Walk into most smoke shops in Santa Fe or Albuquerque and you’ll find two very different products sitting side by side, both labeled “kratom.” One is a bag of ground leaf powder — the dried leaf of a Southeast Asian tree that farmers in Thailand have chewed for centuries to get through long days of work. The other is a small liquid shot, neon-labeled, advertising relaxation and relief, containing a concentrated synthetic compound manufactured in a laboratory. Regulators — including those in New Mexico — have been treating them as the same thing. They are not.
This conflation is not a minor technicality. It is the reason policy in New Mexico, and across the country, keeps getting the answer wrong.
The Leaf and the Lab Product
Natural kratom leaf contains more than 40 alkaloids. The dominant one is mitragynine, which makes up roughly 2–6% of dried leaf weight. Mitragynine is a partial agonist at the mu-opioid receptor — meaning it activates the receptor that manages pain and mood, but does so with what researchers call a “ceiling effect,” limiting the degree of respiratory depression associated with conventional opioids. A 2021 peer-reviewed study published in ACS Central Science by Dr. Christopher McCurdy’s team at the University of Florida found that 7-hydroxymitragynine — a metabolite present in dried leaves in trace amounts, less than 2% of total alkaloid content — is the compound that mediates much of kratom’s analgesic effect.
The problem is not 7-OH in trace amounts from the natural leaf. The problem is manufactured 7-OH. Companies purchase bulk purified mitragynine — legally available from international chemical suppliers — and apply a hydroxyl group in a laboratory to produce semi-synthetic 7-OH at concentrations that have no analog in nature. Dr. David Kroll, director of the pharmacy program at the University of Colorado’s Anschutz campus, described it plainly: these products are “five to fifty times more potent on the brain than mitragynine as an opioid receptor agonist.” A 2025 pharmacological study published on bioRxiv found that 7-OH — unlike mitragynine — fully substitutes for morphine in drug discrimination assays and demonstrates reinforcing effects consistent with opioid drugs. Mitragynine did not.
McCurdy himself, in a 2025 appearance on the Huberman Lab podcast, drew the line clearly: 7-OH is not kratom. It is a semi-synthetic opioid that happens to be derived from a kratom alkaloid.
What New Mexico’s Regulators Got Wrong
When Albuquerque’s Environmental Health Department swept more than 50 retail locations in fall 2025 and seized 5,400-plus products, it cited FDA guidance that kratom is not a recognized safe food ingredient. When the New Mexico Environment Department issued its December 2025 statewide ban on kratom in food and beverages, it cited the same framework. Attorney General Raúl Torrez’s November 2025 consumer warning leaned on DEA and FDA language that dates to 2021 and 2022 — before the FDA’s own position shifted in response to new dosage research on natural leaf kratom.
None of these actions specified synthetic 7-OH. They targeted kratom — the leaf, the powder, the tea — as a monolith. Users who relied on natural, tested kratom powder to manage opioid withdrawal, chronic pain, or anxiety suddenly faced the same enforcement action as retailers selling laboratory-manufactured opioid shots at convenience stores. That is a scientific error with real human consequences.
On Reddit’s kratom communities — which a 2021 NIH-funded study analyzed as one of the largest existing datasets of real-world kratom experience — users describe this gap with consistent frustration. One post cited in that peer-reviewed study reads: “The alkaloid profiles won’t match up name for name with most kratom I could buy right now. If I were to buy these exact names from a random vendor online or in a store then run the same test, it would probably be very different alkaloid profiles. Very frustrating fact of the kratom market.” That frustration is precisely what the KCPA’s lab testing and labeling requirements are designed to solve.
The Policy Answer Already Exists
More than 30 states have addressed this by passing the Kratom Consumer Protection Act, which explicitly bans adulterated products including synthetic 7-OH concentrates, while requiring lab testing and labeling for natural kratom. Arizona’s version limits 7-hydroxymitragynine content to under 2% — essentially requiring that products contain only what the natural leaf would contain. That is not a ban. It is a science-based line between a traditional botanical and a manufactured drug.
New Mexico has not drawn that line. Until it does, its regulators will keep banning the wrong thing — or everything — while the actual problem product continues to be manufactured and distributed elsewhere.
Frequently Asked Questions
Is 7-OH naturally present in kratom?
Yes, in trace amounts. Research from the University of Florida confirms that 7-hydroxymitragynine appears in dried kratom leaf at less than 2% of total alkaloid content. The concern is concentrated synthetic 7-OH, which is manufactured by chemically modifying mitragynine in a laboratory to produce opioid potency that has no equivalent in the natural leaf.
Is natural kratom an opioid?
Mitragynine is a partial agonist at mu-opioid receptors — meaning it interacts with the same receptors as opioids but with different pharmacological behavior, including a ceiling on respiratory depression. Researchers at the University of Florida and elsewhere describe it as having a distinct pharmacological profile from conventional opioids. Synthetic 7-OH, by contrast, fully substitutes for morphine in animal studies and demonstrates reinforcing properties consistent with opioid drugs.
Why did New Mexico’s regulators ban natural kratom too?
New Mexico’s actions were based on FDA guidance classifying kratom as an unapproved food ingredient — a regulatory category that doesn’t distinguish between natural leaf products and synthetic concentrates. The KCPA framework exists precisely to make this distinction in law. New Mexico has not adopted it.
What does “semi-synthetic” mean in this context?
Semi-synthetic means the compound starts with a natural substance — purified mitragynine — and is then chemically altered in a lab to produce a different compound: 7-hydroxymitragynine. This is the same basic process used to produce many pharmaceutical opioids. The result is a drug that does not exist in meaningful concentrations in the natural plant.
Sources
- ACS Central Science, McCurdy et al. — 7-Hydroxymitragynine as Active Metabolite (2019): pubs.acs.org
- bioRxiv — Mitragynine and 7-OH Bidirectional Breathing Effects in Rats (2025): biorxiv.org
- Super Speciosa — Kratom vs. 7-OH: Understanding the Difference (October 2025): superspeciosa.com
- University of Florida College of Pharmacy, McCurdy Kratom Research: csp.pharmacy.ufl.edu
- NIH/PMC — Reddit Kratom User Analysis (2021): pmc.ncbi.nlm.nih.gov/articles/PMC8355181
- Wikipedia, 7-Hydroxymitragynine pharmacology: en.wikipedia.org
- New Mexico Environment Department, Food Ban (December 2025): env.nm.gov
- NMDOJ, AG Torrez Consumer Warning (November 2025): nmdoj.gov