Is MGM-16 Legal in Colorado? (2026)

Illegal

As of November 12, 2026, MGM-16 (9-fluoro-dihydro-7-hydroxymitragynine) is illegal to sell (federally scheduled; state law on file reads gray area) in Colorado. Federal Schedule I (DEA temporary order, drug code 9674), effective 2026-08-26 to 2028-08-26. Controlling source: C.R.S. 6-1-740 (Kratom, deceptive trade practice, definitions).

Verified November 12, 2026 (hash check) · confidence: under review

Is MGM-16 Legal? Every state and federal law

Colorado MGM-16 ban status: ban in force

Watchnotice of intent by the DEA (Drug Enforcement Administration), applies to every seller
Federal
Federal Schedule I (DEA temporary order, drug code 9674), effective 2026-08-26 to 2028-08-26 (effective 2026-08-26). State-law reading underneath: Gray area.
Rule type
permanent
Tier
Under review
Effective
2025-05-29

What the record says

Colorado has not scheduled MGM-16 (a fluorinated synthetic analog), 7-hydroxymitragynine, mitragynine or kratom: C.R.S. 18-18-203 lists no kratom alkaloid, and under C.R.S. 18-18-201 the general assembly adds Schedule I substances by bill, so federal scheduling is not adopted automatically. The Daniel Bregger Act (SB 25-072, C.R.S. 6-1-740) makes it a deceptive trade practice to manufacture, package, label or distribute a kratom product that contains synthesized or semi-synthesized alkaloids, and to sell an adulterated kratom product (adulterated includes the addition of a synthesized or semi-synthesized alkaloid). MGM-16 is a fluorinated compound produced by chemical synthesis and fits the 'synthesized alkaloid' definition (an alkaloid derivative created by chemical synthesis); it also fits the semi-synthesized definition where made from a leaf-extract alkaloid. The reach turns on a definition: 'kratom product' is a food or dietary supplement containing kratom leaf, extract, alkaloid, constituent or metabolite 'and does not include any synthesized alkaloids or semi-synthesized alkaloids'. Read one way, a product containing the compound is a prohibited kratom product; read the other way, it falls outside the act's 'kratom product' definition entirely. Because the outcome depends on that reading, the row is restricted and interpretive, not illegal. The act's remedy is the Colorado Consumer Protection Act (civil deceptive trade practice), not a criminal schedule. The age-21 furnishing law (C.R.S. 18-13-132) defines kratom product by reference to leaf or a synthetic material containing mitragynine or 7-hydroxymitragynine, which does not name this compound. No whole-plant ban. The state analog definition (C.R.S. 18-18-102(6)) applies only to analogs of substances in Colorado Schedule I or II, and no kratom alkaloid is listed there. Federal Schedule I (temporary DEA order, DEA-1644) applies regardless of this state row.

Controlling language, verbatim

"Kratom product" means a food or dietary supplement that consists of, or contains, any part of a kratom leaf, a kratom leaf extract, or any kratom alkaloid, kratom constituent, or kratom metabolite and does not include any synthesized alkaloids or semi-synthesized alkaloids. ... “Semi-synthesized alkaloid” means an alkaloid or alkaloid derivative contained in a kratom leaf extract that has been exposed to chemicals or processes that would confer a structural change in the alkaloids, such as oxidation, reduction, and ring opening and closing, resulting in material that has been chemically altered. ... Manufacture, package, label, or distribute a kratom product that: (I) Contains synthesized alkaloids or semi-synthesized alkaloids;

Source of excerpt

Citations

  1. C.R.S. 6-1-740 (Kratom, deceptive trade practice, definitions) (Colorado Office of Legislative Legal Services, 2026-10-28) PRIMARYOFFICIAL
  2. C.R.S. 6-1-740 (added by SB 25-072, enrolled act) PRIMARYOFFICIAL
  3. C.R.S. 18-18-201, 18-18-203 (Schedule I authority and list); 18-13-132 (age 21) (Colorado Office of Legislative Legal Services, 2026-10-28)OFFICIAL

Where MGM-16 (9-fluoro-dihydro-7-hydroxymitragynine) stands across the country

LegalRestrictedGray areaIllegalNot yet verified

Among Colorado’s 7 neighbors, Arizona, Kansas, Nebraska, New Mexico, Oklahoma, Utah and Wyoming are illegal, the same posture as Colorado.

Open the interactive map · Every compound in Colorado · Where MGM-16 is banned · Embed this map

Federal posture

Federally scheduled or prohibited. Federal Schedule I (DEA temporary order, drug code 9674), effective 2026-08-26 to 2028-08-26 Federal detail

Verbatim law on file for Colorado

3 instruments on file for this compound’s framework in Colorado; 3 of 3 citations above are official sources. Each text carries its source and a fingerprint that changes when the law does.

C.R.S. 6-1-740 (added by SB 25-072, enrolled act) · Kratom - deceptive trade practice - definitionsOFFICIAL
Instrument
Kratom - deceptive trade practice - definitions
Source
https://content.leg.colorado.gov/sites/default/files/documents/2025A/bills/2025a_072_enr.pdf
Retrieved
2026-10-29
Fingerprint
e701a4b0a1b202e9
6-1-740.  Kratom - deceptive trade practice - definitions. (1)  AS

USED IN THIS SECTION, UNLESS THE CONTEXT OTHERWISE REQUIRES:

(a)  "ADULTERATED" MEANS THE ADDITION OF FENTANYL OR ANY
OTHER  CONTROLLED  SUBSTANCE,  A  SYNTHESIZED  ALKALOID  OR
SEMI-SYNTHESIZED  ALKALOID,  OR  ANOTHER  SUBSTANCE  PROHIBITED  BY
LAW.

________
Capital letters or bold & italic numbers indicate new material added to existing law; dashes
through words or numbers indicate deletions from existing law and such material is not part of
the act.

(b)  “ALKALOID FRACTION” MEANS A PORTION OF A PLANT OR PLANT

EXTRACT THAT CONTAINS PRIMARILY ALKALOID COMPOUNDS.

(c)  “CONTROLLED SUBSTANCE” MEANS A SUBSTANCE LISTED IN PART

2 OF ARTICLE 18 OF TITLE 18.

(d)  “KRATOM LEAF” MEANS THE LEAF OF THE MITRAGYNA SPECIOSA

PLANT, IN FRESH, DEHYDRATED, OR DRIED FORM.

(e)  "KRATOM LEAF EXTRACT" MEANS THE MATERIAL EXTRACTED
FROM  A  KRATOM  LEAF  THROUGH  THE  APPLICATION  OF  A  SOLVENT
CONSISTING  OF  WATER,  ETHANOL,  FOOD-GRADE  CARBON  DIOXIDE,  OR
ANOTHER SOLVENT ALLOWED BY FEDERAL OR STATE LAW TO BE USED IN THE
MANUFACTURING OF A FOOD INGREDIENT.

(f)  "KRATOM PRODUCT" MEANS A FOOD OR DIETARY SUPPLEMENT
THAT CONSISTS OF, OR CONTAINS, ANY PART OF A KRATOM LEAF, A KRATOM
LEAF  EXTRACT,  OR  ANY  KRATOM  ALKALOID,  KRATOM  CONSTITUENT,  OR
KRATOM  METABOLITE  AND  DOES  NOT  INCLUDE  ANY  SYNTHESIZED
ALKALOIDS OR SEMI-SYNTHESIZED ALKALOIDS.

(g)    “SEMI-SYNTHESIZED  ALKALOID”  MEANS  AN  ALKALOID  OR
ALKALOID DERIVATIVE CONTAINED IN A KRATOM LEAF EXTRACT THAT HAS
BEEN  EXPOSED  TO  CHEMICALS  OR  PROCESSES  THAT  WOULD  CONFER  A
STRUCTURAL CHANGE IN THE ALKALOIDS, SUCH AS OXIDATION, REDUCTION,
AND RING OPENING AND CLOSING, RESULTING IN MATERIAL THAT HAS BEEN
CHEMICALLY ALTERED.

(h)  "SYNTHESIZED ALKALOID" MEANS AN ALKALOID OR ALKALOID
DERIVATIVE OF THE KRATOM LEAF THAT HAS BEEN CREATED BY CHEMICAL
SYNTHESIS  OR  BIOSYNTHETIC  MEANS,
INCLUDING  FERMENTATION,
RECOMBINANT TECHNIQUES, YEAST-DERIVED TECHNIQUES, AND ENZYMATIC
TECHNIQUES,  RATHER  THAN  BY  TRADITIONAL  FOOD  PREPARATION
TECHNIQUES SUCH AS HEATING OR EXTRACTING.

(2)  A PERSON SHALL NOT:

(a)  KNOWINGLY PREPARE, DISTRIBUTE, ADVERTISE, SELL, OR OFFER

TO SELL A KRATOM PRODUCT:

PAGE 2-SENATE BILL 25-072

(I)  THAT IS ADULTERATED;

(II)  TO A PERSON UNDER TWENTY-ONE YEARS OF AGE;

(III)  THAT CONTAINS A LEVEL OF 7-HYDROXYMITRAGYNINE IN THE
ALKALOID  FRACTION  THAT  IS  GREATER  THAN  TWO  PERCENT  OF  THE
ALKALOID COMPOSITION OF THE KRATOM PRODUCT;

(IV)    THAT  IS  A  CONFECTION;  MIMICS  A  CANDY  PRODUCT;  OR  IS
MANUFACTURED, PACKAGED, LABELED, OR DISTRIBUTED IN A WAY THAT IS
APPEALING TO CHILDREN, INCLUDING IN THE DISTINCT SHAPE OF A HUMAN,
AN ANIMAL, OR FRUIT; OR

(V)  THAT IS COMBUSTIBLE OR INTENDED FOR VAPORIZATION;

(b)  PREPARE, DISTRIBUTE, ADVERTISE, SELL, OR OFFER TO SELL A
KRATOM  PRODUCT  THAT  DOES  NOT  HAVE  A  LABEL  THAT  CLEARLY  AND
CONSPICUOUSLY SETS FORTH ON EACH RETAIL PACKAGE:

(I)  THE NAME AND ADDRESS FOR THE PLACE OF BUSINESS OF THE

MANUFACTURER OR DISTRIBUTOR OF THE KRATOM PRODUCT;

(II)  THE FULL LIST OF INGREDIENTS IN THE KRATOM PRODUCT;

(III)  DISCLOSURE AND ADVICE:

(A)  AGAINST USE BY INDIVIDUALS WHO ARE UNDER TWENTY-ONE

YEARS OF AGE, PREGNANT, OR BREASTFEEDING;

(B)  TO CONSULT A HEALTH-CARE PROFESSIONAL PRIOR TO USE;

(C)  THAT KRATOM MAY BE HABIT FORMING; AND

(D)    THAT  KRATOM  MAY  INTERACT  WITH  CERTAIN  MEDICATIONS,

DRUGS, AND CONTROLLED SUBSTANCES;

(IV)  THE FOLLOWING STATEMENTS:

(A)  "THESE STATEMENTS HAVE NOT BEEN EVALUATED BY THE FOOD
AND DRUG ADMINISTRATION. THIS PRODUCT IS NOT INTENDED TO DIAGNOSE,

PAGE 3-SENATE BILL 25-072

TREAT, CURE, OR PREVENT ANY DISEASE."; AND

(B)  “KEEP OUT OF REACH OF CHILDREN.”; AND

(V)  DIRECTIONS FOR USE THAT INCLUDE:

(A)    A  RECOMMENDED  AMOUNT  OF  THE  KRATOM  PRODUCT  PER

SERVING;

(B)  THE NUMBER OF RECOMMENDED SERVINGS PER PACKAGE;

(C)    A  RECOMMENDED  NUMBER  OF  SERVINGS  OF  THE  KRATOM
PRODUCT  THAT  CAN  BE  SAFELY  CONSUMED  IN  A  TWENTY-FOUR-HOUR
PERIOD; AND

(D)

  QUANTITATIVE  DECLARATIONS  OF  THE  AMOUNT  OF
MITRAGYNINE AND THE AMOUNT OF 7-HYDROXYMITRAGYNINE PER SERVING
OF THE KRATOM PRODUCT;

(c)  DISPLAY OR STORE KRATOM PRODUCTS IN A RETAIL LOCATION IN
A  MANNER  THAT  WILL  ALLOW  THE  PRODUCTS  TO  BE  ACCESSED  BY
INDIVIDUALS UNDER TWENTY-ONE YEARS OF AGE; OR

(d)  MANUFACTURE,  PACKAGE,  LABEL,  OR  DISTRIBUTE  A  KRATOM

PRODUCT THAT:

(I)    CONTAINS  SYNTHESIZED  ALKALOIDS  OR  SEMI-SYNTHESIZED

ALKALOIDS; OR

(II)  HAS A LEVEL  OF 7-HYDROXYMITRAGYNINE IN THE ALKALOID
FRACTION  THAT  IS  GREATER  THAN  TWO  PERCENT  OF  THE  ALKALOID
COMPOSITION OF THE PRODUCT.

(3)    A  PERSON  THAT  CONDUCTS  THE  ACTIVITIES  DESCRIBED  IN
SUBSECTION (2) OF THIS SECTION ENGAGES IN A DECEPTIVE TRADE PRACTICE.
C.R.S. 6-1-740; C.R.S. 18-13-132 · Kratom - deceptive trade practice - definitions; Furnishing kratom products to persons under twenty-one years of age - definitionOFFICIAL
Instrument
Kratom - deceptive trade practice - definitions; Furnishing kratom products to persons under twenty-one years of age - definition
Source
https://olls.info/crs/crs2026-title-06.htm
Retrieved
2026-11-08
Fingerprint
5f387c26e7fb1b8e
6-1-740.

Kratom - deceptive trade
practice - definitions.

(1) As
used in this section, unless the context otherwise requires:

(a)
"Adulterated" means the addition of fentanyl or any other controlled
substance, a synthesized alkaloid or semi-synthesized alkaloid, or another
substance prohibited by law.

(b)
“Alkaloid fraction” means a portion of a plant or plant extract that
contains primarily alkaloid compounds.

(c)
“Controlled substance” means a substance listed in part 2 of article
18 of title 18.

(d)
“Kratom leaf” means the leaf of the Mitragyna speciosa plant, in
fresh, dehydrated, or dried form.

(e)
"Kratom leaf extract" means the material extracted from a kratom leaf
through the application of a solvent consisting of water, ethanol, food-grade
carbon dioxide, or another solvent allowed by federal or state law to be used
in the manufacturing of a food ingredient.

(f)
"Kratom product" means a food or dietary supplement that consists of,
or contains, any part of a kratom leaf, a kratom leaf extract, or any kratom
alkaloid, kratom constituent, or kratom metabolite and does not include any
synthesized alkaloids or semi-synthesized alkaloids.

(g)
“Semi-synthesized alkaloid” means an alkaloid or alkaloid derivative
contained in a kratom leaf extract that has been exposed to chemicals or
processes that would confer a structural change in the alkaloids, such as
oxidation, reduction, and ring opening and closing, resulting in material that
has been chemically altered.

(h)
"Synthesized alkaloid" means an alkaloid or alkaloid derivative of
the kratom leaf that has been created by chemical synthesis or biosynthetic
means, including fermentation, recombinant techniques, yeast-derived
techniques, and enzymatic techniques, rather than by traditional food
preparation techniques such as heating or extracting.

(2) A
person shall not:

(a)
Knowingly prepare, distribute, advertise, sell, or offer to sell a kratom
product:

(I)
That is adulterated;

(II) To
a person under twenty-one years of age;

(III)
That contains a level of 7-hydroxymitragynine in the alkaloid fraction that is
greater than two percent of the alkaloid composition of the kratom product;

(IV)
That is a confection; mimics a candy product; or is manufactured, packaged,
labeled, or distributed in a way that is appealing to children, including in
the distinct shape of a human, an animal, or fruit; or

(V)
That is combustible or intended for vaporization;

(b)
Prepare, distribute, advertise, sell, or offer to sell a kratom product that
does not have a label that clearly and conspicuously sets forth on each retail
package:

(I) The
name and address for the place of business of the manufacturer or distributor
of the kratom product;

(II)
The full list of ingredients in the kratom product;

(III)
Disclosure and advice:

(A)
Against use by individuals who are under twenty-one years of age, pregnant, or
breastfeeding;

(B) To
consult a health-care professional prior to use;

(C)
That kratom may be habit-forming; and

(D)
That kratom may interact with certain medications, drugs, and controlled
substances;

(IV)
The following statements:

(A)
"These statements have not been evaluated by the food and drug
administration. This product is not intended to diagnose, treat, cure, or
prevent any disease."; and

(B)
“Keep out of reach of children.”; and

(V)
Directions for use that include:

(A) A
recommended amount of the kratom product per serving;

(B) The
number of recommended servings per package;

(C) A recommended
number of servings of the kratom product that can be safely consumed in a
twenty-four-hour period; and

(D)
Quantitative declarations of the amount of mitragynine and the amount of
7-hydroxymitragynine per serving of the kratom product;

(c)
Display or store kratom products in a retail location in a manner that will
allow the products to be accessed by individuals under twenty-one years of age;
or

(d)
Manufacture, package, label, or distribute a kratom product that:

(I)
Contains synthesized alkaloids or semi-synthesized alkaloids; or

(II)
Has a level of 7-hydroxymitragynine in the alkaloid fraction that is greater
than two percent of the alkaloid composition of the product.

(3) A
person that conducts the activities described in subsection (2) of this section
engages in a deceptive trade practice.

18-13-132.

Furnishing kratom products
to persons under twenty-one years of age - definition.

(1) (a)
A person shall not give, sell, distribute, dispense, or offer for sale a kratom
product to any person who is under twenty-one years of age.

(b)
Before giving, selling, distributing, dispensing, or offering to sell to an
individual any kratom product, a person shall request from the individual and
examine a government-issued photographic identification that establishes that
the individual is twenty-one years of age or older.

(c) A
person who violates subsection (1)(a) or (1)(b) of this section commits a civil
infraction and, upon conviction thereof, shall be punished by a fine of two
hundred dollars, notwithstanding the provisions of section 18-1.3-503.

(d) It
is an affirmative defense to a prosecution under subsection (1)(a) of this
section that the person furnishing the kratom product was presented with and
reasonably relied upon a government-issued photographic identification that
identified the individual receiving the kratom product as being twenty-one
years of age or older.

(2) (a)
Nothing in this section prohibits a statutory or home rule municipality,
county, or city and county from enacting an ordinance or resolution that
prohibits the sale of any kratom products to persons under twenty-one years of
age or imposes requirements more stringent than provided in this section.

(b) A
statutory or home rule municipality, county, or city and county shall not enact
an ordinance or resolution that establishes a minimum age to purchase kratom
products that is under twenty-one years of age.

(3) As
used in this section, "kratom product" means any product or
ingredient containing:

(a) Any
part of the leaf of the Mitragyna speciosa plant if the plant contains the
alkaloid mitragynine or 7-hydroxymitragynine; or

(b) A
synthetic material that contains the alkaloid mitragynine or
7-hydroxymitragynine.
C.R.S. Sec. 6-1-737 (Daniel Bregger Act) · CO KCPA - 2% 7-OH cap, synthetic/semi-synthetic ban, age 21, labeling, no vape/candyOFFICIAL
Instrument
CO KCPA - 2% 7-OH cap, synthetic/semi-synthetic ban, age 21, labeling, no vape/candy
Source
https://leg.colorado.gov/bills/sb25-072
Retrieved
2026-07-07
Fingerprint
336f0b85d37da43f
6-1-737. Kratom - deceptive trade practice - definitions. (1) Definitions: "adulterated" = addition of fentanyl or any other controlled substance, a synthesized or semi-synthesized alkaloid, or another prohibited substance; "kratom product" = a food or dietary supplement that consists of or contains any part of a kratom leaf, a kratom leaf extract, or any kratom alkaloid/constituent/metabolite and does not include any synthesized or semi-synthesized alkaloids; “semi-synthesized alkaloid” = an alkaloid ... exposed to chemicals or processes that would confer a structural change ... such as oxidation, reduction, and ring opening and closing ...; "synthesized alkaloid" = created by chemical synthesis or biosynthetic means ... (2) A person shall not: (a) knowingly prepare, distribute, advertise, sell, or offer to sell a kratom product: (I) that is adulterated; (II) to a person under twenty-one years of age; (III) that contains a level of 7-hydroxymitragynine in the alkaloid fraction that is greater than two percent of the alkaloid composition of the kratom product; (IV) that is a confection; mimics a candy product; or is ... appealing to children ...; or (V) that is combustible or intended for vaporization; (b) [labeling requirements incl. quantitative declarations of mitragynine and 7-OH per serving]; (c) display/store accessible to under-21; or (d) manufacture/package/label/distribute a kratom product that: (I) contains synthesized or semi-synthesized alkaloids; or (II) has a level of 7-hydroxymitragynine in the alkaloid fraction greater than two percent of the alkaloid composition. (3) [violation = deceptive trade practice]. Companion: 18-13-132 (furnishing to under-21).

MGM-16 (9-fluoro-dihydro-7-hydroxymitragynine) in neighboring states

MGM-16 in 43 other states

Closest to MGM-16 in Colorado

36 other compounds in Colorado

Cite this page

Compound Analytics. “Is MGM-16 Legal in Colorado? Updated Nov 2026.” Compound Laws, https://compoundlaws.com/compounds/mgm-16/colorado/. 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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