If you are not a shop and something on your own shelf is the reason you are reading this, start here. If someone is difficult to wake, is not breathing normally, or is unresponsive, call 911. Anywhere in the United States you can call or text 988. Poison Control is 1-800-222-1222, around the clock, about a product in your hand. The federal treatment locator is findtreatment.gov.
Two sentences we state once. Kratom is not a treatment for opioid use disorder and it is not a treatment for withdrawal from anything, including the products this piece is about; the medicines with an evidence base are buprenorphine, methadone and naltrexone, and they come from a clinician. And we sell botanical products for a living, so every clinical question below belongs with a clinician rather than with us.
Listen to this article
Read by an AI voice. Both boxes are read aloud. The two checklist cards are on the page, and every item on them is spoken in the sections below.
On Friday 25 September 2026 New Jersey's Attorney General announced that three synthetic compounds, mitragynine pseudoindoxyl, MGM-15 and MGM-16, are now Schedule I controlled dangerous substances in the state, and that "Any individual or business found violating this ban could face criminal charges." The same release says, in the same breath, that "Natural kratom and other synthetic kratom-related compounds not scheduled will not be illegal in New Jersey as a result of this change in federal law." So the leaf you stock is where it was on Thursday, three compounds you may never have heard of are now in Schedule I, the most restrictive category the law has, and a New Jersey shop has exactly one question: is there any of it on my shelf, and can I prove there is not?
This is the brief for answering that. It is not a legal opinion, and it is not a guide to the compounds themselves; the state's release and the federal order are linked below and carry the chemistry. It is the operational version: what to pull, what the panel says, what a certificate should now name, and the two questions to put to any laboratory before you trust the paper it prints. It is written for New Jersey because New Jersey moved on Friday, and it applies in every state, because the federal order underneath it applies in every state.
Researched 28 September 2026. The three compounds became controlled in New Jersey on 25 September under N.J.S.A. 24:21-3(c), thirty days after the federal temporary order published on 26 August; the order runs to 26 August 2028 and can be extended. Botanical kratom and mitragynine are not controlled in New Jersey or federally. The Department of Justice has said it "will exercise enforcement discretion when only incidental trace amounts of MGPI are confirmed in a product otherwise consistent with botanical kratom", and that this does not cover MGM-15, MGM-16 or products with manufactured, concentrated, fortified or intentionally added MGPI; that is a federal prosecution policy, and New Jersey's announcement is silent on trace amounts. Two New Jersey bills, one adding an age line, a potency cap and a synthetic ban and one adding a second kratom alkaloid to the state's Schedule I, are in committee and are not law. If any of that changes, this box changes first.
What is actually controlled, by name and by number
Start with the list, because the audit is a search for three names and their aliases, and a search is only as good as its search terms. The Attorney General's alert names "mitragynine pseudoindoxyl, MGM-15, and MGM-16". The federal temporary scheduling order adds the detail a panel reader needs: each compound is controlled "including its isomers, esters, ethers, salts, and salts of isomers, esters, and ethers", and, so that differences in chemical numbering do not create a loophole, "Since nomenclature of this substance is not internationally standardized, compounds of this structure, regardless of numerical designation of atomic positions are covered."
The DEA's alphabetical list of controlled substances, footer dated 27 August 2026, gives the three drug codes, 9672, 9673 and 9674, and the order's regulatory text gives each compound a chemical name as well as its nickname. Both of the MGM chemical names contain the string "dihydro", and MGM-16's also contains "fluoro". Laboratories tend to report them under those chemical names rather than the nicknames, so a certificate may never say "MGM" at all. Those are the strings to search for on a panel, on a certificate and on a supplier's product sheet. So is "pseudo", on its own, because the DEA's July notice records products sold as "Pseudo" blends in extract tablets and liquid shots, and a shelf label rarely spells the whole word. The same list has no entry for kratom, for mitragynine or for the leaf's own minor alkaloid on its own. Three lines were added to that list in August. Nothing about the plant was.
Where it hides, according to the people who found it
Do not audit the powder wall first. The DEA's notice of intent of July, whose findings the August order restates, describes the market for these compounds in plain terms: "These products are commonly sold in different forms such as powders, tablets, and liquid shots", and it cites a study of 51 products sold online: "Seventy-six percent (39 of 51) of these products were chewable tablets, 18 percent were liquids (9 of 51), and the remaining three were either dried ice cream cones with ice cream (two products) or a chocolate bar (one product)." It lists the brand names they were sold under, and the channels, "gas stations, corner shops, and vape shops". It records prices "from about $2-4 per tablet or $34.99 per pack", and it flags "The use of 'research chemical' labeling, a common tactic to bypass regulatory oversight, for flavored chewable products". If you have a countertop display of fruit flavored tablets that arrived through a distributor whose name you would struggle to spell, that display is where the audit starts.
The second place is the one nobody expects: the kava cooler. In August 2026 Clinical Toxicology published a report by Marshall and colleagues on a cluster the Alabama Poison Information Center and local addiction medicine providers identified in October 2025: "a cluster of cases involving liquid products marketed as containing kava associated with opioid-like withdrawal symptoms". Five retail products were tested. "Quantitative UPLC-MS/MS identified both kavalactones and kratom alkaloids in three products, with mitragynine pseudoindoxyl predominating at concentrations of 0.16-0.21 mg per bottle", and one product "contained mitragynine with no detectable kavalactones". A bottle labeled kava, with no kratom on the panel, carried a compound that is now Schedule I in New Jersey. The authors' conclusion is the audit's second rule: "Unrecognized exposure to opioid-active kratom compounds may occur through products marketed as kava". If it is a relaxation shot and you did not test it, you do not know what is in it.
The third place is the whole extract shelf, read by form rather than by brand. The United Nations Office on Drugs and Crime, in its early warning announcement of August 2025, listed the forms these products take: "chewable/sublingual tablets or strips, gummies, drink mixes, shots, syrups, vape pens, capsules, food products or powders", and reported that recent testing of six products sold under the leaf's minor alkaloid name found that alkaloid in every sample, "together with mitragynine pseudoindoxyl, mitragynine and paynantheine in varying concentrations". The people making these did not make one thing. They made one thing in every format your store sells.
What a certificate should show now
No New Jersey rule requires a certificate of analysis for kratom; there is still no testing rule in statute. What changed on Friday is what a certificate is good for. Until then a shop read one for the alkaloid content, the heavy metals and the microbiology. From Friday the most useful lines on it are results for three compounds you hope are not there. For each SKU on your shelf you need a document that names mitragynine pseudoindoxyl, MGM-15 and MGM-16 as analytes and reports a result for each. Not "no synthetics detected". Not "compliant". The three names, each with a number or a not-detected against it.
Here is why the wording matters. The DEA explains that forensic laboratories may have reported so few of these compounds because of a "lack of readily available analytical reference standards and other analytic challenges", and that "Because these are new substances, it often takes time for forensic laboratories to develop and validate the necessary testing methods required for substance identification." And more specifically: "such closely related compounds require specific method and instrumentation for accurate identification." UNODC says the same thing from the other side of the bench: "reference standards and appropriate analytical methods are needed to effectively identify and differentiate mitragynine-related compounds. Complexities such as metabolism, poor stability especially in biological samples and limitations of some standard methods such as GC-MS need to be considered."
Translate that into what you hold in your hand. A laboratory cannot report a compound it did not look for, cannot confirm a compound without a reference standard for it, and cannot reliably tell these three apart from their close relatives with a method that was not built to. A certificate that does not name the analyte was not testing for it, whatever the summary line says. A certificate that names it but shows no method and no detection limit is telling you a result without telling you how it got there. "Not tested" and "not detected" look alike on a summary page and mean opposite things in a police station.
So the certificate you want has five things on it, and you should be able to find each in under a minute. The three compounds named as analytes. A method beside them; for these compounds we would look for liquid chromatography with mass spectrometry rather than GC-MS alone. That recommendation is ours: the Alabama team's quantitative results came from UPLC-MS/MS, and UNODC says only that "limitations of some standard methods such as GC-MS need to be considered". A limit of detection or quantitation, per gram or per serving, because nobody has defined "trace" and a stated limit is the only number you will have. A batch or lot number that matches the package in your hand, not the product line. And a laboratory name you can look up. If any of the five is missing, the document is a brochure.
The accreditation trap
Many certificates in this category cite ISO/IEC 17025, and it is easy to read that as "this result is accredited". It may not be, and understanding why is the single most useful thing in this brief.
The International Organization for Standardization describes ISO/IEC 17025 as the standard that "sets out requirements for the competence, impartiality, and consistent operation of laboratories", and notes that "Accreditation bodies use ISO/IEC 17025 as the criteria for assessing and accrediting laboratories." The accreditation belongs to the laboratory, and it is granted for a defined list of tests. The American Association for Laboratory Accreditation, one of the US accreditation bodies, puts it this way in its accreditation FAQ: the scope of accreditation is "The list of specific tests, types of tests, calibrations, product certifications, etc. for which a Conformity Assessment Body (CAB) is found competent", and "Capabilities that are not listed on the scope are not covered by the CAB's A2LA accreditation."
Read that twice. A laboratory can be fully accredited for mitragynine quantitation, heavy metals and microbiology, cite the standard on every page, and run a pseudoindoxyl screen it added in August that is not yet on its scope. The accreditation statement would be honest and the pseudoindoxyl result would be outside it. By the DEA's own account the first of these compounds was confirmed in consumer products in 2024, the second in September 2025, and there is no evidence the third has reached the market at all; a scope of accreditation, meanwhile, is amended by application and assessment, not by news cycle. So it is possible that a laboratory reporting these compounds is doing so outside its accredited scope; read the scope to find out. That does not make the result wrong. It makes it unaccredited, and the difference matters the day a regulator asks who stands behind the number.
Our own certificates show what this looks like in print. The laboratory whose certificates are on our lab results page states on each one that its methods are performed in a laboratory accredited to ISO/IEC 17025:2017 by PJLA "or a registered outsourcing facility", and that "Some test methods reported may fall outside the scope of L22-250 supplement." That second sentence is the one to look for on any certificate, ours included, and it is why the scope document matters more than the badge.
So the two questions for the laboratory, or for the supplier who used it, are these. First: do you hold certified reference standards for mitragynine pseudoindoxyl, MGM-15 and MGM-16, and is the method that reports them validated? Second: are those three analytes on your current scope of accreditation, and can I see the scope document? A2LA publishes a searchable directory of the organizations it accredits, and an accredited laboratory should be able to hand you its current scope; a supplier who will not produce it is answering the question. A no to either question is not disqualifying on its own, because these compounds were scheduled only in August. A no dressed up as a yes is.
The trace problem, stated honestly
There is a complication that every shop should understand before its first conversation with a lawyer, and it is chemical rather than legal. The DEA calls mitragynine pseudoindoxyl a chemical rearrangement product of a minor kratom alkaloid, and says the three compounds "are produced through synthetic modifications of purified mitragynine isolates" or of another purified kratom alkaloid. Even so, the Department of Justice's press release on the order puts the complication in its own words: "The published scientific literature has not established MGPI as a naturally occurring kratom alkaloid. However, scientific and analytical questions remain about whether MGPI may be reported at incidental trace levels in some botanical products as a result of processing, storage or analytical conditions." That is why it says the department "will exercise enforcement discretion when only incidental trace amounts of MGPI are confirmed in a product otherwise consistent with botanical kratom", and, in the same paragraph, that "This policy does not create a legal exemption and does not change MGPI's status as a schedule I controlled substance." It also says the policy does not apply to MGM-15 or MGM-16, "or products containing manufactured, concentrated, fortified or intentionally added MGPI."
Two things follow. The first is that a sensitive enough instrument may report a very small number against a botanical product. That is precisely why you want the detection limit printed on the certificate: a reported "not detected" at a stated limit is a defensible statement, and a numeric trace result with a method behind it is a fact you can put in front of counsel, whereas a certificate with no limit leaves you arguing about what "trace" means with no document to argue from. The second is that the federal discretion statement is a federal statement. New Jersey's release does not repeat it, does not contradict it, and does not mention trace amounts at all. We are not going to tell you what New Jersey will or will not do, because New Jersey has not said. We will tell you that the state's silence is a reason to hold the number, not a reason to skip the test.
What this means for us, since the standard we are describing is one we have to meet too. The laboratory whose certificates are on our lab results page already reports all three compounds on a panel of mitragynine derivatives on its newer certificates; older certificates do not carry it. Where the panel is present, it states a result and a limit for each analyte. Read ours the way this brief tells you to read anyone's, and hold us to it.
The counter conversation this changes
Some of your regulars in New Jersey may have read a headline on Saturday suggesting kratom itself is now illegal, and some of them will ask you whether they are breaking the law by buying leaf. The counter script we published in when a regular asks still holds: say less, and make every word true. The sentence is: "On 25 September New Jersey scheduled three synthetic compounds; it did not ban kratom leaf; the state's own release says so, and I have the certificate for what I sell." Then show the release and show the certificate. Do not say "totally legal", because uncontrolled is not the same as approved. Do not say "safe": the same release says "no forms of kratom or related synthetic compounds have been shown to be safe or effective to treat any medical condition". And do not, under any circumstances, tell a customer who used to buy the tablets what to use instead. That conversation belongs with a clinician, and the numbers at the top of this page are how you hand it to one.
If a customer asks whether you ever carried the scheduled products, answer with your records, not your memory. Purchase orders and supplier product sheets are the audit trail, and a shop that can show it pulled a display on Friday and can name the SKUs is in a different position from a shop that shrugs. The Attorney General's release warns that "Kratom products are not subject to any quality controls regarding contaminants or concentration" and that "the labels may not identify the contents clearly". Your certificate file is your rebuttal to that sentence. Keep it where a staff member can find it in under a minute.
The audit, in order
Pull every tablet, strip, gummy, shot, syrup, extract and relaxation drink in the store, including the kava cooler, and set them on one counter after close. Read every panel for the three names, for "pseudo", for "MGM" and for "dihydro", and read the fine print for "research chemical", which the DEA describes as "a common tactic to bypass regulatory oversight" rather than a disclaimer. Match every remaining SKU to a certificate that names the three compounds, shows a method and a limit, and carries the lot number on the package. Anything that fails the match does not go back out until it passes, and anything that names a scheduled compound is a conversation with your lawyer now, because possession has been unlawful federally since 26 August and in New Jersey since 25 September; the federal order says that anyone without a Schedule I registration "must surrender all currently held quantities of this substance", and we are not the people to tell you how that is done in New Jersey. Then call every supplier whose product survived and ask the two laboratory questions. Write the answers down with the date.
If a supplier cannot produce a scope document, cannot say whether the reference standards are in hand, or sends you a certificate for the product line rather than the lot, our general checklist on how to vet a wholesale supplier covers the rest, including asking for a current certificate for the exact product. If you are looking at rebuilding the shelf around suppliers who can answer, the wholesale application is where that conversation starts with us, and the lab results page is where you check whether we have earned it.
The reason to do all of this now rather than waiting for a letter is not that we expect raids on corner shops. It is that the state has just shown it can add three substances to its Schedule I without a hearing, a vote or a finding, by the automatic operation of a statute, and the DEA's July threshold notice for a fourth compound still has no order behind it. If one publishes, the same thirty day clock runs in Trenton unless the Director objects, and the shops that already know how to read a certificate will be ready for it. Build the habit on three compounds that should not be on your shelf, so that it is already built on the day it is needed for something that is.
Disclaimer: this article summarizes publicly available material as of 28 September 2026 and links to primary sources so you can check them. State and federal status can change on the day an order publishes; the status box carries the date it was last checked. It is general business information, not legal or medical advice, and no substitute for counsel in your jurisdiction or for a clinician. Laboratory and accreditation questions are suggested wording; your state may impose its own testing rules. Statements about botanical products have not been evaluated by the Food and Drug Administration, and no product is intended to diagnose, treat, cure or prevent any disease.
