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 Vermont. 9-OH not named; mitragynine and 7-OH listed in Regulated Drug Rule 7.0 without derivative words; derivative reach interpretive. Controlling source: Vermont Department of Health, Regulated Drug Rule (Ch. 8, Subch. 9), sections 3.1, 3.5, 3.7, 3.8 and 7.0.
Verified November 12, 2026 (hash check) · confidence: under reviewIs 9-OH Legal? Every state and federal law
Vermont controls drugs through the Department of Health Regulated Drug Rule adopted under 18 V.S.A. 4201 and 4202. Section 7.0 of the rule lists Mitragynine and 7-hydroxymitragynine by name, with no salts, isomers, esters, ethers or derivatives words attached to either entry. 9-OH (9-hydroxycorynantheidine, 9-O-demethylmitragynine) is not named anywhere in the rule or in 18 V.S.A. chapter 84, and Mitragyna speciosa is not listed as a plant. The rule defines 'Derivative' (section 3.5) as a compound obtained from a parent compound by a chemical reaction that replaces one atom or functional group with a different one, and a semi-synthetic 9-OH made by O-demethylating mitragynine fits those words on their face. But the rule attaches derivative and analog words by text only to the depressant, stimulant, cannabimimetic and narcotic definitions; the hallucinogenic drug definition attaches 'salts or derivatives or compounds' only to stramonium, mescaline or peyote, LSD, psilocybin and synthetic cannabis equivalents, and the 7.0 list carries no derivative clause. Reach to 9-OH therefore depends on reading the section 3.5 definition into the bare 7.0 mitragynine entry, so the row is restricted and interpretive (definitional). 9-OH is not an opiate, so the narcotic definition does not plainly reach it. Trace exposure: a tablet or liquid that contains any detectable mitragynine or 7-hydroxymitragynine contains a listed regulated drug. Checked and absent: automatic adoption of federal scheduling (Vermont designates regulated drugs only by Department rule), a kratom consumer protection act (S.121 and H.416 of 2025-2026 never left committee and died with the biennium), a whole-plant ban, and a general controlled-substance analog statute. 9-OH is not federally scheduled; federal Analogue Act and FDA exposure are interpretive.
“Derivative” shall mean a compound that can be obtained from a parent compound as a result of a chemical reaction which replaces one atom/functional group with a different one. ... Hallucinogenic Drugs; Synthetic Cannabinoids; Tryptamines; Cannabinimimetics; Mescaline Analogs; Dissociatives; Trade or Chemical Name ... 7-hydroxymitragynine; (αE,2S,3S,7aS,12bS)-3-Ethyl-1,2,3,4,6,7,7a,12b-octahydro-7ahydroxy-8-methoxy-α-(methoxymethylene)indolo[2,3-a]quinolizine-2-acetic acid methyl ester ... Mitragynine
Among Vermont's 3 neighbors, New York is restricted; Massachusetts and New Hampshire are 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
4 instruments on file for this compound’s framework in Vermont; 5 of 5 citations above are official sources. Each text carries its source and a fingerprint that changes when the law does.
b6dcd01b1987a8eeVermont Dept. of Health Regulated Drug Rule (Code Vt. R. 13-140-011), Sec. 7.0 (Hallucinogenic Drugs...), effective 7/15/2019 - listed entry (bare named substance, no isomer/salt tail): "Mitragynine" (For contrast the metabolite is listed with full chemical name: "7-hydroxymitragynine; (aE,2S,3S,7aS,12bS)-3-Ethyl-1,2,3,4,6,7,7a,12b-octahydro-7a-hydroxy-8-methoxy-a-(methoxymethylene)indolo[2,3-a]quinolizine-2-acetic acid methyl ester.") "Hallucinogenic Drug" class (Rule Sec. 3.7 / 18 V.S.A. 4201(10)) - NO isomer clause: “\”Hallucinogenic Drug\" means stramonium, mescaline or peyote, lysergic acid diethylamide, and psilocybin, and all synthetic equivalents of chemicals contained in resinous extractives of Cannabis sativa, or any salts or derivatives or compounds of any preparations or mixtures thereof, and any other substance which is designated as habit-forming or as having a serious potential for abuse..." 18 V.S.A. 4201 isomer clauses attach only to specifically enumerated drugs and are optical/geometric (e.g., cocaine "its salts, optical and geometric isomers, and salts of isomers"). Vermont has no diastereomer/stereoisomer catch-all.
e79e6179b4678ab13.1 3.2 "Analog" means one of a group of chemical components similar in structure but different with respect to elemental composition. It can differ in one or more atoms, functional groups or substructures, which are replaced with other atoms, groups or substructures. “Benchmark Unlawful Dosage” means the quantity of a drug commonly consumed over a twenty-four-hour period for any therapeutic purpose, as established by the manufacturer of the drug. Benchmark Unlawful dosage is not a medical or pharmacologic concept with any implication for medical practice. Instead, it is a legal concept established only for the purpose of calculating penalties for improper sale, possession, or dispensing of drugs pursuant to 18 V.S.A. § 4234. 3.3 Cannabimimetic Agents means, collectively, any chemical that is a cannabinoid receptor type 1 (CB1) or cannabinoid receptor type 2 (CB2) agonist, or any salts, isomers, derivatives, or analogs of these chemicals. Structural classes include but are not limited to: Page 1 of 35 Effective Date:7/15/2019 3.3.1 2-(3-hydroxycyclohexyl)phenol with substitution at the 5-position of the phenolic ring by alkyl or alkenyl, whether or not substituted on the cyclohexyl ring to any extent. 3.3.2 3-(1-naphthoyl)indole or 3-(1-naphthyl)indole with substitution at the nitrogen atom of the indole ring, whether or not further substituted on the indole ring to any extent, whether or not substituted on the naphthoyl or naphthyl ring to any extent. 3.3.3 3-(1-naphthoyl)pyrrole with substitution at the nitrogen atom of the pyrrole ring, whether or not further substituted in the pyrrole ring to any extent, whether or not substituted on the naphthoyl ring to any extent. 3.3.4 1-(1-naphthylmethyl)indene with substitution of the 3-position of the indene ring, whether or not further substituted in the indene ring to any extent, whether or not substituted on the naphthyl ring to any extent. 3.3.5 3-phenylacetylindole or 3-benzoylindole with substitution at the nitrogen atom 3.3.6 of the indole ring, whether or not further substituted in the indole ring to any extent, whether or not substituted on the phenyl ring to any extent. Indole- (2,2,3,3-tetramethylcyclopropyl)methanone, with substitution at the nitrogen atom of the indole ring, whether or not further substituted in the indole ring to any extent, whether or not substituted on the phenyl ring to any extent. 3.3.7 N- adamantyl-indole-3-carboxamide, with substitution at the nitrogen atom of the indole ring, whether or not further substituted in the indole ring to any extent, whether or not substituted on the phenyl ring to any extent. (1,3-thiazol-2- ylidine)-2,2,3,3- tetramethylcyclopropane-1-carboxamide, with substitution to any extent at any position of the thiazolylidine ring. 3.3.8 3.4 "Depressant drug" means any drug which contains any substances, its salt, optical isomers, salts of its optical isomers, derivatives or analogs of substances, designated in Section 5.0 of this rule as habit forming because of its effect on the central nervous system or as having a serious potential for abuse arising out of its effect on the central nervous system. 3.5 “Derivative” shall mean a compound that can be obtained from a parent compound as a result of a chemical reaction which replaces one atom/functional group with a different one. 3.6 “Fentanyl-related substances” means any substance that is structurally related to fentanyl by one or more of the following modifications: 3.6.1 Replacement of the phenyl portion of the phenethyl group by any monocycle, whether or not further substituted in or on the monocycle; 3.6.2 Substitution in or on the phenethyl group with alkyl, alkenyl, alkoxyl, hydroxyl, halo, haloalkyl, amino or nitro groups; 3.6.3 Substitution in or on the piperidine ring with alkyl, alkenyl, alkoxyl, ester, Page 2 of 35 Effective Date:7/15/2019 ether, hydroxyl, halo, haloalkyl, amino or nitro groups; 3.6.4 Replacement of the aniline ring with any aromatic monocycle whether or not further substituted in or on the aromatic monocycle; and/or 3.6.5 Replacement of the N-propionyl group by another acyl group. "Hallucinogenic Drug" means stramonium, mescaline or peyote, lysergic acid diethylamide, and psilocybin, and all synthetic equivalents of chemicals contained in resinous extractives of Cannabis sativa, or any salts or derivatives or compounds of any preparations or mixtures thereof, and any other substance which is designated as habit-forming or as having a serious potential for abuse arising out of its effect on the central nervous system or its hallucinogenic effect in the regulations adopted by the Board of Health under 18 V.S.A.§ 4202. "Narcotic drug" means opium, coca leaves, pethidine (isonipecaine, meperidine), and opiates or their compound, manufacture, salt, alkaloid, or derivative, and every substance neither chemically nor physically distinguishable from them, and preparations containing such drugs or their derivatives, by whatever trade name identified and whether produced directly or indirectly by extraction from substances of vegetable origin, or independently by means of chemical synthesis or by a combination of extraction and chemical synthesis, as the same are so designated in the regulations adopted by the Board of Health under 18 V.S.A.§ 4202. "Regulated drug" means a narcotic drug, a depressant or stimulant drug, other than methamphetamine, a hallucinogenic drug, Ecstasy, marijuana, or methamphetamine whose possession or use is regulated by law. 7.0 Hallucinogenic Drugs; Synthetic Cannabinoids; Tryptamines; Cannabinimimetics; Mescaline Analogs; Dissociatives; Trade or Chemical Name • 6-APB; 6-(2-aminopropyl)benzofuran • 7-hydroxymitragynine; (αE,2S,3S,7aS,12bS)-3-Ethyl-1,2,3,4,6,7,7a,12b-octahydro-7a- hydroxy-8-methoxy-α-(methoxymethylene)indolo[2,3-a]quinolizine-2-acetic acid methyl ester • 25B-NBOMe; • MN-18; N-1-naphthalenyl-1-pentyl-1H-indazole-3-carboxamide • MN-24; NNEI; N-1-naphthalenyl-1-pentyl-1H-indole-3-carboxamide; AM-6527 • Mitragynine • Nabilone
786c66aadb161c2c"Analog" means one of a group of chemical components similar in structure but different with respect to elemental composition. It can differ in one or more atoms, functional groups or substructures, which are replaced with other atoms, groups or substructures. “Derivative” shall mean a compound that can be obtained from a parent compound as a result of a chemical reaction which replaces one atom/functional group with a different one. "Hallucinogenic Drug" means stramonium, mescaline or peyote, lysergic acid diethylamide, and psilocybin, and all synthetic equivalents of chemicals contained in resinous extractives of Cannabis sativa, or any salts or derivatives or compounds of any preparations or mixtures thereof, and any other substance which is designated as habit-forming or as having a serious potential for abuse arising out of its effect on the central nervous system or its hallucinogenic effect in the regulations adopted by the Board of Health under 18 V.S.A.§ 4202. "Narcotic drug" means opium, coca leaves, pethidine (isonipecaine, meperidine), and opiates or their compound, manufacture, salt, alkaloid, or derivative, and every substance neither chemically nor physically distinguishable from them, and preparations containing such drugs or their derivatives, by whatever trade name identified and whether produced directly or indirectly by extraction from substances of vegetable origin, or independently by means of chemical synthesis or by a combination of extraction and chemical synthesis, as the same are so designated in the regulations adopted by the Board of Health under 18 V.S.A.§ 4202. Hallucinogenic Drugs; Synthetic Cannabinoids; Tryptamines; Cannabinimimetics; Mescaline Analogs; Dissociatives; Trade or Chemical Name 7-hydroxymitragynine; (αE,2S,3S,7aS,12bS)-3-Ethyl-1,2,3,4,6,7,7a,12b-octahydro-7ahydroxy-8-methoxy-α-(methoxymethylene)indolo[2,3-a]quinolizine-2-acetic acid methyl ester Mitragynine (10) "Hallucinogenic drugs" means stramonium, mescaline or peyote, lysergic acid diethylamide, and psilocybin, and all synthetic equivalents of chemicals contained in resinous extractives of Cannabis sativa, or any salts or derivatives or compounds of any preparations or mixtures thereof, and any other substance that is designated as habit-forming or as having a serious potential for abuse arising out of its effect on the central nervous system or its hallucinogenic effect in the rules adopted by the Department of Health under section 4202 of this title.
f7a61e3b28085a753.4
"Depressant drug" means any drug which contains any substances, its salt, optical
isomers, salts of its optical isomers, derivatives or analogs of substances, designated in
Section 5.0 of this rule as habit forming because of its effect on the central nervous
system or as having a serious potential for abuse arising out of its effect on the central
nervous system.
3.5
“Derivative” shall mean a compound that can be obtained from a parent compound as
a result of a chemical reaction which replaces one atom/functional group with a
different one.
3.6
“Fentanyl-related substances” means any substance that is structurally related to
fentanyl by one or more of the following modifications:
3.6.1 Replacement of the phenyl portion of the phenethyl group by any monocycle,
whether or not further substituted in or on the monocycle;
3.6.2 Substitution in or on the phenethyl group with alkyl, alkenyl, alkoxyl,
hydroxyl, halo, haloalkyl, amino or nitro groups;
3.6.3 Substitution in or on the piperidine ring with alkyl, alkenyl, alkoxyl, ester,
Page 2 of 35
Effective Date:7/15/2019
ether, hydroxyl, halo, haloalkyl, amino or nitro groups;
3.6.4 Replacement of the aniline ring with any aromatic monocycle whether or not
further substituted in or on the aromatic monocycle; and/or
3.6.5 Replacement of the N-propionyl group by another acyl group.
"Hallucinogenic Drug" means stramonium, mescaline or peyote, lysergic acid
diethylamide, and psilocybin, and all synthetic equivalents of chemicals contained in
resinous extractives of Cannabis sativa, or any salts or derivatives or compounds of
any preparations or mixtures thereof, and any other substance which is designated as
habit-forming or as having a serious potential for abuse arising out of its effect on the
central nervous system or its hallucinogenic effect in the regulations adopted by the
Board of Health under 18 V.S.A.§ 4202.
"Narcotic drug" means opium, coca leaves, pethidine (isonipecaine, meperidine), and
opiates or their compound, manufacture, salt, alkaloid, or derivative, and every
substance neither chemically nor physically distinguishable from them, and
preparations containing such drugs or their derivatives, by whatever trade name
identified and whether produced directly or indirectly by extraction from substances of
vegetable origin, or independently by means of chemical synthesis or by a
combination of extraction and chemical synthesis, as the same are so designated in the
regulations adopted by the Board of Health under 18 V.S.A.§ 4202.
7.0 Hallucinogenic Drugs; Synthetic Cannabinoids; Tryptamines; Cannabinimimetics;
Mescaline Analogs; Dissociatives; Trade or Chemical Name
• 1-(1-Phenylcyclohexyl)pyrrolidine; PCPy; Rolicyclidine
• 1-[1-(2-Thienyl)cyclohexyl]piperidine; TCP; Tenocyclidine
• 1-[1-(2-Thienyl)cyclohexyl]pyrrolidine; TCPy
• 1-Piperidinocyclohexanecarbonitrile; PCC
• 1-(4-methoxybenzoyl)-4-methylpiperazine; MEXP; Methoxypiperamide
• 2,5-dimethoxyamphetamine; 2,5-dimethoxy-a-methylphenethylamin; 2,5 DMA
• 2C-B; 4-bromo-2,5-dimethoxy-benzeneethanamine, monohydrochloride
• 2C-C; 2-(4-Chloro-2,5-dimethoxyphenyl)ethanamine
• 2C-D; 2-(2,5-Dimethoxy-4-methylphenyl)ethanamine
• 2C-E; 2-(2,5-Dimethoxy-4-ethylphenyl)ethanamine
• 2C-H; 2-(2,5-Dimethoxyphenyl)ethanamine
• 2C-I; 2-(4-Iodo-2,5-dimethoxyphenyl)ethanamine
• 2C-N; 2-(2,5-Dimethoxy-4-nitro-phenyl)ethanamine
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Effective Date:7/15/2019
• 2C-P; 2-(2,5-Dimethoxy-4-(n)-propylphenyl)ethanamine
• 2C-T-2; 2-[4-(Ethylthio)-2,5-dimethoxyphenyl]ethanamine
• 2C-T-4; 2-[4-(Isopropylthio)-2,5-dimethoxyphenyl]ethanamine
• 2C-T-7; 2,5-dimethoxy-4-(propylthio)-benzeneethanamine, monohydrochloride
• 2C-TFM-NBOMe; 2-(4-trifluoromethyl-2,5-dimethoxyphenyl)-N-[(2-
methoxyphenyl)methyl]ethanamine
• 2CBCB-NBOMe; N-(2-methoxybenzyl)-1-[(7R)-3-bromo-2,5-
dimethoxybicyclo[4.2.0]octa- 1,3,5-trien-7-yl]methanamine
• 2CBFly-NBOMe; N-(2-Methoxybenzyl)-1-(8-bromo-2,3,6,7-tetrahydrobenzo[1,2-b:4,5-
b’]difuran-4-yl)-2-aminoethane
• 2-Fluorodeschloroketamine; 2-Fl-2'-Oxo-PCM; Fluoroketamine; 2-FDCK
• 2-MeO-ketamine; methoxyketamine; 2-MeO-2-deschloroketamine
• 2-Trifluoromethyldeschloroketamine; 2-TFMDCK; TFM-K
• 3,4,5-trimethoxy amphetamine; TMA; Mescalamphetamine
• 3,4-methylenedioxy amphetamine; MDA
• 3-HO-PCE; 3-[1-(ethylamino)cyclohexyl]phenol; 3-hydroxyethicyclidine
• 3-HO-PCP; 3-Hydroxyphencyclidine
• 3-Methoxyphencyclidine; 3-MeO-PCP; 1-[1-(3-methoxyphenyl)cyclohexyl]-piperidine
• 4-AcO-DET; 3-(2-Diethylaminoethyl)-1H-indol-4-yl acetate; 4-acetoxy-N,N-
diethyltryptamine; Ethacetin
• 4-AcO-DMT; 3-[2-(Dimethylamino)ethyl]-1H-indol-4-yl acetate; 4-acetoxy-N,N-
dimethyltryptamine
• 4-AcO-DPT
• 4-AcO-MET; 3-(2-Ethyl(methyl)aminoethyl)-1H-indol-4-yl acetate
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Effective Date:7/15/2019
• 4-bromo-2, 5-dimethoxyamphetamine; DOB; bromo-DMA
• 4-HO-MET; 3-(2-(ethyl(methyl)amino)ethyl)-1H-indol-4-ol
• 4-HO-MiPT; 3-(2-[Isopropyl(methyl)amino]ethyl)-1H-indol-4-ol; 4-hydroxy-MiPT
• 4-HO-MPMI; (R)-3-(N-methylpyrrolidin-2-ylmethyl)-4-hydoxyindole
• 4-HO-MPT; 3-{2-[methyl(propyl)amino]ethyl}-1H-indol-4-ol
• 4-MeO-AET
• 4-MeO-MiPT
• 4-MeO-PCP; 1-[1-(4-methoxyphenyl)cyclohexyl]-piperidine; 4-Methoxyphencyclidine;
Methoxydine
• 4-methoxyamphetamine; 4-methoxy-a-methylphenethylamine;
paramethoxyamphetamine; PMA; 4-MA
• 4-methyl-2, 5-dimethoxyamphetamine; 4-methyl-2, 5-dimethoxy-a-ethylphenethylamine;
DOM; STP
• 4-methyl-AET
• 5-APB; 5-(2-aminopropyl)benzofuran
• 5-EAPB; 5-(2-Ethylaminopropyl)Benzofuran
• 5F-APICA; N-(adamantan-1-yl)-1-(5-fluoropentyl)-1H-indole-3-carboxamide
• 5F-AMB; 5-fluoro AMP
• 5F-ADBICA; 5-fluoro ADBICA; N-(1-amino-3,3-dimethyl-1-oxobutan-2-yl)-1-(5-
fluoropentyl)-1H-indole-3-carboxamide
• 5F-AKB48; AKB48 N-(5-fluoropentyl) analog; 5f-APINACA; APINACA 5-
fluoropentyl analog; N-((3s,5s,7s)-adamantan-1-yl)-1-(5-fluoropentyl)-1H-indazole-3-
carboxamide
• 5F-MN-018; 5-fluoro MN-18; N-1-naphthalenyl-1-pentyl-1H-indazole-3-carboxamide
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Effective Date:7/15/2019
• 5F-MN24; 5-fluoro NNEI; 1-(5-fluoropentyl)-N-(naphthalen-1-yl)-1H-indole-3-
carboxamide
• 5F-PCN; 1-(5-fluoropentyl)-N-(naphthalen-1-yl)-1H-pyrrolo[3,2-c]pyridine-3-
carboxamide
• 5F-SDB-005; naphthalen-1-yl 1-(5-fluoropentyl)-1H-indazole-3-carboxylate
• 5F-THJ-2201; (1-(5-fluoropentyl)-1H-indazol-3-yl)(naphthalen-1-yl)methanone
• 5FAB-FUBINACA
• 5FAB-PINACA; AB-PINACA 5 fluoro analog; (S)-N-(1-amino-3-methyl-1-oxobutan-
2-yl)-1-(5-fluoropentyl)-1H-indazole-3-carboxamide
• 5FPB22; 5-fluoro PB-22; 5-fluoro QUPIC; 1-(5-fluoropentyl)-8-quinolinyl ester
• Mescaline
• Methoxetamine; MXE; 3-MeO-2-Oxo-PCE; (RS)2-(3-methoxyphenyl)-2-
(ethylamino)cyclohexanone
• MMB-2201; I-AMB; methyl (1-(5-fluoropentyl)-1H-indole-3-carbonyl)-L-valinate
• MMB-CHMINACA; (2S)-methyl-2-(1-(cyclohexylmethyl)-1 H-indol-3-
ylcarbonylamino)-3,3-dimethylbutanoate
• MN-18; N-1-naphthalenyl-1-pentyl-1H-indazole-3-carboxamide
• MN-24; NNEI; N-1-naphthalenyl-1-pentyl-1H-indole-3-carboxamide; AM-6527
• Mitragynine
• Nabilone
• N-ethyl-3 piperidyl benzilate; JB-318
• N-methyl-3-piperidyl benzilate; JB-336Compound 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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