Is MGM-15 (dihydro-7-hydroxymitragynine) Legal in Vermont? (2026)

Instrument

Vermont Regulated Drug Rule mitragynine listing (bare) + hallucinogenic-drug class (no isomer clause)

Source

https://www.healthvermont.gov/sites/default/files/document/reg-regulated-drugs.pdf

Retrieved

2026-07-06

Fingerprint

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Vermont 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.

Instrument

Regulated Drug Rule: definitions and Section 7.0 hallucinogenic drug list

Source

https://healthvermont.gov/file/76941

Retrieved

2026-10-29

Fingerprint

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3.1

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:

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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,

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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

Instrument

Definitions (Analog, Derivative, Hallucinogenic Drug, Narcotic drug); Hallucinogenic drugs list (7-hydroxymitragynine, Mitragynine); statutory hallucinogenic drugs definition

Source

https://healthvermont.gov/file/76941

Retrieved

2026-11-08

Fingerprint

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.

Instrument

Regulated Drug Rule: derivative definition and 7.0 hallucinogenic list (7-hydroxymitragynine, mitragynine)

Source

https://healthvermont.gov/file/76941

Retrieved

2026-10-28

Fingerprint

f7a61e3b28085a75

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,

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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

Page 21 of 35

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-336