of the federal Food, Drug, and Cosmetic Act (21 U.S.C. Sec. 355), to the extent that the conduct with respect to that substance is pursuant to the exemption. (3) A substance, before an exemption as specified in paragraph (2) takes effect with respect to the substance, to the extent the substance is not intended for human consumption.
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