3.6. Second Reading and adoption of an Ordinance of the City Council of the City of Orange adding Chapter 9.45 of the Orange Municipal Code prohibiting the sale and distribution of kratom products. Ordinance No. 01-26.
I write to you today to ask that you vote NO on this ordinance. My partner has chronic pain that makes normal activities, that the able bodied have no problem doing, almost impossible most days. With the crackdown by the government on pain relieving drugs, things have been even harder.
Thankfully she found natural kratom that has made things more bearable for her. With the help of natural kratom she has been able to live her life. It has been such a life saver.
I hate seeing her in pain and natural kratom has made her feel better.
Kratom (Mitragyna speciosa) has a long history of traditional use in Southeast Asia as a natural, whole-plant remedy for pain management, fatigue, and opioid harm reduction. When consumed in its natural, unaltered leaf form, kratom functions as a mild, plant-based medicine with a comparatively low risk profile.
The primary public-health concerns associated with kratom in the United States are overwhelmingly linked not to raw kratom leaf, but to high-potency kratom extracts and synthetic concentrates. These products dramatically alter the plant’s natural alkaloid balance, increase dependency risk, and have been disproportionately associated with adverse events, misuse, and hospitalizations.
Whole-leaf kratom contains a complex spectrum of alkaloids that naturally moderate one another, producing a ceiling effect that reduces the likelihood of respiratory depression and overdose. Extracts, by contrast, bypass this natural safeguard by isolating and amplifying specific alkaloids—particularly mitragynine and 7-hydroxymitragynine—creating pharmacological effects that are fundamentally different from traditional use.
From a regulatory and public-health perspective, banning or restricting kratom extracts while protecting access to raw, unadulterated leaf kratom represents a balanced, evidence-based approach. This strategy:
Reduces harm and abuse potential
Preserves access for individuals using kratom as an alternative to opioids
Respects traditional and medicinal plant use
Encourages transparency, quality control, and responsible consumption
Prohibition of whole-leaf kratom risks pushing consumers toward illicit markets or more dangerous substances, while failing to address the true source of harm. Regulation should therefore focus on product purity, labeling, age restrictions, and the elimination of concentrated extracts, rather than blanket bans that ignore critical distinctions within kratom products.
In summary, raw kratom leaf is best understood as a medicinal plant, not a synthetic drug. Sensible regulation—rather than prohibition—can protect public health while honoring both scientific evidence and traditional practice.
Hello my name is Mariana otero and i grew up here in orang. I
Im writing to give you a little perspective on kratom and how its changed my life for the better.
About 25 years ago I suffered a tragic accident that left me with debilitating pain.
I was given opiods by my doctor's which lead me to become dependant.
Throughout the next few years I had 3 massive back surgeries and dozens of other treatments to address my Injuries. But the main one was opiods. A lot of them. I became both an addict and a chronic pain patient taking up to 60 pills a day to get by. Id develop tolerance and then they would increase my dosage and type of narcotic.
I was a walking zombie on long term disability.
My constant desire to get clean and off these meds lead my to be in and out of rehab facilities. Many hospitals stays where I would be chemically detoxed by doctors and nurses.
The times I would be free of the addiction I would be confronted with the chronic pain of my injuries. I was a prisoner to opioids.
Unable to work, exercise or have healthy relationships with friends and family.
Until I discovered kratom.
Kratom saved my life. It allowed me to be able to cope with my chronic pain as well as allow to have a normal quality of life off of opiods.
I now work full time, work out 6x a week and feel liberated from years of constant withdrawals and addiction.
Its allowed me to again be able to have good relationships with family and friends.
With 8 little grams of a green natural powder a day I feel great. All while never needing to increase the dose. It keeps me pain free and helps my depression and anxiety all while never needing to take the poison that stole so many years of my life.
So I ask you to please keep natural kratom leaf legal and accessible. I am in favor of banning 7-oh which is not kratom leaf. Its a synthetic form that 100x the strength and very dangerous.
I ask that you consider regulating kratom like more than a dozen other states and cities have done. Wirh the the kratom consumer protection act
Which would ensure kratom products are not adultered, it would limit sales to individuals at least 18 or 21 years and require proper labeling.
Kratom has saved so many lives and gives people a natural way to cope with debilitating conditions including chronic pain and depression.
If you took this plant away my whole world would fall apart and I would be forced to turn to very dangerous opiods again and that would surely destroy my life. I would lose everything I've built and back to a life of active addiction.
My story is just one of millions. Kratom is safe and a miracle to people like me.
Thank you for listening and considering my story. I know you'll make the right decisions.
With love,
Mariana Otero
424 450 8948
I am writing to respectfully oppose any proposed ban on kratom. Kratom has helped me significantly manage chronic pain with no negative side effects and without making me feel impaired or “under the influence” in any way. Because of kratom, I am able to function normally, remain clear-headed, and continue working a very stressful job.
That ability to work is not a small thing. It allows me to support myself, pay a substantial amount in taxes, and contribute to society in a meaningful way. Without kratom, my pain would be far more limiting, and my quality of life — as well as my ability to remain productive — would be seriously compromised.
Many people rely on this natural plant to get through their day. It helps manage pain effectively without producing a “high,” without intoxication, and without the severe side effects or risks associated with many prescription pain medications. For countless individuals, kratom is the difference between participating in daily life and being sidelined by pain.
It is deeply concerning and disheartening to see kratom placed on the agenda for a potential ban, especially when it is being grouped with or conflated with 7-hydroxymitragynine (7OH). I strongly urge the Council to research kratom itself, not just isolated compounds, and to understand the important differences between the whole plant and synthetic or concentrated extracts.
Most importantly, I ask that you listen carefully to the public comments submitted here and shared in person tonight. You will hear from many people whose lives have been positively impacted by kratom — people who are parents, workers, caregivers, and contributing members of the community.
Please consider regulation, education, and quality control rather than prohibition. A ban would not protect people like me; it would only take away a tool that allows us to live functional, productive, and pain-managed lives.
Thank you for your time, your consideration, and for listening to the voices of the people this decision will directly affect.
I am an LA county resident. I'm writing as a constituent and a responsible kratom user of eight years. I use natural leaf kratom for pain management and as a safer alternative to caffeine, and it has significantly improved my quality of life.
I want to be clear that I am strongly opposed to adulterated kratom products, specifically highly concentrated 7-OH (7-hydroxymitragynine) products. These are not representative of traditional, natural leaf kratom and should be regulated or restricted separately. I fully support strict standards to prevent unsafe, synthetic, or manipulated products from being sold.
At the same time, I am in full support of natural leaf kratom and believe it should remain legal with sensible regulation. A full ban would harm responsible consumers like myself and push people toward unregulated and unsafe alternatives. Regulation, not prohibition, is the best way to protect public health.
I respectfully urge you to oppose any blanket ban on kratom and instead support policies that distinguish between dangerous adulterated products and responsibly sold natural leaf kratom.
Thank you for your time and for your commitment to public safety.
My name is Jordan Richard, and I appreciate your time and consideration.
For the past 13 years, I have dedicated my life to studying kratom. I have traveled across the United States and internationally, interviewing researchers, clinicians, toxicologists, and regulators, including experts associated with Johns Hopkins and the FDA. Through this work, I have developed a practical understanding of kratom and how it is used in the real world. I am also the author of one of the most widely read books on kratom, written to help policymakers separate science from speculation.
I want to highlight the position of California’s own narcotics authorities. The California Narcotic Officers Association does not call for banning kratom. Instead, it supports regulating traditional kratom leaf while banning high-potency synthetic products such as 7-hydroxymitragynine, often referred to as 7-OH.
If the kratom leaf itself posed a public safety risk, law enforcement would recommend prohibition. They have not, because they recognize a clear difference between traditional kratom leaf and synthetic derivatives. One is presenting problems. The other is not.
This same framework has been adopted across California, including Orange County. Cities have chosen regulation over prohibition because it is targeted, enforceable, and evidence-based.
Federal regulators share this view. The current FDA Commissioner has stated that the FDA is not concerned with traditional kratom leaf, but rather with high-potency synthetic products. The FDA has also released its first human-focused study on kratom, funded directly by the FDA, concluding that kratom appears to be safe even at high exposure levels.
Banning 7-hydroxymitragynine is not difficult to enforce. Jurisdictions already do this by limiting total 7-hydroxy content to two percent or less, directly targeting synthetics while allowing regulated traditional products.
Independent research has found that kratom has a relatively low potential for abuse compared to traditional opioids, with a safety margin roughly one thousand times greater than prescription opioids.
I also speak from lived experience. I am a former heroin addict and today a business owner and father of five. Addiction involves compulsive behavior despite harm. Physical dependence simply reflects adaptation. Many people are physically dependent on prescribed medications, including antidepressants, without being addicted. That distinction matters here.
Traditional kratom leaf has been used daily by millions of people in Southeast Asia for over 1,000 years, including Indigenous communities such as the Dayak people of Borneo, with no documented deaths attributed to traditional use. The concerns being raised today are recent and align with the emergence of synthetic and concentrated products.
Regarding liver injury, the NIH’s LiverTox database reports 26 potential cases among an estimated 20 million U.S. users, approximately 0.00013 percent. Context matters when evaluating risk.
The question before the City of Orange is not whether to allow something harmful, but whether to regulate responsibly while drawing a clear line against synthetics.
Respectfully,
Jordan Richard
Author, The Truth About Kratom: Life-Saving Plant or Botanical Menace?
I am submitting this comment in strong support of Ordinance No. 01-26, and I do so as a parent who has already paid the highest possible price for kratom being legal, normalized, and aggressively defended.
My son, Austin, was not a drug user. He was a normal young man with plans, relationships, and a future. He worked, he laughed, and he believed—because he was repeatedly told—that kratom was a “natural” and safer product.
That belief did not come from science.
It came from organized industry messaging.
Groups such as the American Kratom Association and the Global Kratom Coalition promote kratom as safe, minimize documented harms, and flood public hearings with user testimony designed to normalize continued access. They frame themselves as advocates, but function as trade organizations whose primary goal is protecting sales, not lives.
On December 6, 2023, my son Austin died alone in his bedroom after consuming a kratom product he believed was legal and safe.
His official autopsy and toxicology report, completed by the Montgomery County, Ohio Coroner, determined:
• Cause of Death: Intoxication by mitragynine
• Toxicology: Mitragynine only
• No fentanyl, no illicit drugs, and no prescription opioids present
• Findings: Pulmonary edema and frothy airway fluid, consistent with opioid-type respiratory depression
This was not a contaminated product.
It was not mixed with alcohol.
It was not misuse in the way advocates often imply.
It was the predictable pharmacological effect of kratom itself.
Kratom’s primary alkaloid, mitragynine, is opioid-active and is converted by the human liver into 7-hydroxymitragynine, a compound more potent than morphine. No warning label, dosage suggestion, or “responsible use” guideline can prevent that biological conversion.
And this is the point that is rarely said out loud:
When kratom users stand at podiums and say “this pure leaf powder got me off morphine, oxycodone, heroin, or fentanyl and saved my life,” they are not proving safety.
They are proving opioid equivalence.
A substance does not replace heroin unless it acts on the same opioid receptors. A product does not suppress withdrawal unless it has clinically meaningful opioid potency. You cannot simultaneously argue that kratom is weak and harmless while also claiming it is powerful enough to replace heroin.
Those statements are not evidence of safety.
They are admissions of dependence-forming potency.
Public health is not decided by who feels better today. It is decided by mechanism of action and population-level harm. And by their own words, kratom users are describing opioid substitution—not a dietary supplement.
Austin believed kratom was safe because it was legal, sold openly, and defended loudly. That false sense of safety cost him his life.
Local governments exist to protect residents when higher systems fail. Ordinance No. 01-26 is a responsible and necessary use of the City’s police power to stop the commercial sale and distribution of a product with no FDA approval, no accepted medical use, and real, documented fatalities.
Please do not allow emotional testimony or outside trade groups to override medical reality. This ordinance is not about judging users—it is about preventing the next family from standing where mine is now.
I respectfully urge the City Council to adopt Ordinance No. 01-26.
Thank you for your time and for choosing public safety over industry pressure.
My son, William, died in 2024 from a toxic mixture of raw leaf kratom and his prescribed antidepressants. He started using kratom to supplement his antidepressants to treat his anxiety & depression. Everything he and I read on-line said it was safe and all natural and MARKED with a Good Manufacturing Practice stamp of approval. Will took kratom for about 1 year before he realized he'd become dependent. He kept having to up the dose to achieve the same desired effect. Will spent the last 3 years of his life trying to withdraw from kratom..it was a vicious cycle full of embarrassment, feelings of hopeless and helplessness.
You will hear from the pro kratom community which consists of chronic pain suffers and drug addicts who claim the can not possibly function without kratom. All I can tell you is I lost my son--HE IS DEAD--because kratom is readily available in gas stations, smoke shops and on-line. How can a person be a responsible kratom consumer if so little is know about how to consume kratom safely. No lethal dose has been established, no studies of how kratom interacts with other drugs, no studies how kratom might effect a person with pre-existing health conditions or how chronic use effects the body. I honestly cant even believe my son is dead when kratom is not even suppose to be in this country...why won't the DEA enforce IMPORT ALERT 54-15 ?? I sincerely applaude the efforts of the people on this committee in keeping your citizens safe from this deadly poison...SusanCave
It makes no sense to punish the 97% of responsible adult citizens because of adverse events from the 3% addiction (profile) be mindful that addiction is a mental illness that infects family members, co-dependency also a mental illness. That’s equal to banning guns because of the unstable users and criminals. I’m offended as a USMC veteran and a working senior citizen that laws are shaped because of the 3%. To add insult to injury to ban kratom is a “death sentence “ to untold thousands of responsible citizens who have broken no laws or misuse this natural leaf product, none of this makes sense especially when quality,enforced regulations are the practical solution. SMH
In 2021 my 22 year old son Matthew Eller died from whole leaf Kratom Powder (the least potent form of Kratom available in the United States). Kratom caused him to have a seizure, go into cardiac arrest and die. His toxicology showed he died from the “TOXIC effects of Mitragynine” an alkaloid found only in Kratom. He had no prescription drugs, no street drugs nor alcohol in his system when he died, and his autopsy showed he had no underlying health conditions. It’s important to note my son didn’t die from 7-OH/7-hydroxymitragynine.
Hello, my name is Bunny Baker and I'm from Tulare County Ca
Pure, plain leaf powder Kratom has had a profoundly positive impact on my quality of life. Before I started using it, I had been diagnosed with severe depression and struggled with chronic migraines. My days were often spent in bed, exhausted and unmotivated. I felt disconnected from my family and from life itself.
Since incorporating kratom into my wellness routine, I’ve experienced a complete turnaround. My energy levels have improved dramatically, and my migraines have become far less frequent. Most importantly, the heavy cloud of depression that once controlled my life has lifted. I now wake up feeling motivated and capable.
I’m an involved mother, a supportive wife, and an active member of my community. I’ve been able to return to regular exercise, eat healthier, and live fully again—something I never thought I’d be able to say.
Kratom hasn’t just improved my mood; it’s given me back my sense of purpose, balance, and well-being. It’s helped me reduce dependence on antidepressants and reconnect with life in a natural, sustainable way.
Please regulate and keep lab tested plain leaf kratom legal.
My name is Christopher Deaney. I am a lifelong American, a small business owner, and someone who has lived with chronic pain since childhood after being struck by a car at the age of eight.
For many years, I followed the traditional medical path and was prescribed opioid pain medications long-term. While legal and doctor-prescribed, those medications came with escalating risks. In 2015, after careful research and consideration, I transitioned away from that path and began using plain, natural kratom leaf prepared as a traditional tea.
I want to be very clear about what I am speaking about tonight.
I am not here to defend synthetic products, isolated alkaloids, or highly concentrated substances being sold under the name “kratom.” I share concerns about those products, and I believe they should be addressed directly through regulation or removal.
What I am asking you not to ban is natural kratom leaf.
This distinction is supported by the American Herbal Products Association (AHPA), the national trade organization representing the herbal products industry. In 2025, AHPA published a new entry in its Botanical Safety Handbook recognizing Mitragyna speciosa leaf as a traditional herbal material and clearly distinguishing it from synthesized or chemically altered kratom alkaloids. AHPA has also issued guidance stating that synthetic kratom alkaloids should not be conflated with the natural botanical.
This information is publicly available here:
https://www.ahpa.org/blog_home.asp?Display=279
Policy works best when it is based on accurate classification. Treating natural leaf the same as synthetic or altered products misidentifies the risk and leads to unintended consequences.
Natural kratom is a whole-plant botanical related to the coffee family. In its traditional form, it has been used responsibly in Southeast Asia for generations and by millions of Americans for over two decades. For people like me, it functions as a stability tool, not an intoxicant and not a recreational drug.
History consistently shows that blanket bans do not eliminate demand. They push responsible adults away from transparent products and toward unregulated or illicit alternatives. That outcome increases risk rather than reducing it.
If the City’s goal is public safety, a more effective approach is targeted regulation, not prohibition:
• Distinguish natural leaf from synthetic or altered products
• Require proper labeling and testing
• Keep products out of the hands of minors
• Hold bad actors accountable without punishing responsible consumers
I am also a father, and I take public safety seriously. That is why I am asking the City to focus on the real sources of harm rather than removing a traditional botanical that many adults use responsibly to maintain quality of life.
Natural kratom leaf is not the problem.
Lack of distinction is.
Please consider an evidence-based, balanced approach that protects public health without unintended harm.
Hello Mayor, Councilmembers, and staff,
Please do not pass Ordinance 01-26 as currently written. The draft unintentionally bans natural kratom leaf instead of focusing on the products that actually pose the highest risk to public health.
You correctly identified that 7-hydroxymitragynine and synthetic kratom derivatives are dangerous and should be removed from stores. These are potent, highly addictive, and lack safety data. Natural kratom leaf is different. It contains only trace 7-OH and has research supporting its relative safety in a regulated market.
Scientific evidence shows that natural leaf kratom:
• Does not trigger the respiratory depression pathway associated with opioids
• Shows lower addiction potential in preclinical studies
• Is used by adults to improve daily functioning or reduce more dangerous substances
• Was well tolerated in a recent randomized, double-blind human study
• Causes serious harm mainly when adulterated or synthetic
Other California jurisdictions, including Riverside, Orange County, Huntington Beach, Fresno, and Laguna Niguel, allow regulated natural kratom while prohibiting high-potency extracts and synthetics. This protects consumers without pushing them to illicit markets.
In July 2025, FDA and HHS stated they support scheduling 7-OH products but not natural kratom. They have formally asked DEA to begin scheduling only 7-OH.
Banning natural leaf eliminates oversight and testing. Regulation allows for age restrictions, product testing, labeling standards, limits on extracts, and explicit prohibition of synthetic derivatives.
A regulatory approach addresses the real sources of harm while preserving responsible access for adults.
Thank you for considering a practical and public-health-focused solution. I am happy to provide research or assist with refining the ordinance.
My name is Anthony Rosa, and I’m a lifelong California resident. I’m 29 years old, and I’ve been a kratom user for six years. I’m not here to defend synthetic 7-hydroxy derivatives — I’ve never used them, and I fully agree they should be restricted. But please don’t punish responsible adults who use natural kratom leaf powder. It’s a mild, traditional plant that has been safely used for generations. Kratom is NOT 7-OH.
I still struggle every day with anxiety, stress, and depression. The pressure of my life is constant, but kratom is what gets me through it. It’s the only thing that keeps me functional, stable, and able to provide for my family. Without it, I would likely fall back into alcoholism.
Kratom didn’t turn me into an addict — It helped me overcome crippling lethargy, rebuild my motivation, and become a small business owner. I am living proof that kratom can save lives.
Lumping lab-tested kratom leaf together with synthetic 7-OH is a scientific and moral mistake. Those synthetic capsules contain up to a thousand times the alkaloid concentration of natural kratom powder. Even The federal dept of health and human services. reached out to the state in late September urging California to make that distinction clear. Texas chose a 7OH limit over a blanket ban. Why can't we? The actions of our state public health department are authoritarian, and are not making that distinction.
How can we allow adults to legally buy alcohol and cigarettes — substances proven to kill — yet criminalize a natural plant that helps people live?
Please, Do not force people like me back into despair and addiction.
Good afternoon,
My name is Holly Trouville and I am writing to you as a mother who lost her only child Ty, to mitragynine toxicity, on February 6th, 2024. I am not a lobbyist, a business owner making money, nor a user. My only goal is to prevent any parent from feeling the complete and utter devastation I felt losing my only child. I am trying to prevent having a parent only be able to speak to their child, 6 feet under, in a cemetery.
Mitragynine toxicity was Tyrell’s sole cause of death, with no secondary causes nor opioids in his system. And, it was ruled as only an accident. Tyrell died from a Kratom seltzer drink that is marketed as caffeine free, sugar free, and alcohol free. He drank them at the Kava bar he would go to.
Regulation does not work, as much as people may think it does. The majority of deaths are men over 21, to regulate under 21 is futile. Due to there being no federal regulations, oversight, nor FDA approval, we do not know if mixing anything with Kratom, even something such as Benadryl or prescription medicine will give an adverse effect. There is not enough information known to say how much could be taken to prevent an adverse effect. There is no labeling saying what could cause an adverse effect. There are also no dosage recommendations on any of these packages. So when talking about selling Kratom to uninformed consumers, people who are looking for help and trusting sellers to do the right thing, that is not always happening.
Here are proven facts. The majority of people using whole leaf, synthetic, or 7OH are recovering addicts. You can hear it in almost every hearing. Why did Fell Free Wellness Tonic, one of the largest sellers of Kratom drinks, have to pay 8.75 million dollars and add a disclaimer on the back of their can stating "Individuals with a history of substance abuse are advised against use." If it is so natural, why can’t you use it if you have a history of substance abuse and why does it state you should consult a physician before trying it, if you are on any medication? This should be gravely concerning to you.
You will hear people testify that veterans use it to help them with their PTSD. Then please answer this, why did the DOD ban Kratom in ALL armed forces? Use of it is punishable by the Uniform Military Code of Justice. That in and of itself is telling. The DOD obviously does not believe it benefits military people. I could go on and on but these are just a couple examples of how Kratom, in all forms, is being recognized as dangerous, addictive, and deadly.
I implore you to ban ALL forms of Kratom, natural and synthetic. You will be saving more lives than not. Lastly, all of these people testifying that Kratom has saved their life, that is opinion only. I have yet to see one letter from a doctor stating that it has saved a life. You will not see that because a doctor will not put their stamp on that. However, I have a letter from a doctor stating that Kratom took my son’s life. Death certificates do not lie, autopsy reports do not lie.
Please don’t allow another parent to have to live the rest of their life without their child, due to a substance that if it already hasn’t, will kill some of the people you represent..
Im in full support for a full ban on kratom. My perspective comes from a loss no parent should ever experience. My daughter Kielee died on March 1st 2025 of a mitragynine overdose. She was only 23. Because she was so young they had to do an investigation. After an autopsy and toxicology screen was preformed mitragynine overdose was determined to be the factor of death.
Kratom took my daughter's life and robbed the world of the light she brought into it. She trusted the word natural. Kielee used the natural kratom powder. She believed it was safe to use for pain because that is how the industry markets it. She was not using extracts or 7OH products. The leaf itself killed her. Regulations wouldn't have saved her because she was 23 and didn't buy it from a gas station.
Mitragynine and 7OH both bind to the same opioid receptors as morphine. The idea that the natural powder is harmless while only certain extracts are dangerous is not supported by what is happening in real families. Both forms take lives.
My state of Idaho reported 83 kratom involved deaths between 2020 and 2024. Bonneville County recorded six deaths in eighteen months. Four were from mitragynine alone one of was my daughter. Mitragynine overdose is what i have to read on her death certificate. These deaths mirror what other states are seeing, especially as kratom becomes more available in small shops and gas stations.
I want you to understand this because your decision will shape what families in your community face. Parents don’t know what it is. Young people assume it’s safe. The reality does not match the marketing.
You may hear the argument that the Kratom Consumer Protection Act is the safer middle ground. It is important to understand what the KCPA actually is. It was written and promoted by the kratom industry, not by medical or toxicology experts. Its purpose is to protect sales,
States that passed the KCPA continue to see addiction, poison center calls, emergency room visits, and kratom related deaths. The KCPA does not place real caps on potency. It does not control online sales. Local agencies have no practical way to enforce it. And banning 7OH alone is pointless because mitragynine naturally converts to 7OH once it is inside the body.
The industry is already developing new derivatives like MGM 15 and MGM 16. A full ban is the only approach that closes the loopholes and keeps this opioid acting substance out of your community.
I know bans are not easy decisions. But I also know what it feels like to stand in my daughter’s empty bedroom and wonder how something sold as a “natural herb” destroyed her life. I would give anything to go back and warn her. I can’t. But I can warn you.
I am asking you to put a ban on kratom so
no family has to learn the same lesson through the loss of a child parent spouse or friend. Thank you for taking the time to listen and for putting the safety of your residents first.
Public Comment in Support of the Orange City Kratom Prohibition Ordinance
Good evening Mayor and Councilmembers,
My name is Wendy Chamberlain. I am the founder and Chair of Kratom Danger Awareness, Inc., a national nonprofit, and I am here today as a mother who lost her only child because the dangers of kratom were never made clear.
My son, Joseph S. Lumbrazo, was a healthy, hardworking father of three. He did not use illicit drugs. He did not use prescriptions. He used plain kratom leaf powder, sold legally and marketed as a “natural” and “safe” supplement for energy. On August 30, 2020, Joseph died from mitragynine toxicity, the primary active alkaloid in kratom.
Seeing something sold openly in gas stations and smoke shops listed as the cause of your child’s death is something no parent should ever experience.
This ordinance is important because regulation has not worked. Across the country, states that chose regulation instead of prohibition have seen continued injuries, poison center calls, addiction, and deaths. Products are mislabeled, adulterated, or sold with little to no meaningful warnings. Enforcement is inconsistent, and the market simply shifts to new formulations and more potent derivatives.
Local governments like Orange City are often the first line of defense when higher levels of government fail to act quickly enough. Prohibiting kratom is not about criminalizing people—it is about preventing harm, protecting families, and stopping a dangerous product from being sold as a harmless supplement.
I urge you to support this ordinance and take a clear, decisive stand for public health and safety. Your action here has the power to prevent future tragedies like mine.
Thank you for your time, your leadership, and your commitment to protecting your community.
Please do not pass Ordinance 01-26 as currently written at today’s meeting. While much of the ordinance is well intentioned, it unintentionally bans natural kratom leaf rather than targeting the products that pose the greatest risk to public health.
You correctly identified that 7-hydroxymitragynine (7-OH) and synthetic kratom derivatives are dangerous and should be removed from store shelves. These products are strong, synthetic, highly addictive, and have no established safety record. Natural kratom leaf is fundamentally different. It contains only trace amounts of 7-OH and has extensive scientific research supporting its relative safety when sold in a regulated marketplace.
Kratom is a natural plant, not a synthetic isolate. Hundreds of peer-reviewed studies on kratom’s chemistry, pharmacology, and public health impact show:
• Natural kratom leaf does not activate the same biological pathway responsible for opioid-related respiratory depression
• Preclinical studies demonstrate lower addiction potential than traditional opioids
• National surveys show many adults use kratom to improve daily functioning or reduce reliance on more dangerous substances
• A recent randomized, double-blind human study found encapsulated kratom leaf powder to be well tolerated with no serious short-term safety concerns
• The most serious harms are consistently linked to adulterated, contaminated, or synthetic products—not natural leaf kratom
Riverside set an important precedent in California by banning products above a 2% alkaloid fraction (targeting 7-OH) while allowing regulated natural leaf kratom. Other jurisdictions that have taken this balanced approach include Orange County, Huntington Beach, Fresno City, Fresno County, Riverside, and Laguna Niguel. These policies protect consumers without driving them into illicit markets.
At a July 29, 2025 press conference, the FDA and HHS made clear they support scheduling 7-OH products while leaving natural kratom legal. They have formally requested that the DEA begin the scheduling process for 7-OH—but not kratom itself.
A ban on possession and sale of natural kratom removes the city’s ability to regulate, test, or label products and eliminates oversight altogether. Regulation provides tools; prohibition takes them away.
A regulatory framework modeled on the Kratom Consumer Protection Act would allow Orange to:
• Set age limits
• Require product testing
• Ensure accurate labeling
• Limit high-potency extracts
• Explicitly prohibit synthetic or semi-synthetic derivatives such as 7-OH, pseudoindoxyl, and MGM-15 & 16
This approach directly addresses the sources of harm while preserving access to a plant-based product many adults use responsibly.
Thank you for your time and for considering a practical, public-health-focused path forward. I am happy to provide education, research materials, or assist with ordinance refinement.
Sincerely,
Lora Romney
President, International Plant & Herbal Alliance
Thank you for taking the time to hear this written request. I am writing to advocate for raw leaf kratom, asking that the board consider regulating raw leaf kratom while outright banning the synthetic product known as “7-OH.”
Currently, there is widespread misinformation/miseducation in the public media regarding kratom’s safety.
Unfortunately, the synthetic product 7-OH has appeared in smoke shops across America, marketed as a kratom product over the last 2 years causing problems with break-ins at smoke shops (to steal the product) concerns of children under the influence while also possibly being linked to some overdose deaths;.
Most 7-OH products are displayed alongside Raw Leaf Kratom products misleading consumers all the more while also trying to entice the younger under aged consumers with brightly colored packaging using familiar cartoon characters and grandiose wording to further entice others who are not looking for a maintenance level adjustment but seeking more of a "trainwreck" like experience.
While 7-OH shares a common alkaloid with kratom, it is in fact a very different substance—chemically manipulated and derived from compounds similar to those found in pool-cleaning solvents. It is far stronger and far more dangerous than natural kratom.
There is several years of reliable scientific fact based evidence of raw leaf kratom's safety and use over 100 to possibly thousands of years. Used for pain management, mood enhancement, energy or even soothing withdrawal symptoms for those with SUD. Kratom has been a savior for millions in America allowing them to remain in the community as productive individuals seeking self help and independence.
And you may hear from organizations like “Mothers Against Kratom.” or the "Kratom Danger Awareness" group that have testified in Congress and receiving support from state legislatures and others who have professional medical license to push for kratom bans. At the same time, not recognizing, ignoring, or are they possibly being misled that the pharmaceutical interests—including those tied to opioid treatment medications like Suboxone—have financial incentives to oppose kratom’s legalization?. Medical professionals prefer medications over nature though the natural supplements come with far less side effects or adverse effects as compared to medications such as Suboxone. Relying on shorter trial times than that of kratom's known historical use is several countries as well as information available in the U.S. If one would "Follow the money"funding these advocacy groups , much of their support is coming from these medical professional groups standing on their "institutional and clinical success" within the prescription treatment regime and (ironically) their stance that addiction is the problem and not the initial prescribing issues, be it the weaning or length or strength of initial prescription that got the patient needing treatment in the first place.
I respectfully ask that you consider the lead of the several states across the US that have adopted Kratom Consumer Protection Act–style regulations, ensuring safe access to raw leaf kratom while banning 7-OH altogether.
Raw leaf kratom has been shown to provide beneficial and positive support for harm reduction, particularly for individuals struggling with opioid use disorders and chronic pain.
Thank you for your time and consideration
I oppose this potential ban on kratom. My concern is that the ordinance does not distinguish between traditional kratom leaf and newer high-potency 7-OH products, which have very different risk profiles.
A blanket ban on all kratom products removes lower-risk, widely used products from the legal market while failing to specifically target the newer concentrated products that are driving safety concerns. In many cases, broad prohibitions like this can make enforcement harder and unintentionally push consumers toward unregulated alternatives.
I respectfully encourage the Council to consider a narrower approach that:
* Allows regulated sale of kratom leaf with appropriate safeguards, and
* Specifically prohibits or restricts 7-OH products.
Thank you for considering this perspective as you review the ordinance.
To whom it may concern,
I write to you today to ask that you vote NO on this ordinance. My partner has chronic pain that makes normal activities, that the able bodied have no problem doing, almost impossible most days. With the crackdown by the government on pain relieving drugs, things have been even harder.
Thankfully she found natural kratom that has made things more bearable for her. With the help of natural kratom she has been able to live her life. It has been such a life saver.
I hate seeing her in pain and natural kratom has made her feel better.
Thank you for your time.
Kratom (Mitragyna speciosa) has a long history of traditional use in Southeast Asia as a natural, whole-plant remedy for pain management, fatigue, and opioid harm reduction. When consumed in its natural, unaltered leaf form, kratom functions as a mild, plant-based medicine with a comparatively low risk profile.
The primary public-health concerns associated with kratom in the United States are overwhelmingly linked not to raw kratom leaf, but to high-potency kratom extracts and synthetic concentrates. These products dramatically alter the plant’s natural alkaloid balance, increase dependency risk, and have been disproportionately associated with adverse events, misuse, and hospitalizations.
Whole-leaf kratom contains a complex spectrum of alkaloids that naturally moderate one another, producing a ceiling effect that reduces the likelihood of respiratory depression and overdose. Extracts, by contrast, bypass this natural safeguard by isolating and amplifying specific alkaloids—particularly mitragynine and 7-hydroxymitragynine—creating pharmacological effects that are fundamentally different from traditional use.
From a regulatory and public-health perspective, banning or restricting kratom extracts while protecting access to raw, unadulterated leaf kratom represents a balanced, evidence-based approach. This strategy:
Reduces harm and abuse potential
Preserves access for individuals using kratom as an alternative to opioids
Respects traditional and medicinal plant use
Encourages transparency, quality control, and responsible consumption
Prohibition of whole-leaf kratom risks pushing consumers toward illicit markets or more dangerous substances, while failing to address the true source of harm. Regulation should therefore focus on product purity, labeling, age restrictions, and the elimination of concentrated extracts, rather than blanket bans that ignore critical distinctions within kratom products.
In summary, raw kratom leaf is best understood as a medicinal plant, not a synthetic drug. Sensible regulation—rather than prohibition—can protect public health while honoring both scientific evidence and traditional practice.
Hello my name is Mariana otero and i grew up here in orang. I
Im writing to give you a little perspective on kratom and how its changed my life for the better.
About 25 years ago I suffered a tragic accident that left me with debilitating pain.
I was given opiods by my doctor's which lead me to become dependant.
Throughout the next few years I had 3 massive back surgeries and dozens of other treatments to address my Injuries. But the main one was opiods. A lot of them. I became both an addict and a chronic pain patient taking up to 60 pills a day to get by. Id develop tolerance and then they would increase my dosage and type of narcotic.
I was a walking zombie on long term disability.
My constant desire to get clean and off these meds lead my to be in and out of rehab facilities. Many hospitals stays where I would be chemically detoxed by doctors and nurses.
The times I would be free of the addiction I would be confronted with the chronic pain of my injuries. I was a prisoner to opioids.
Unable to work, exercise or have healthy relationships with friends and family.
Until I discovered kratom.
Kratom saved my life. It allowed me to be able to cope with my chronic pain as well as allow to have a normal quality of life off of opiods.
I now work full time, work out 6x a week and feel liberated from years of constant withdrawals and addiction.
Its allowed me to again be able to have good relationships with family and friends.
With 8 little grams of a green natural powder a day I feel great. All while never needing to increase the dose. It keeps me pain free and helps my depression and anxiety all while never needing to take the poison that stole so many years of my life.
So I ask you to please keep natural kratom leaf legal and accessible. I am in favor of banning 7-oh which is not kratom leaf. Its a synthetic form that 100x the strength and very dangerous.
I ask that you consider regulating kratom like more than a dozen other states and cities have done. Wirh the the kratom consumer protection act
Which would ensure kratom products are not adultered, it would limit sales to individuals at least 18 or 21 years and require proper labeling.
Kratom has saved so many lives and gives people a natural way to cope with debilitating conditions including chronic pain and depression.
If you took this plant away my whole world would fall apart and I would be forced to turn to very dangerous opiods again and that would surely destroy my life. I would lose everything I've built and back to a life of active addiction.
My story is just one of millions. Kratom is safe and a miracle to people like me.
Thank you for listening and considering my story. I know you'll make the right decisions.
With love,
Mariana Otero
424 450 8948
Hello Council Members,
I am writing to respectfully oppose any proposed ban on kratom. Kratom has helped me significantly manage chronic pain with no negative side effects and without making me feel impaired or “under the influence” in any way. Because of kratom, I am able to function normally, remain clear-headed, and continue working a very stressful job.
That ability to work is not a small thing. It allows me to support myself, pay a substantial amount in taxes, and contribute to society in a meaningful way. Without kratom, my pain would be far more limiting, and my quality of life — as well as my ability to remain productive — would be seriously compromised.
Many people rely on this natural plant to get through their day. It helps manage pain effectively without producing a “high,” without intoxication, and without the severe side effects or risks associated with many prescription pain medications. For countless individuals, kratom is the difference between participating in daily life and being sidelined by pain.
It is deeply concerning and disheartening to see kratom placed on the agenda for a potential ban, especially when it is being grouped with or conflated with 7-hydroxymitragynine (7OH). I strongly urge the Council to research kratom itself, not just isolated compounds, and to understand the important differences between the whole plant and synthetic or concentrated extracts.
Most importantly, I ask that you listen carefully to the public comments submitted here and shared in person tonight. You will hear from many people whose lives have been positively impacted by kratom — people who are parents, workers, caregivers, and contributing members of the community.
Please consider regulation, education, and quality control rather than prohibition. A ban would not protect people like me; it would only take away a tool that allows us to live functional, productive, and pain-managed lives.
Thank you for your time, your consideration, and for listening to the voices of the people this decision will directly affect.
Hello,
I am an LA county resident. I'm writing as a constituent and a responsible kratom user of eight years. I use natural leaf kratom for pain management and as a safer alternative to caffeine, and it has significantly improved my quality of life.
I want to be clear that I am strongly opposed to adulterated kratom products, specifically highly concentrated 7-OH (7-hydroxymitragynine) products. These are not representative of traditional, natural leaf kratom and should be regulated or restricted separately. I fully support strict standards to prevent unsafe, synthetic, or manipulated products from being sold.
At the same time, I am in full support of natural leaf kratom and believe it should remain legal with sensible regulation. A full ban would harm responsible consumers like myself and push people toward unregulated and unsafe alternatives. Regulation, not prohibition, is the best way to protect public health.
I respectfully urge you to oppose any blanket ban on kratom and instead support policies that distinguish between dangerous adulterated products and responsibly sold natural leaf kratom.
Thank you for your time and for your commitment to public safety.
Sincerely,
Paul Todisco
Mayor and Members of the Orange City Council,
My name is Jordan Richard, and I appreciate your time and consideration.
For the past 13 years, I have dedicated my life to studying kratom. I have traveled across the United States and internationally, interviewing researchers, clinicians, toxicologists, and regulators, including experts associated with Johns Hopkins and the FDA. Through this work, I have developed a practical understanding of kratom and how it is used in the real world. I am also the author of one of the most widely read books on kratom, written to help policymakers separate science from speculation.
I want to highlight the position of California’s own narcotics authorities. The California Narcotic Officers Association does not call for banning kratom. Instead, it supports regulating traditional kratom leaf while banning high-potency synthetic products such as 7-hydroxymitragynine, often referred to as 7-OH.
If the kratom leaf itself posed a public safety risk, law enforcement would recommend prohibition. They have not, because they recognize a clear difference between traditional kratom leaf and synthetic derivatives. One is presenting problems. The other is not.
This same framework has been adopted across California, including Orange County. Cities have chosen regulation over prohibition because it is targeted, enforceable, and evidence-based.
Federal regulators share this view. The current FDA Commissioner has stated that the FDA is not concerned with traditional kratom leaf, but rather with high-potency synthetic products. The FDA has also released its first human-focused study on kratom, funded directly by the FDA, concluding that kratom appears to be safe even at high exposure levels.
Banning 7-hydroxymitragynine is not difficult to enforce. Jurisdictions already do this by limiting total 7-hydroxy content to two percent or less, directly targeting synthetics while allowing regulated traditional products.
Independent research has found that kratom has a relatively low potential for abuse compared to traditional opioids, with a safety margin roughly one thousand times greater than prescription opioids.
I also speak from lived experience. I am a former heroin addict and today a business owner and father of five. Addiction involves compulsive behavior despite harm. Physical dependence simply reflects adaptation. Many people are physically dependent on prescribed medications, including antidepressants, without being addicted. That distinction matters here.
Traditional kratom leaf has been used daily by millions of people in Southeast Asia for over 1,000 years, including Indigenous communities such as the Dayak people of Borneo, with no documented deaths attributed to traditional use. The concerns being raised today are recent and align with the emergence of synthetic and concentrated products.
Regarding liver injury, the NIH’s LiverTox database reports 26 potential cases among an estimated 20 million U.S. users, approximately 0.00013 percent. Context matters when evaluating risk.
The question before the City of Orange is not whether to allow something harmful, but whether to regulate responsibly while drawing a clear line against synthetics.
Respectfully,
Jordan Richard
Author, The Truth About Kratom: Life-Saving Plant or Botanical Menace?
I am submitting this comment in strong support of Ordinance No. 01-26, and I do so as a parent who has already paid the highest possible price for kratom being legal, normalized, and aggressively defended.
My son, Austin, was not a drug user. He was a normal young man with plans, relationships, and a future. He worked, he laughed, and he believed—because he was repeatedly told—that kratom was a “natural” and safer product.
That belief did not come from science.
It came from organized industry messaging.
Groups such as the American Kratom Association and the Global Kratom Coalition promote kratom as safe, minimize documented harms, and flood public hearings with user testimony designed to normalize continued access. They frame themselves as advocates, but function as trade organizations whose primary goal is protecting sales, not lives.
On December 6, 2023, my son Austin died alone in his bedroom after consuming a kratom product he believed was legal and safe.
His official autopsy and toxicology report, completed by the Montgomery County, Ohio Coroner, determined:
• Cause of Death: Intoxication by mitragynine
• Toxicology: Mitragynine only
• No fentanyl, no illicit drugs, and no prescription opioids present
• Findings: Pulmonary edema and frothy airway fluid, consistent with opioid-type respiratory depression
This was not a contaminated product.
It was not mixed with alcohol.
It was not misuse in the way advocates often imply.
It was the predictable pharmacological effect of kratom itself.
Kratom’s primary alkaloid, mitragynine, is opioid-active and is converted by the human liver into 7-hydroxymitragynine, a compound more potent than morphine. No warning label, dosage suggestion, or “responsible use” guideline can prevent that biological conversion.
And this is the point that is rarely said out loud:
When kratom users stand at podiums and say “this pure leaf powder got me off morphine, oxycodone, heroin, or fentanyl and saved my life,” they are not proving safety.
They are proving opioid equivalence.
A substance does not replace heroin unless it acts on the same opioid receptors. A product does not suppress withdrawal unless it has clinically meaningful opioid potency. You cannot simultaneously argue that kratom is weak and harmless while also claiming it is powerful enough to replace heroin.
Those statements are not evidence of safety.
They are admissions of dependence-forming potency.
Public health is not decided by who feels better today. It is decided by mechanism of action and population-level harm. And by their own words, kratom users are describing opioid substitution—not a dietary supplement.
Austin believed kratom was safe because it was legal, sold openly, and defended loudly. That false sense of safety cost him his life.
Local governments exist to protect residents when higher systems fail. Ordinance No. 01-26 is a responsible and necessary use of the City’s police power to stop the commercial sale and distribution of a product with no FDA approval, no accepted medical use, and real, documented fatalities.
Please do not allow emotional testimony or outside trade groups to override medical reality. This ordinance is not about judging users—it is about preventing the next family from standing where mine is now.
I respectfully urge the City Council to adopt Ordinance No. 01-26.
Thank you for your time and for choosing public safety over industry pressure.
My name is Susan Cave and i fully support 3.6
My son, William, died in 2024 from a toxic mixture of raw leaf kratom and his prescribed antidepressants. He started using kratom to supplement his antidepressants to treat his anxiety & depression. Everything he and I read on-line said it was safe and all natural and MARKED with a Good Manufacturing Practice stamp of approval. Will took kratom for about 1 year before he realized he'd become dependent. He kept having to up the dose to achieve the same desired effect. Will spent the last 3 years of his life trying to withdraw from kratom..it was a vicious cycle full of embarrassment, feelings of hopeless and helplessness.
You will hear from the pro kratom community which consists of chronic pain suffers and drug addicts who claim the can not possibly function without kratom. All I can tell you is I lost my son--HE IS DEAD--because kratom is readily available in gas stations, smoke shops and on-line. How can a person be a responsible kratom consumer if so little is know about how to consume kratom safely. No lethal dose has been established, no studies of how kratom interacts with other drugs, no studies how kratom might effect a person with pre-existing health conditions or how chronic use effects the body. I honestly cant even believe my son is dead when kratom is not even suppose to be in this country...why won't the DEA enforce IMPORT ALERT 54-15 ?? I sincerely applaude the efforts of the people on this committee in keeping your citizens safe from this deadly poison...SusanCave
It makes no sense to punish the 97% of responsible adult citizens because of adverse events from the 3% addiction (profile) be mindful that addiction is a mental illness that infects family members, co-dependency also a mental illness. That’s equal to banning guns because of the unstable users and criminals. I’m offended as a USMC veteran and a working senior citizen that laws are shaped because of the 3%. To add insult to injury to ban kratom is a “death sentence “ to untold thousands of responsible citizens who have broken no laws or misuse this natural leaf product, none of this makes sense especially when quality,enforced regulations are the practical solution. SMH
My name is Susan Eppard,
In 2021 my 22 year old son Matthew Eller died from whole leaf Kratom Powder (the least potent form of Kratom available in the United States). Kratom caused him to have a seizure, go into cardiac arrest and die. His toxicology showed he died from the “TOXIC effects of Mitragynine” an alkaloid found only in Kratom. He had no prescription drugs, no street drugs nor alcohol in his system when he died, and his autopsy showed he had no underlying health conditions. It’s important to note my son didn’t die from 7-OH/7-hydroxymitragynine.
Hello, my name is Bunny Baker and I'm from Tulare County Ca
Pure, plain leaf powder Kratom has had a profoundly positive impact on my quality of life. Before I started using it, I had been diagnosed with severe depression and struggled with chronic migraines. My days were often spent in bed, exhausted and unmotivated. I felt disconnected from my family and from life itself.
Since incorporating kratom into my wellness routine, I’ve experienced a complete turnaround. My energy levels have improved dramatically, and my migraines have become far less frequent. Most importantly, the heavy cloud of depression that once controlled my life has lifted. I now wake up feeling motivated and capable.
I’m an involved mother, a supportive wife, and an active member of my community. I’ve been able to return to regular exercise, eat healthier, and live fully again—something I never thought I’d be able to say.
Kratom hasn’t just improved my mood; it’s given me back my sense of purpose, balance, and well-being. It’s helped me reduce dependence on antidepressants and reconnect with life in a natural, sustainable way.
Please regulate and keep lab tested plain leaf kratom legal.
Thank you,
Bunny Baker
Public Testimony Regarding Natural Kratom
City of Orange
Good evening Mayor and Council Members,
My name is Christopher Deaney. I am a lifelong American, a small business owner, and someone who has lived with chronic pain since childhood after being struck by a car at the age of eight.
For many years, I followed the traditional medical path and was prescribed opioid pain medications long-term. While legal and doctor-prescribed, those medications came with escalating risks. In 2015, after careful research and consideration, I transitioned away from that path and began using plain, natural kratom leaf prepared as a traditional tea.
I want to be very clear about what I am speaking about tonight.
I am not here to defend synthetic products, isolated alkaloids, or highly concentrated substances being sold under the name “kratom.” I share concerns about those products, and I believe they should be addressed directly through regulation or removal.
What I am asking you not to ban is natural kratom leaf.
This distinction is supported by the American Herbal Products Association (AHPA), the national trade organization representing the herbal products industry. In 2025, AHPA published a new entry in its Botanical Safety Handbook recognizing Mitragyna speciosa leaf as a traditional herbal material and clearly distinguishing it from synthesized or chemically altered kratom alkaloids. AHPA has also issued guidance stating that synthetic kratom alkaloids should not be conflated with the natural botanical.
This information is publicly available here:
https://www.ahpa.org/blog_home.asp?Display=279
Policy works best when it is based on accurate classification. Treating natural leaf the same as synthetic or altered products misidentifies the risk and leads to unintended consequences.
Natural kratom is a whole-plant botanical related to the coffee family. In its traditional form, it has been used responsibly in Southeast Asia for generations and by millions of Americans for over two decades. For people like me, it functions as a stability tool, not an intoxicant and not a recreational drug.
History consistently shows that blanket bans do not eliminate demand. They push responsible adults away from transparent products and toward unregulated or illicit alternatives. That outcome increases risk rather than reducing it.
If the City’s goal is public safety, a more effective approach is targeted regulation, not prohibition:
• Distinguish natural leaf from synthetic or altered products
• Require proper labeling and testing
• Keep products out of the hands of minors
• Hold bad actors accountable without punishing responsible consumers
I am also a father, and I take public safety seriously. That is why I am asking the City to focus on the real sources of harm rather than removing a traditional botanical that many adults use responsibly to maintain quality of life.
Natural kratom leaf is not the problem.
Lack of distinction is.
Please consider an evidence-based, balanced approach that protects public health without unintended harm.
Thank you for your time and consideration.
Respectfully,
Christopher Deaney
Hello Mayor, Councilmembers, and staff,
Please do not pass Ordinance 01-26 as currently written. The draft unintentionally bans natural kratom leaf instead of focusing on the products that actually pose the highest risk to public health.
You correctly identified that 7-hydroxymitragynine and synthetic kratom derivatives are dangerous and should be removed from stores. These are potent, highly addictive, and lack safety data. Natural kratom leaf is different. It contains only trace 7-OH and has research supporting its relative safety in a regulated market.
Scientific evidence shows that natural leaf kratom:
• Does not trigger the respiratory depression pathway associated with opioids
• Shows lower addiction potential in preclinical studies
• Is used by adults to improve daily functioning or reduce more dangerous substances
• Was well tolerated in a recent randomized, double-blind human study
• Causes serious harm mainly when adulterated or synthetic
Other California jurisdictions, including Riverside, Orange County, Huntington Beach, Fresno, and Laguna Niguel, allow regulated natural kratom while prohibiting high-potency extracts and synthetics. This protects consumers without pushing them to illicit markets.
In July 2025, FDA and HHS stated they support scheduling 7-OH products but not natural kratom. They have formally asked DEA to begin scheduling only 7-OH.
Banning natural leaf eliminates oversight and testing. Regulation allows for age restrictions, product testing, labeling standards, limits on extracts, and explicit prohibition of synthetic derivatives.
A regulatory approach addresses the real sources of harm while preserving responsible access for adults.
Thank you for considering a practical and public-health-focused solution. I am happy to provide research or assist with refining the ordinance.
Hello Mayor, Councilmembers, and staff,
My name is Anthony Rosa, and I’m a lifelong California resident. I’m 29 years old, and I’ve been a kratom user for six years. I’m not here to defend synthetic 7-hydroxy derivatives — I’ve never used them, and I fully agree they should be restricted. But please don’t punish responsible adults who use natural kratom leaf powder. It’s a mild, traditional plant that has been safely used for generations. Kratom is NOT 7-OH.
I still struggle every day with anxiety, stress, and depression. The pressure of my life is constant, but kratom is what gets me through it. It’s the only thing that keeps me functional, stable, and able to provide for my family. Without it, I would likely fall back into alcoholism.
Kratom didn’t turn me into an addict — It helped me overcome crippling lethargy, rebuild my motivation, and become a small business owner. I am living proof that kratom can save lives.
Lumping lab-tested kratom leaf together with synthetic 7-OH is a scientific and moral mistake. Those synthetic capsules contain up to a thousand times the alkaloid concentration of natural kratom powder. Even The federal dept of health and human services. reached out to the state in late September urging California to make that distinction clear. Texas chose a 7OH limit over a blanket ban. Why can't we? The actions of our state public health department are authoritarian, and are not making that distinction.
How can we allow adults to legally buy alcohol and cigarettes — substances proven to kill — yet criminalize a natural plant that helps people live?
Please, Do not force people like me back into despair and addiction.
Thank you for your time and compassion.
Good afternoon,
My name is Holly Trouville and I am writing to you as a mother who lost her only child Ty, to mitragynine toxicity, on February 6th, 2024. I am not a lobbyist, a business owner making money, nor a user. My only goal is to prevent any parent from feeling the complete and utter devastation I felt losing my only child. I am trying to prevent having a parent only be able to speak to their child, 6 feet under, in a cemetery.
Mitragynine toxicity was Tyrell’s sole cause of death, with no secondary causes nor opioids in his system. And, it was ruled as only an accident. Tyrell died from a Kratom seltzer drink that is marketed as caffeine free, sugar free, and alcohol free. He drank them at the Kava bar he would go to.
Regulation does not work, as much as people may think it does. The majority of deaths are men over 21, to regulate under 21 is futile. Due to there being no federal regulations, oversight, nor FDA approval, we do not know if mixing anything with Kratom, even something such as Benadryl or prescription medicine will give an adverse effect. There is not enough information known to say how much could be taken to prevent an adverse effect. There is no labeling saying what could cause an adverse effect. There are also no dosage recommendations on any of these packages. So when talking about selling Kratom to uninformed consumers, people who are looking for help and trusting sellers to do the right thing, that is not always happening.
Here are proven facts. The majority of people using whole leaf, synthetic, or 7OH are recovering addicts. You can hear it in almost every hearing. Why did Fell Free Wellness Tonic, one of the largest sellers of Kratom drinks, have to pay 8.75 million dollars and add a disclaimer on the back of their can stating "Individuals with a history of substance abuse are advised against use." If it is so natural, why can’t you use it if you have a history of substance abuse and why does it state you should consult a physician before trying it, if you are on any medication? This should be gravely concerning to you.
You will hear people testify that veterans use it to help them with their PTSD. Then please answer this, why did the DOD ban Kratom in ALL armed forces? Use of it is punishable by the Uniform Military Code of Justice. That in and of itself is telling. The DOD obviously does not believe it benefits military people. I could go on and on but these are just a couple examples of how Kratom, in all forms, is being recognized as dangerous, addictive, and deadly.
I implore you to ban ALL forms of Kratom, natural and synthetic. You will be saving more lives than not. Lastly, all of these people testifying that Kratom has saved their life, that is opinion only. I have yet to see one letter from a doctor stating that it has saved a life. You will not see that because a doctor will not put their stamp on that. However, I have a letter from a doctor stating that Kratom took my son’s life. Death certificates do not lie, autopsy reports do not lie.
Please don’t allow another parent to have to live the rest of their life without their child, due to a substance that if it already hasn’t, will kill some of the people you represent..
Thank you and with much respect,
Holly
Im in full support for a full ban on kratom. My perspective comes from a loss no parent should ever experience. My daughter Kielee died on March 1st 2025 of a mitragynine overdose. She was only 23. Because she was so young they had to do an investigation. After an autopsy and toxicology screen was preformed mitragynine overdose was determined to be the factor of death.
Kratom took my daughter's life and robbed the world of the light she brought into it. She trusted the word natural. Kielee used the natural kratom powder. She believed it was safe to use for pain because that is how the industry markets it. She was not using extracts or 7OH products. The leaf itself killed her. Regulations wouldn't have saved her because she was 23 and didn't buy it from a gas station.
Mitragynine and 7OH both bind to the same opioid receptors as morphine. The idea that the natural powder is harmless while only certain extracts are dangerous is not supported by what is happening in real families. Both forms take lives.
My state of Idaho reported 83 kratom involved deaths between 2020 and 2024. Bonneville County recorded six deaths in eighteen months. Four were from mitragynine alone one of was my daughter. Mitragynine overdose is what i have to read on her death certificate. These deaths mirror what other states are seeing, especially as kratom becomes more available in small shops and gas stations.
I want you to understand this because your decision will shape what families in your community face. Parents don’t know what it is. Young people assume it’s safe. The reality does not match the marketing.
You may hear the argument that the Kratom Consumer Protection Act is the safer middle ground. It is important to understand what the KCPA actually is. It was written and promoted by the kratom industry, not by medical or toxicology experts. Its purpose is to protect sales,
States that passed the KCPA continue to see addiction, poison center calls, emergency room visits, and kratom related deaths. The KCPA does not place real caps on potency. It does not control online sales. Local agencies have no practical way to enforce it. And banning 7OH alone is pointless because mitragynine naturally converts to 7OH once it is inside the body.
The industry is already developing new derivatives like MGM 15 and MGM 16. A full ban is the only approach that closes the loopholes and keeps this opioid acting substance out of your community.
I know bans are not easy decisions. But I also know what it feels like to stand in my daughter’s empty bedroom and wonder how something sold as a “natural herb” destroyed her life. I would give anything to go back and warn her. I can’t. But I can warn you.
I am asking you to put a ban on kratom so
no family has to learn the same lesson through the loss of a child parent spouse or friend. Thank you for taking the time to listen and for putting the safety of your residents first.
Sincerly, Tia
Public Comment in Support of the Orange City Kratom Prohibition Ordinance
Good evening Mayor and Councilmembers,
My name is Wendy Chamberlain. I am the founder and Chair of Kratom Danger Awareness, Inc., a national nonprofit, and I am here today as a mother who lost her only child because the dangers of kratom were never made clear.
My son, Joseph S. Lumbrazo, was a healthy, hardworking father of three. He did not use illicit drugs. He did not use prescriptions. He used plain kratom leaf powder, sold legally and marketed as a “natural” and “safe” supplement for energy. On August 30, 2020, Joseph died from mitragynine toxicity, the primary active alkaloid in kratom.
Seeing something sold openly in gas stations and smoke shops listed as the cause of your child’s death is something no parent should ever experience.
This ordinance is important because regulation has not worked. Across the country, states that chose regulation instead of prohibition have seen continued injuries, poison center calls, addiction, and deaths. Products are mislabeled, adulterated, or sold with little to no meaningful warnings. Enforcement is inconsistent, and the market simply shifts to new formulations and more potent derivatives.
Local governments like Orange City are often the first line of defense when higher levels of government fail to act quickly enough. Prohibiting kratom is not about criminalizing people—it is about preventing harm, protecting families, and stopping a dangerous product from being sold as a harmless supplement.
I urge you to support this ordinance and take a clear, decisive stand for public health and safety. Your action here has the power to prevent future tragedies like mine.
Thank you for your time, your leadership, and your commitment to protecting your community.
Wendy Chamberlain
Kratomdangerawareness.org
Dear Orange City Council,
Please do not pass Ordinance 01-26 as currently written at today’s meeting. While much of the ordinance is well intentioned, it unintentionally bans natural kratom leaf rather than targeting the products that pose the greatest risk to public health.
You correctly identified that 7-hydroxymitragynine (7-OH) and synthetic kratom derivatives are dangerous and should be removed from store shelves. These products are strong, synthetic, highly addictive, and have no established safety record. Natural kratom leaf is fundamentally different. It contains only trace amounts of 7-OH and has extensive scientific research supporting its relative safety when sold in a regulated marketplace.
Kratom is a natural plant, not a synthetic isolate. Hundreds of peer-reviewed studies on kratom’s chemistry, pharmacology, and public health impact show:
• Natural kratom leaf does not activate the same biological pathway responsible for opioid-related respiratory depression
• Preclinical studies demonstrate lower addiction potential than traditional opioids
• National surveys show many adults use kratom to improve daily functioning or reduce reliance on more dangerous substances
• A recent randomized, double-blind human study found encapsulated kratom leaf powder to be well tolerated with no serious short-term safety concerns
• The most serious harms are consistently linked to adulterated, contaminated, or synthetic products—not natural leaf kratom
Riverside set an important precedent in California by banning products above a 2% alkaloid fraction (targeting 7-OH) while allowing regulated natural leaf kratom. Other jurisdictions that have taken this balanced approach include Orange County, Huntington Beach, Fresno City, Fresno County, Riverside, and Laguna Niguel. These policies protect consumers without driving them into illicit markets.
At a July 29, 2025 press conference, the FDA and HHS made clear they support scheduling 7-OH products while leaving natural kratom legal. They have formally requested that the DEA begin the scheduling process for 7-OH—but not kratom itself.
A ban on possession and sale of natural kratom removes the city’s ability to regulate, test, or label products and eliminates oversight altogether. Regulation provides tools; prohibition takes them away.
A regulatory framework modeled on the Kratom Consumer Protection Act would allow Orange to:
• Set age limits
• Require product testing
• Ensure accurate labeling
• Limit high-potency extracts
• Explicitly prohibit synthetic or semi-synthetic derivatives such as 7-OH, pseudoindoxyl, and MGM-15 & 16
This approach directly addresses the sources of harm while preserving access to a plant-based product many adults use responsibly.
Thank you for your time and for considering a practical, public-health-focused path forward. I am happy to provide education, research materials, or assist with ordinance refinement.
Sincerely,
Lora Romney
President, International Plant & Herbal Alliance
To whom it may concern,
Thank you for taking the time to hear this written request. I am writing to advocate for raw leaf kratom, asking that the board consider regulating raw leaf kratom while outright banning the synthetic product known as “7-OH.”
Currently, there is widespread misinformation/miseducation in the public media regarding kratom’s safety.
Unfortunately, the synthetic product 7-OH has appeared in smoke shops across America, marketed as a kratom product over the last 2 years causing problems with break-ins at smoke shops (to steal the product) concerns of children under the influence while also possibly being linked to some overdose deaths;.
Most 7-OH products are displayed alongside Raw Leaf Kratom products misleading consumers all the more while also trying to entice the younger under aged consumers with brightly colored packaging using familiar cartoon characters and grandiose wording to further entice others who are not looking for a maintenance level adjustment but seeking more of a "trainwreck" like experience.
While 7-OH shares a common alkaloid with kratom, it is in fact a very different substance—chemically manipulated and derived from compounds similar to those found in pool-cleaning solvents. It is far stronger and far more dangerous than natural kratom.
There is several years of reliable scientific fact based evidence of raw leaf kratom's safety and use over 100 to possibly thousands of years. Used for pain management, mood enhancement, energy or even soothing withdrawal symptoms for those with SUD. Kratom has been a savior for millions in America allowing them to remain in the community as productive individuals seeking self help and independence.
And you may hear from organizations like “Mothers Against Kratom.” or the "Kratom Danger Awareness" group that have testified in Congress and receiving support from state legislatures and others who have professional medical license to push for kratom bans. At the same time, not recognizing, ignoring, or are they possibly being misled that the pharmaceutical interests—including those tied to opioid treatment medications like Suboxone—have financial incentives to oppose kratom’s legalization?. Medical professionals prefer medications over nature though the natural supplements come with far less side effects or adverse effects as compared to medications such as Suboxone. Relying on shorter trial times than that of kratom's known historical use is several countries as well as information available in the U.S. If one would "Follow the money"funding these advocacy groups , much of their support is coming from these medical professional groups standing on their "institutional and clinical success" within the prescription treatment regime and (ironically) their stance that addiction is the problem and not the initial prescribing issues, be it the weaning or length or strength of initial prescription that got the patient needing treatment in the first place.
I respectfully ask that you consider the lead of the several states across the US that have adopted Kratom Consumer Protection Act–style regulations, ensuring safe access to raw leaf kratom while banning 7-OH altogether.
Raw leaf kratom has been shown to provide beneficial and positive support for harm reduction, particularly for individuals struggling with opioid use disorders and chronic pain.
Thank you for your time and consideration
Dear city council,
I oppose this potential ban on kratom. My concern is that the ordinance does not distinguish between traditional kratom leaf and newer high-potency 7-OH products, which have very different risk profiles.
A blanket ban on all kratom products removes lower-risk, widely used products from the legal market while failing to specifically target the newer concentrated products that are driving safety concerns. In many cases, broad prohibitions like this can make enforcement harder and unintentionally push consumers toward unregulated alternatives.
I respectfully encourage the Council to consider a narrower approach that:
* Allows regulated sale of kratom leaf with appropriate safeguards, and
* Specifically prohibits or restricts 7-OH products.
Thank you for considering this perspective as you review the ordinance.
Michelle Eagan-White
Tax Payer
Orange, CA