100-to-1 ratio

DEA's reissued notice of intent proposes two tests. The first is concentration, more than 1 mg of 7-hydroxymitragynine or mitragynine pseudoindoxyl per gram or milliliter. The second is the ratio: the product is covered when the mass of mitragynine divided by the mass of those compounds "is less than 100" (91 FR 65370). Florida's June 2026 emergency rule uses the same figure, requiring at least 100 times more mitragynine by mass (Central Florida Public Media).

The ratio is computed from the potency panel. A tablet at 82.81 mg/g mitragynine with 7-hydroxymitragynine not detected at 0.025 ppm cannot fail it, because the denominator is below the detection floor. A product at 80 mg/g mitragynine and 2 mg/g 7-hydroxymitragynine gives 40 and fails. The test was written to separate leaf-derived products, in which mitragynine dominates, from concentrated or converted 7-OH products, in which it does not; it is why a laboratory must report 7-hydroxymitragynine with a real limit of quantitation.