The Board
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Index
Every card on the board
The same record as the board above, as a list. Each card carries its label and sources. The colored bar on a source tells you what kind of record it is.
- Federal Register or court
- Disclosure filing
- Official statement
- Patent
- Reported
- Own statement or denied
- Study or data
The leaf
A tree in the coffee family, used for generations in Southeast Asia.
Chewed and brewed for generations
Mitragyna speciosa grows in Thailand, Malaysia and Indonesia. Workers there have chewed the fresh leaf or brewed it as tea for generations.
- Minor alkaloid to 7-OH is in the leaf
Thailand bans the leaf
Thailand's Kratom Act of 1943 made it illegal to plant the tree. The ban stayed on the books for most of a century.
- Reversed to Thailand makes it legal again
7-OH is in the leaf
7-hydroxymitragynine was identified in kratom leaf in 1994. It is a minor alkaloid there, about 0.01 to 0.04% of the leaf by FDA's own figures.
Thailand makes it legal again
Thailand took kratom off its narcotics list in 2021. The country that banned it first is now selling it again.
The 2016 fight
DEA tried this once before. It backed down in six weeks.
DEA moves to schedule kratom
DEA published a notice of intent to put mitragynine and 7-OH in Schedule I on an emergency basis. Its record then cited about 30 deaths and 720 seizure reports.
- Withdrawn to DEA backs down
Congress pushes back
51 members of the House, 22 of them Republicans, led by Mark Pocan and Matt Salmon, wrote DEA on Sept 26, 2016, asking it to delay and take public comment first.
- Pushback to DEA moves to schedule kratom
DEA backs down
Six weeks later DEA withdrew the notice and opened a comment period instead.
HHS pulls its recommendation
HHS's assistant secretary for health, Brett Giroir, wrote DEA withdrawing the department's recommendation to schedule kratom.
- HHS follows to DEA backs down
The trade group
The American Kratom Association and the man who lobbies for it.
American Kratom Association
The main kratom trade association. It reported $4,700,427 in revenue for 2024.
- $708,000 Lobbying fees to Upstream (our tally), 2017 to 2020 to Mac Haddow, AKA's lobbyist
- Label deal, per AKA to AKA and HART agree on labels
- Backs scheduling 7-OH to AKA backs scheduling 7-OH
- Plaintiff to AKA sues DEA
Mac Haddow, AKA's lobbyist
Listed on Upstream Consulting's federal lobbying filings for AKA from 2017. Those filings disclose his 1987 conviction. He is AKA's senior fellow on public policy.
- Registered lobbyist to American Kratom Association
CPSH pays Haddow's firm
The Center for Plant Science and Health paid $246,000 to HPNA, Haddow's firm, its top contractor for 2019.
- $246,000 Foundation contract to HPNA, 2019 to Mac Haddow, AKA's lobbyist
$708,000 to Upstream
Our tally of AKA's lobbying payments to Upstream, from the federal filings with amendments applied: $251,000, $157,000, $150,000 and $150,000. Courthouse News reported a higher figure.
The split
Leaf sellers turned on each other over 7-OH.
Global Kratom Coalition
A leaf-industry coalition led by Matthew Lowe. Its 2024 tax return reports $3,431,756 in revenue and $683,500 in grants.
- Praised the suit to GKC thanks Missouri
AKA names Ross as GKC's founder
AKA's chairman identified Jerry W. Ross, founder of Botanic Tonics, as the founder of the Global Kratom Coalition.
GKC hits AKA from the right
GKC accused AKA of going soft on 7-OH. AKA answered three days later.
- Press war to American Kratom Association
AKA and HART agree on labels
AKA described an agreement with HART to separate products by labeling. AKA says it never endorsed isolates sold as kratom.
Ross sues AKA
According to AKA's own release, Ross sued AKA, the Center for Plant Science and Health, and Haddow over donations and Utah's delisting of Feel Free.
- Suit, per AKA to American Kratom Association
AKA backs scheduling 7-OH
The same day DEA announced its plans, AKA publicly supported scheduling concentrated 7-OH. The leaf's own trade group asked for its competitor to be scheduled.
GKC thanks Missouri
Missouri's attorney general sued to stop "any kratom product," leaf included. GKC praised the suit as aligned with "the federal distinction."
- Same suit to Missouri reaches the leaf
The patents
Who is filing claims on kratom chemistry.
atai buys into Kures
atai took a majority stake in Kures, which was developing KUR101, a kratom-related drug candidate. Kures wound down in 2024 and its Columbia license ended.
- Rights went back to Columbia to Lilly bought atai, not kratom
$19.5M NIH grant for SBS-226
Sparian Biosciences announced a five-year NIH grant to develop SBS-226, related to kratom chemistry, for opioid-use disorder and withdrawal.
Botanic Tonics gets a patent
US 12,419,927: kava CO2 extract plus ground kratom leaf. The leaf company holds a patent on its own kava and kratom formula.
More filings in line
Published applications from Singularity Pharma (alkaloid analogs), Mitradyne (enzyme-based production) and Shaman Pharma (derivative manufacturing).
Sloan Kettering's mitragynine analogs
Memorial Sloan Kettering was granted a patent on mitragynine analogs.
CaamTech claims purified 7-OH
A published CaamTech application claims a 7-OH formulation free of mitragynine.
Lilly bought atai, not kratom
Lilly closed its purchase of atai for its depression programs. The Kures kratom rights had already gone back to Columbia in 2024.
The money
One leaf company, its founder and the campaign tied to them.
Botanic Tonics (Feel Free)
Sells Feel Free, a kava and kratom leaf drink. It says annual sales passed $250 million in more than 30,000 stores. Those are its own figures.
- Exempt offering to $25 million raised
- $500,000 Company receipt, Mar 4, 2026 to MAHA PAC
- $500,000 Company receipt, Apr 9, 2026 to MAHA PAC
- $8.75M Class settlement, Settlement to Torres v. Botanic Tonics
- Patent holder to Botanic Tonics gets a patent
- Forfeiture case to Federal case dropped
- Defendant to Arizona v. Botanic Tonics
Jerry W. Ross
Founded Botanic Tonics and is listed on its SEC filing as a director or manager. His direct political giving totals $182,607.34.
- Director or manager to Botanic Tonics (Feel Free)
- Founder, per AKA to Global Kratom Coalition
- Allies set it up (NYT) to Stop Gas Station Heroin LLC
- Partner (attributed) to Hydra623 Holdings
- Former name (Carney) to Formerly Jerry Cash
- $6,600 To Team Kennedy, Sept 19, 2023 to Kennedy committees
- $161,800 To Kennedy Victory Fund, Jan 2 and Feb 5, 2025 to Kennedy committees
Kennedy committees
Team Kennedy and Kennedy Victory Fund, political committees for Robert F. Kennedy Jr. Not HHS.
- RFK Jr. called Ohio to Ohio pauses its ban
Formerly Jerry Cash
Reporter Scott Carney says Ross confirmed he was Jerry Cash, an Oklahoma energy executive sentenced in 2010 to 108 months for diverting about $10 million from Quest Energy.
$25 million raised
Botanic Tonics sold $25 million in an exempt offering to 30 investors. That is financing, not sales. Revenue: "Decline to Disclose."
Ohio pauses its ban
Ohio canceled a pharmacy-board meeting on kratom. Governor DeWine acknowledged contact from Robert F. Kennedy Jr.
Federal case dropped
FDA seized more than 250,000 Feel Free units in April 2023. The government dismissed the forfeiture case in December 2025. A dismissal is not a finding that the product is safe.
Matthew Lowe
Executive director of Stop Gas Station Heroin LLC, per its launch release. He also leads the Global Kratom Coalition. Same man runs both.
- Leads to Global Kratom Coalition
- Executive director to Stop Gas Station Heroin LLC
Stop Gas Station Heroin LLC
A campaign company that targets concentrated products and defends natural botanicals. The New York Times reported that Ross's allies set it up.
What we thinkIt calls itself a coalition. It is an LLC, and its money trail ends at a lobbying firm.
- $750,000 Lobbying fees, Q3 2025 to Q2 2026 to Checkmate
- Same name to The End Gas Station Heroin Act
Checkmate
Reported $750,000 in lobbying income from Stop Gas Station Heroin LLC: $150,000, $300,000, $150,000 and $150,000 by quarter.
MAHA PAC
Make America Healthy Again PAC. It booked Botanic Tonics' $1 million as "Other Federal Receipts," so its contribution line reads $0.00.
Hydra623 Holdings
Ross's holding partnership. FEC memo entries attribute $443,000 of its RNC money to him as a partner. That is an attribution, not a second check.
- FEC image 202603209853749439
- FEC image 202603209853749438
- FEC image 202603209853743128
- California SoS, Hydra623 Holdings
- $443,000 Attributed to Ross, Feb 17, 2026 to Republican National Committee
Republican National Committee
Received $443,000 from Hydra623 on February 17, 2026.
Markwayne Mullin
Homeland Security secretary since March 2026. His disclosure lists Botanic Tonics at $500,001 to $1 million. His ethics agreement lists 62 stocks and 19 bonds to sell. Botanic Tonics is not one of them.
What we thinkDEA sits in the Justice Department, not his. A cabinet officer holding a stake in the leaf company is still worth asking about.
- $500,001 to $1M Disclosed stake, 2026 disclosure to Botanic Tonics (Feel Free)
Senate Finance asks
Ranking member Ron Wyden's letters ask when Mullin bought in and which other officials hold stakes.
- Asks about the stake to Markwayne Mullin
No drug company in the lobbying record
We read 302 federal lobbying filings that mention kratom. None names a pharmaceutical client or registrant.
The ban network
The groups asking for all of it to go.
Smart Approaches to Marijuana
Asked for Schedule I treatment of all kratom on August 5, 2025.
- Denies drug money to SAM says no drug money
Kevin Sabet
Leads SAM and FDPS.
- Leads to Smart Approaches to Marijuana
- Leads to Foundation for Drug Policy Solutions
- Testified to Grassley and Sabet, 2013
Patrick J. Kennedy
Former congressman. SAM and FDPS name him as a co-founder. Not the same person as Robert F. Kennedy Jr.
- Co-founder to Smart Approaches to Marijuana
- Co-founder to Foundation for Drug Policy Solutions
- Board since 2017 to Braeburn
Grassley and Sabet, 2013
Sabet testified before Senate Judiciary in 2013. SAM says it helped draft bills Grassley cosponsored.
- 2013 hearing to Grassley: all of it off the shelves
Braeburn
Patrick J. Kennedy joined Braeburn's board on December 12, 2017. Braeburn sells Brixadi, a buprenorphine injection for opioid-use disorder.
What we thinkOne camp sells a shot with kratom in it. A founder of the other sits on the board of a company that sells a buprenorphine shot.
Foundation for Drug Policy Solutions
Runs the Ban Kratom Now petition. Says it shares staff with SAM.
- $55,194 To Sabet's firms, 2024 to Kevin Sabet
- Says it helped draft to "We helped draft it"
- HHS comment to FDPS wants mitragynine too
- Council to Treatment businesses at the table
- Cites 5,208 to The 5,208 figure
FDPS paid Sabet's firms
$55,194 to LUA Partners and Policy Solutions Group, Sabet's firms, about 18% of its spending. It reported zero employees and paid Luke Niforatos $117,987. It checked "No" on lobbying.
The AMA's model bill
Would ban human-use kratom products without FDA approval. The AMA's own policy says personal use shouldn't be a crime.
SAM says no drug money
"SAM does not take money from the alcohol, tobacco, pharmaceutical, or marijuana industries." No payment record shows Braeburn funding the ban campaign.
"We helped draft it"
FDPS says it helped draft the eleven senators' March letter. The Senate release doesn't credit it.
- The letter to Eleven senators want the leaf
FDPS wants mitragynine too
Its comment to HHS asks for 7-OH with no threshold, plus mitragynine, the leaf's main alkaloid.
Treatment businesses at the table
FDPS's leadership council includes people from addiction-treatment businesses and law enforcement.
End Kratom Addiction
Advisers include Michelle Siwek, who owns Scottsdale Recovery Center. Reporting says Bob Good LLC lobbies for it.
The agencies
FDA, HHS and DEA, in their own words.
"Gas station heroin" was tianeptine
FDA used the phrase for tianeptine, an unapproved antidepressant. Tianeptine is not kratom.
- Borrowed slogan to The End Gas Station Heroin Act
FDA targets concentrated 7-OH
FDA recommended scheduling for concentrated 7-OH products, not the leaf.
- Leads to notice to DEA's 7-OH notice
Ohio goes after mitragynine
Ohio's pharmacy board voted 8-0 to move ahead with a proposal to schedule mitragynine, the leaf's main alkaloid.
"Not the leaf," three times
HHS (July 1), FDA (July 13) and DOJ (August 25) each said the action wasn't aimed at natural leaf.
- Then: no threshold to The order that did issue
- Senators ask for the leaf to Eleven senators want the leaf
DEA's 7-OH notice
A notice of intent to schedule 7-OH above a threshold. A notice is not an order. No 7-OH order has been published.
- Same notice to DEA admits there's no number
- Same notice to 55 fatal cases with 7-OH found
- Same day to More than 30,000 comments
DEA admits there's no number
DEA's own notice says the "safety profile" of 7-OH "remains unknown." The bills still set a line at 1 milligram.
55 fatal cases with 7-OH found
DEA's notice cites 55 fatal cases where 7-OH was found, out of 85 selected cases since 2019. DEA says the samples often held other drugs too, fentanyl among them, and that 7-OH is also a metabolite of mitragynine.
What we thinkFound is not caused. These cases argue for testing and a dose on the label, not a ban.
More than 30,000 comments
HHS asked the public about 7-OH. More than 30,000 comments were published, most from ordinary people.
The order that did issue
Temporary Schedule I for mitragynine pseudoindoxyl, MGM-15 and MGM-16. Separate compounds, not 7-OH, and no threshold.
AKA sues DEA
AKA filed suit against DEA in federal court in Washington, case 1:26-cv-02997.
The bills
Congress, statehouses and attorneys general.
The End Gas Station Heroin Act
S.5383 (Sen. Bernie Moreno) and H.R.10272 (Rep. Lance Gooden) share a short title. Products stay exempt under 1 mg of 7-OH per gram and 1 part 7-OH per 100 parts mitragynine.
What we thinkThe name is the lobbying campaign's brand. The exemption protects the leaf company's product and knocks out its concentrated competitors.
- Bill text to The bills protect possession
- House version to The bill came before the deaths
The bills protect possession
Both bills say no person may be prosecuted "solely for simple possession." Even the sponsors don't want users jailed.
The bill came before the deaths
Gooden introduced H.R.10272 on September 3. His release citing two Ole Miss students' deaths came on September 24. Nothing in the record connects them, and we are not saying it does.
- Cited in release to Ole Miss: no certified cause
Eleven senators want the leaf
Their letter asked for "scheduling action of the whole Kratom leaf and 7-OH" and called 7-OH "an important first step."
Grassley: all of it off the shelves
Sen. Chuck Grassley said all kratom should leave store shelves and demanded a final 7-OH rule.
- Whole-plant letter to Grassley, Lee and Collins: the whole plant
Grassley, Lee and Collins: the whole plant
Their letter asks for permanent scheduling of the full plant.
Delaware: 21 and up, nothing else
Delaware passed an age limit and no ban, 39-1 in the House and 19-0 in the Senate.
Missouri reaches the leaf
The attorney general's suit asks a court to stop the sale of "any kratom product."
Colorado settles, no ban
As reported, Colorado's attorney general used consumer-protection law and settled. The terms: $152,000 paid, $500,000 more if the sellers fall out of compliance, and testing before sale.
North Dakota's own count
The governor acted by executive order. The order cites 50 deaths, and kratom was the primary cause in 23 of them. The state's count adds 1 where it contributed.
Utah's regulation law holds
Utah's Kratom Regulation Act survived a challenge. The appeal ended in September without a ruling on the merits.
The data
What the death counts measure, and what they don't.
CDC 2019: 152 of 27,338
Kratom was found in 152 of 27,338 overdose deaths. It was the only substance found in 7, and CDC said other substances "cannot be ruled out."
Poison centers: 233 in 11 years
233 deaths reported to poison centers where kratom was involved, 2015 to 2025. 49 listed no other substance. 79% involved other substances.
The 5,208 figure
FDPS cites 5,208 overdose deaths involving kratom from 2020 to 2024. Its link goes to the front page of CDC's SUDORS dashboard, not to a table that shows the number. SUDORS counts deaths where a drug was found or involved, not caused.
Iowa's 45, Arizona's 146
Iowa's warning cites 45 "kratom-associated" deaths since 2024. Arizona's lawsuit cites 146 kratom-related deaths from 2020 to 2023. Associated and related are not the same as caused.
Poison-center calls on 7-OH
593 reports in 2025 and 901 in the first half of 2026. Among 7-OH-only reports, 20.5% went to the hospital. DEA's notice says poison centers only got codes for 7-OH between February and May 2025.
What we thinkOver a billion servings of 7-OH products have been sold. Hundreds of calls a year, against that, is a small number, and part of the climb is the new codes coming into use. It is the case for labels and age limits, not a ban.
Brandon Clarke's cause of death
The Los Angeles County medical examiner gave the cause as the effects of heroin and cocaine. Mitragynine was one of eight substances detected. It is not named as the cause.
Ole Miss: no certified cause
No cause of death or toxicology has been released for the two students. DOJ's release describes a "suspected connection" to one death.
The science
Receptors, breathing and who paid for the study.
The body makes 7-OH
In mouse and human liver preparations, mitragynine turned into 7-OH, and mice made 7-OH from it. The authors say that 7-OH explains most or all of mitragynine's opioid pain relief in mice. Co-author Andrew Kruegel co-founded Kures.
What we think7-OH is not something foreign to kratom. It is part of how the leaf works.
- Same co-author, next step to Mice: a ceiling on breathing
A partial agonist
Mitragynine is a partial agonist at the mu-opioid receptor with low intrinsic efficacy. Heroin and fentanyl are full agonists.
- Partial agonist, ceiling to Mice: a ceiling on breathing
Mice: a ceiling on breathing
Oral mitragynine's effect on breathing leveled off above 10 mg/kg. Oral 7-OH had a dose-dependent effect. Co-author Andrew Kruegel co-founded Kures.
- Co-author co-founded to atai buys into Kures
- Read together to Injected: both halves
Rats: 400 mg/kg by mouth
No breathing drop from oral mitragynine up to 400 mg/kg. One rat died at each oxycodone dose. Funded by the American Kratom Foundation; Henningfield works for AKA's consultant, Pinney.
- Funded by the American Kratom Foundation to American Kratom Association
NIDA's own study of real users
NIDA researchers tracked 357 regular users by phone for 15 days. Most used kratom in a way that seemed to cause no problems. 66.7% met two or more use-disorder symptoms, impairment was rare, and 28% used kratom in place of opioids.
- Both run by NIDA to The government is testing it as a medicine
Injected: both halves
In rats given IV doses, mitragynine did not lower breathing up to 17.8 mg/kg. 7-OH did, comparable to morphine, and naloxone reversed it.
What we thinkInjected into a vein is not how people use 7-OH. They take it by mouth.
Rats: 7-OH by mouth
A Labcorp study paid for by Outpost Brands gave male rats one dose of 7-OH by mouth at 1, 5 or 25 mg/kg. Breathing did not drop. At the two higher doses it sped up for up to 90 minutes, then settled. It is a draft report, filed with HHS, not yet peer-reviewed.
- Labcorp Study No. 8571915, draft report for Outpost Brands, filed with HHS Sept 10, 2026 (Exhibit 1)
- 7-OH by mouth: results split to Mice: a ceiling on breathing
The government is testing it as a medicine
NIDA's Phase 1 trial gives single oral doses of mitragynine to 32 healthy adults who used oral opioids in the past month. Its listing says some people use mitragynine to help manage opioid withdrawal. It is a safety trial, not proof it treats anything, and it was still not recruiting in October 2026.
Kratom against oxycodone at the VA
A study at the Houston VA medical center, led by a Baylor researcher, gives 72 people with past recreational opioid use single doses of 4 to 16 grams of kratom in capsules, 30 mg of oxycodone or a placebo. Its main measure is how much they like the drug. Recruiting since September 2026.
What we thinkA drug-liking test against oxycodone is how abuse potential gets measured. Watch where the results end up.
Cutting people off
What happened when pain patients lost their opioids.
Tapering raised overdose risk
Patients tapered off long-term opioids had higher overdose and suicide risk (RR 1.15).
- Same finding to Fast cuts, nearly double
Fast cuts, nearly double
Rapid dose cuts were tied to almost twice the overdose risk (HR 1.95).
- Opposite, no fentanyl to Australia found the opposite
Australia found the opposite
An Australian study found lower risk after tapering (aOR 0.45). Its authors point to Australia's lack of fentanyl. The US difference is the fentanyl.
The lawsuits
Courts and consumer law, not bans.
Torres v. Botanic Tonics
A class action over Feel Free's kratom disclosure ended in an $8.75 million settlement. 7-Eleven was a co-defendant.
Arizona v. Botanic Tonics
A consumer-fraud suit. It doesn't ask to pull the product. It cites 146 deaths without a published case definition.
- Cites 146 to Iowa's 45, Arizona's 146
Four AGs, no bans
Arizona, Colorado, Missouri and Texas used consumer-protection law. None of them got a ban.
- Arizona AG v. Botanic Tonics, Sept 23, 2026
- Colorado Politics, Sept 21, 2026, on the settlement
- State v. Shaman Botanicals, Jackson County 2616-CV11773
- Consumer law to Colorado settles, no ban
- Consumer law to Missouri reaches the leaf