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 respectfully urge the Council to reconsider a full ban on kratom and instead adopt a more targeted, common-sense approach.
The easiest way to understand this issue is with a familiar analogy: coffee.
Coffee has been around forever. Millions of adults consume it safely every day. It is widely understood, regulated, and relatively low risk when used normally.
Now imagine someone isolates caffeine, chemically concentrates it, and sells it as a tiny pill or shot. People begin getting hurt because the effects are faster, stronger, and harder to control.
In that situation, you would not ban coffee.
You would regulate or prohibit the dangerous, high-potency caffeine products.
That distinction matters here.
Kratom leaf is like coffee. It is a whole-plant product, slower acting, and widely used by adults.
7-OH products are like super-potent caffeine pills. They are chemically manipulated, highly concentrated, and are where the real safety concerns originate.
Banning kratom leaf because of 7-OH products would be like banning coffee because someone created dangerous caffeine pills. It would not solve the underlying problem — and history shows that prohibition does not work. It tends to push consumers toward unregulated or higher-risk alternatives.
A more effective approach would be to:
Regulate kratom leaf, including age limits, labeling, testing, and manufacturing standards.
Prohibit or strictly regulate 7-OH products, which do not belong in the supplement marketplace.
This approach protects public health while avoiding unnecessary prohibition and ensures enforcement is focused on the products that actually pose elevated risk.
Thank you for your time and consideration as you deliberate this item.
My name is Justin Wolf, and I’m the Founder & CEO of New Brew, a California-based 21+ alcohol-free beverage company. Our products contain small, clearly disclosed servings of natural kratom leaf -- a botanical that has helped many adults, including myself, move away from alcohol.
I understand and respect your goal of protecting public health, especially for young people. However, I strongly urge you to reject Ordinance No. 01-26 if it includes a blanket ban on kratom. That approach is not common-sense public health policy -- it is prohibition, and it will cause real harm while failing to address the true source of risk in this category.
A full ban does not target bad actors. It targets responsible adults, people seeking alternatives to alcohol, and small businesses operating transparently and legally. It would effectively criminalize law-abiding residents for accessing a natural leaf product that remains legal federally and is already regulated responsibly in many states.
The core issue is that natural kratom leaf is being wrongly lumped together with 7-hydroxymitragynine (7-OH) isolate products. These high-potency, often synthetic products carry a drastically different risk profile. But 7-OH is not kratom. A blanket ban on kratom leaf will not stop 7-OH -- it will push everything underground, remove responsible sellers, and make enforcement harder.
We don’t claim kratom is risk-free. But regulation works better than bans.
California already has a framework underway through AB 1088, which would restrict sales to adults, require clear labeling and third-party testing, enforce potency limits, and ban synthetic or spiked products including 7-OH isolates. Many cities and counties have adopted similar approaches after reviewing the facts. Orange can do the same.
Bans do not eliminate demand -- they increase risk by driving consumers toward unregulated products that are more likely to be mislabeled, contaminated, or sold without age restrictions.
My request is simple: please reject Ordinance No. 01-26 if it includes a blanket kratom ban, avoid conflating natural kratom leaf with 7-OH isolates, and instead pursue common-sense regulation that protects residents while respecting adult choice and supporting responsible businesses.
Thank you for your time and thoughtful consideration. I would be happy to speak with City staff or Council members directly and provide additional information and consumer perspectives.
I oppose Ordinance No. 01-26 banning all kratom products in the City of Orange. Please protect the safe, plain leaf Kratom. My wife, Melody, has had a very positive experience with it. This is her story: My name is Melody Woolf, and I’ve been working on kratom advocacy at the local, state, and now federal level, focusing on reasonable policy and responsible regulation. Most recently, I participated in the July 29 HHS-FDA joint press briefing, where I was invited to the stage by the FDA Commissioner. I spoke about the benefits of kratom, shared how it has positively impacted my family, and clarified how it differs from the dangers associated with opioids. I also highlighted the importance of science-based regulation to protect consumers while ensuring access to safe, legal products.
On a personal note, I’ve lived with chronic pain for over 20 years and have several painful conditions. For eight years, when my kids were in elementary school, they had to keep a fan on in their room at night just to sleep because I was crying in pain nearly every night. Kratom has allowed me to reclaim my life, care for my family, and function without being debilitated by pain.
In 2022, when my daughter and son-in-law’s childcare shut down just before paternity leave, I was able to step in and care for my granddaughter for a year. I gladly moved in with them to help. The same thing happened this past summer: I watched my granddaughter all summer long, taking her to the zoo every week—the same zoo where, years ago, my kids had to push me around in a wheelchair, and now I was chasing my granddaughter around it. Kratom made that possible.
There are 50 to 100 million chronic pain patients in the United States. Every person with pain should have every tool in the toolbox available to manage their condition safely. Everybody is only one accident or diagnosis away from living with chronic pain. Please remove 708 and protect kratom with reasonable, science-based regulations so that patients like me and millions of others can continue to live productive, meaningful lives.
For more information and the related science, please see her LinkedIn profile: https://www.linkedin.com/in/melody-woolf-366a7b146?utm_source=share&utm_campaign=share_via&utm_content=profile&utm_medium=ios_app
I oppose Ordinance No. 01-26 banning all kratom products in the City of Orange. This proposal relies on broad federal agency statements and conflates ordinary kratom leaf with high-risk concentrated products such as 7-hydroxymitragynine, without distinction. California has no statewide kratom statute, and Orange County itself chose regulation rather than a total ban. An outright prohibition ignores less restrictive alternatives like age limits, product standards, and enforcement against specific high-risk products. I urge the City Council to reject a blanket ban and pursue a narrowly tailored, evidence-based regulatory approach instead.
To the City Council and Director of Code Enforcement:
My name is Stephen McIntosh, I spoke at the 1st reading of this agenda item as a chronic pain patient who uses kratom to manage my chronic pain. I won't spend your valuable time repeating what I said in the meeting here.
I would like to add a few items as they came to mind while listening to testimony from staff, and/or had time to think about them since the last meeting.
First: It is true that kratom has no approved medical purpose. This is because no dietary supplement is approved for specific medical purposes, though consumers do routinely take them for some benefit. Only drugs that go though the FDA New Drug Application process are approved for a specific purpose which allows vendors to make approved health claims such as fitness for a particular purpose. This is not a flaw or detriment, but by design under the Dietary Supplement Health and Education Act (1994) that sets a very different standard for dietary supplements that may be helpful. It is why they carry the notification "These statements have not been evaluated by the Food and Drug Administration. This product is not intended to diagnose, treat, cure, or prevent any disease.”
Second, for all FDA has said about kratom in media, by its own admission it has not made a determination about the safety of kratom when asked under oath. In the Federal Case "3:23-cr-00179-TWR Page ID.1032 Exhibit 6; United States of America, Plaintiff, v. Nine2Five, LLC (1) Sebastian Guthery (2), Defendants" the US attorney told the judge "They [FDA] have refused to provide us with witnesses or documents to support our position. The reason they gave was that they have not yet made a determination regarding whether kratom is dangerous."
Since this admission, it has conducted the Single Ascending Dose Study where test subjects were given up to 12 grams of botanical kratom and none experienced a severe adverse effect. The results are available as Trial NCT06072170 at: https://cdek.pharmacy.purdue.edu/trial/NCT06072170/
The FDA was also chastised by HHS in 2018 by then Undersec. Dr. Giroir for submissions to prohibit kratom as “embarrassingly poor evidence and data" when those were withdrawn by HHS.
CDPH is, at present, using these exact claims from FDA to justify their action, which FDA refused to make under oath, doesn't align with their newer studies, and that they have been chastised for in the past.
CA Narcotics Officers Assn, American Medical Assn (Res. 515), and the US Nat. Inst. for Drug Addiction support availability of botanical kratom for adults and further research.
I am again imploring you to re-consider this Ordinance to limit itself to adulterated high "7-OH" products and to exempt botanical kratom.
Doing so would create an ordinance in the City that is compatible with both SB 578 and AB 1088 that are progressing though the legislature with considerable support from legislators and members of the general public. These bills and the OC Ordinance limit sales to 21+, bar 7-OH products from sale, and prohibit products attractive to children (similar to regulations for marketing/labeling alcohol or tobacco).
It would allow for individuals such as myself who use it for important purposes, sometimes as a last resort or due to being under-treated by their limited medical options to still obtain botanical kratom which has been in regular sale since at least 2000 and centuries of indigenous use.
I am Abdullah Mamun, the owner of Authentic Kratom. For the past 12 years, I have operated as a responsible kratom retailer, committed to consumer safety, transparency, and regulatory compliance. I appreciate the City of Orange for bringing this important matter forward for discussion. I plan to attend in-person, but just in case sending my comment prior hand.
I respectfully oppose the proposed ordinance to ban “kratom products,” as the current language lacks clarity and risks unintentionally prohibiting natural kratom, which has been safely used by millions of Americans for decades. I believe this issue requires careful distinction between natural kratom and synthetic 7-hydroxymitragynine (commonly known as 7-OH) products.
Kratom is a natural botanical derived from Mitragyna speciosa, a plant belonging to the same plant family as coffee (Rubiaceae). Traditionally, kratom leaves are brewed into tea and consumed in many parts of Southeast Asia and the United States. Many consumers use kratom for energy, focus, and overall wellness, and in my personal experience, it has been helpful in managing chronic back discomfort.
Kratom contains multiple naturally occurring alkaloids, the primary ones being mitragynine and 7-hydroxymitragynine (7-OH). In natural kratom leaf powder, capsules, and even extracts, mitragynine is the dominant alkaloid, while 7-OH is present only in trace amounts. I have included laboratory test results demonstrating the full alkaloid profile of our products, which confirms these trace levels.
In contrast, around 2023, certain manufacturers began producing synthetic pills/liquids labeled as “7-OH”, containing unnaturally high concentrations of 7-hydroxymitragynine. These products do not reflect the natural composition of kratom and represent a fundamentally different—and far more concerning—category.
Research conducted by Dr. Chris McCurdy of the University of Florida College of Pharmacy, a leading authority in kratom science, has identified unknown and potentially dangerous chemical constituents in these synthetic 7-OH products (see attached study). Additionally, a comprehensive 8-factor abuse liability analysis conducted by Dr. Jack Henningfield and colleagues concluded that synthetic 7-OH presents a significantly elevated risk profile compared to natural kratom (see attached).
Furthermore, during a public press conference on July 29, 2025, the U.S. Food and Drug Administration (FDA) explicitly stated that natural kratom containing trace levels of 7-OH is not their regulatory target, and instead recommended that the DEA focus enforcement efforts on banning synthetic 7-OH products.
In summary, the emerging public health concerns are not caused by natural kratom, but rather by synthetic, chemically manipulated 7-OH products. I strongly urge the City of Orange to consider legislation that specifically bans synthetic 7-OH, while preserving legal access to natural kratom for the thousands of responsible adults who rely on it to maintain their quality of life—particularly when traditional treatments have failed.
That said, I fully support reasonable regulation of kratom, including strict age requirements, proper labeling, laboratory testing, and consumer education. At Authentic Kratom, we already enforce a minimum purchase age of 21, provide transparent labeling, and conduct rigorous third-party laboratory testing.
Thank you for your time and thoughtful consideration.
I urge you to reconsider this ordinace that would take away many chronic pain patients' quality of life. My kratom story: After waking up one day in 2005, paralyzed from my neck down, I was eventually diagnosed with Transverse Myelitis, and became a chronic pain patient. For years, I was able to manage my chronic pain with prescription medications, but eventually with more DEA cutbacks and new regulations over the years those were no longer an option for me. I was left to endure living in pain every single second of every single day just like so many other chronic pain patients in the same position. Luckily I discovered whole leaf kratom powder in May of 2019. I've been consuming it responsibly for 6 years and it has granted me a second chance at life! I no longer suffer every day, I can get out of bed and be a mom! I can go to school functions run errands, go to the store, and just live life without suffering. Though I regained mobility I still face many physical limitations, however I'm no longer confined by constant pain. Kratom gave me my life back. My story is just one of many chronic pain patients that have been able to manage their pain with kratom.
There is a big difference between natural whole-leaf kratom VS the semi-synthetic 7-OH products being marketed as kratom. I’ve been encouraged to see even the FDA has stepped in, not only to educate the public on this distinction, but also to warn about the risks of 7-OH. They’ve made it clear their concern is with 7-OH products, NOT with whole leaf kratom.
I’m asking you to support regulation instead of prohibition and keep natural, whole-leaf kratom legal. We need clear safety standards such as age restrictions, mandatory lab testing, accurate labeling, and limits on 7-hydroxymitragynine (7-OH). These are the kinds of measures that protect public health while preserving the freedom of choice for responsible adults.
Thank you so much for your time and letting me use my voice to represent the many others in the chronic pain community.
Sincerely, Jennifer Gillis
There is a critical scientific difference between whole-leaf kratom and the products being sold today as "7-hydroxymitragynine," or 7-OH.
Whole-leaf kratom is simply the dried leaf of Mitragyna speciosa. Its primary alkaloid is mitragynine. When someone consumes kratom, the human body naturally converts only a very small amount-typically well under one percent-into 7-OH through normal liver metabolism. This process is slow and self-limiting.
By contrast, the 7-OH products now appearing on the market contain laboratory-isolated or chemically converted 7-hydroxymitragynine in amounts far beyond what the human body could ever produce from kratom leaf. At those levels, 7-OH behaves much more like a conventional opioid and carries much higher risk.
When these high-potency 7-OH products are lumped with natural kratom, it leads to misleading risk assessments and poor public policy. Regulating or restricting 7-OH does not require banning whole-leaf kratom-and that distinction matters, because kratom saved my life.
From 2008 to 2019, I lived trapped in FDA-approved pain pills, benzodiazepines, and muscle relaxers prescribed for my degenerative disc disease. Over 11 years, chronic pain management turned into full-blown addiction. What began as dependency slowly became a cycle of misuse, desperation, and shame.
In April of 2019, I was dismissed from pain management after failing a required pill count. I was short on my medication and couldn't find what I needed. Cut off from prescriptions, I turned to the streets, and in that desperation, I slipped into cocaine use while trying to find another doctor.
By June of 2019, I was in withdrawal and at rock bottom when I watched a documentary called A Leaf of Faith. That moment changed everything. The next day, I walked into a shop, showed my ID, and bought whole-leaf kratom..not synthetic 7-OH.
Kratom quieted the relentless cravings. The voice that kept saying, "one more pill, one more snort, one more escape," finally went silent. For the first time in over a decade, I felt stable. Kratom gave me the breathing room to heal and allowed me to rebuild my life.
I have not returned to pain management in over six and a half years. Today, I am a thriving mother, a first-time grandmother, and a contributing member of society. I am no longer a burden to my children. I am an example of recovery.
I will always be grateful that I had access to safe, lab-tested, whole-leaf kratom. And that is why I speak out to protect others who are still fighting for their lives.
Dear Orange City Council,
I respectfully urge the Council to reconsider a full ban on kratom and instead adopt a more targeted, common-sense approach.
The easiest way to understand this issue is with a familiar analogy: coffee.
Coffee has been around forever. Millions of adults consume it safely every day. It is widely understood, regulated, and relatively low risk when used normally.
Now imagine someone isolates caffeine, chemically concentrates it, and sells it as a tiny pill or shot. People begin getting hurt because the effects are faster, stronger, and harder to control.
In that situation, you would not ban coffee.
You would regulate or prohibit the dangerous, high-potency caffeine products.
That distinction matters here.
Kratom leaf is like coffee. It is a whole-plant product, slower acting, and widely used by adults.
7-OH products are like super-potent caffeine pills. They are chemically manipulated, highly concentrated, and are where the real safety concerns originate.
Banning kratom leaf because of 7-OH products would be like banning coffee because someone created dangerous caffeine pills. It would not solve the underlying problem — and history shows that prohibition does not work. It tends to push consumers toward unregulated or higher-risk alternatives.
A more effective approach would be to:
Regulate kratom leaf, including age limits, labeling, testing, and manufacturing standards.
Prohibit or strictly regulate 7-OH products, which do not belong in the supplement marketplace.
This approach protects public health while avoiding unnecessary prohibition and ensures enforcement is focused on the products that actually pose elevated risk.
Thank you for your time and consideration as you deliberate this item.
Thank you for your time.
Best,
Jeff Michaels
Resident
Orange, CA
Dear Members of the Orange City Council,
My name is Justin Wolf, and I’m the Founder & CEO of New Brew, a California-based 21+ alcohol-free beverage company. Our products contain small, clearly disclosed servings of natural kratom leaf -- a botanical that has helped many adults, including myself, move away from alcohol.
I understand and respect your goal of protecting public health, especially for young people. However, I strongly urge you to reject Ordinance No. 01-26 if it includes a blanket ban on kratom. That approach is not common-sense public health policy -- it is prohibition, and it will cause real harm while failing to address the true source of risk in this category.
A full ban does not target bad actors. It targets responsible adults, people seeking alternatives to alcohol, and small businesses operating transparently and legally. It would effectively criminalize law-abiding residents for accessing a natural leaf product that remains legal federally and is already regulated responsibly in many states.
The core issue is that natural kratom leaf is being wrongly lumped together with 7-hydroxymitragynine (7-OH) isolate products. These high-potency, often synthetic products carry a drastically different risk profile. But 7-OH is not kratom. A blanket ban on kratom leaf will not stop 7-OH -- it will push everything underground, remove responsible sellers, and make enforcement harder.
We don’t claim kratom is risk-free. But regulation works better than bans.
California already has a framework underway through AB 1088, which would restrict sales to adults, require clear labeling and third-party testing, enforce potency limits, and ban synthetic or spiked products including 7-OH isolates. Many cities and counties have adopted similar approaches after reviewing the facts. Orange can do the same.
Bans do not eliminate demand -- they increase risk by driving consumers toward unregulated products that are more likely to be mislabeled, contaminated, or sold without age restrictions.
My request is simple: please reject Ordinance No. 01-26 if it includes a blanket kratom ban, avoid conflating natural kratom leaf with 7-OH isolates, and instead pursue common-sense regulation that protects residents while respecting adult choice and supporting responsible businesses.
Thank you for your time and thoughtful consideration. I would be happy to speak with City staff or Council members directly and provide additional information and consumer perspectives.
Respectfully,
Justin Wolf
Founder & CEO, New Brew
I oppose Ordinance No. 01-26 banning all kratom products in the City of Orange. Please protect the safe, plain leaf Kratom. My wife, Melody, has had a very positive experience with it. This is her story: My name is Melody Woolf, and I’ve been working on kratom advocacy at the local, state, and now federal level, focusing on reasonable policy and responsible regulation. Most recently, I participated in the July 29 HHS-FDA joint press briefing, where I was invited to the stage by the FDA Commissioner. I spoke about the benefits of kratom, shared how it has positively impacted my family, and clarified how it differs from the dangers associated with opioids. I also highlighted the importance of science-based regulation to protect consumers while ensuring access to safe, legal products.
On a personal note, I’ve lived with chronic pain for over 20 years and have several painful conditions. For eight years, when my kids were in elementary school, they had to keep a fan on in their room at night just to sleep because I was crying in pain nearly every night. Kratom has allowed me to reclaim my life, care for my family, and function without being debilitated by pain.
In 2022, when my daughter and son-in-law’s childcare shut down just before paternity leave, I was able to step in and care for my granddaughter for a year. I gladly moved in with them to help. The same thing happened this past summer: I watched my granddaughter all summer long, taking her to the zoo every week—the same zoo where, years ago, my kids had to push me around in a wheelchair, and now I was chasing my granddaughter around it. Kratom made that possible.
There are 50 to 100 million chronic pain patients in the United States. Every person with pain should have every tool in the toolbox available to manage their condition safely. Everybody is only one accident or diagnosis away from living with chronic pain. Please remove 708 and protect kratom with reasonable, science-based regulations so that patients like me and millions of others can continue to live productive, meaningful lives.
For more information and the related science, please see her LinkedIn profile: https://www.linkedin.com/in/melody-woolf-366a7b146?utm_source=share&utm_campaign=share_via&utm_content=profile&utm_medium=ios_app
I oppose Ordinance No. 01-26 banning all kratom products in the City of Orange. This proposal relies on broad federal agency statements and conflates ordinary kratom leaf with high-risk concentrated products such as 7-hydroxymitragynine, without distinction. California has no statewide kratom statute, and Orange County itself chose regulation rather than a total ban. An outright prohibition ignores less restrictive alternatives like age limits, product standards, and enforcement against specific high-risk products. I urge the City Council to reject a blanket ban and pursue a narrowly tailored, evidence-based regulatory approach instead.
Marcelle
To the City Council and Director of Code Enforcement:
My name is Stephen McIntosh, I spoke at the 1st reading of this agenda item as a chronic pain patient who uses kratom to manage my chronic pain. I won't spend your valuable time repeating what I said in the meeting here.
I would like to add a few items as they came to mind while listening to testimony from staff, and/or had time to think about them since the last meeting.
First: It is true that kratom has no approved medical purpose. This is because no dietary supplement is approved for specific medical purposes, though consumers do routinely take them for some benefit. Only drugs that go though the FDA New Drug Application process are approved for a specific purpose which allows vendors to make approved health claims such as fitness for a particular purpose. This is not a flaw or detriment, but by design under the Dietary Supplement Health and Education Act (1994) that sets a very different standard for dietary supplements that may be helpful. It is why they carry the notification "These statements have not been evaluated by the Food and Drug Administration. This product is not intended to diagnose, treat, cure, or prevent any disease.”
Second, for all FDA has said about kratom in media, by its own admission it has not made a determination about the safety of kratom when asked under oath. In the Federal Case "3:23-cr-00179-TWR Page ID.1032 Exhibit 6; United States of America, Plaintiff, v. Nine2Five, LLC (1) Sebastian Guthery (2), Defendants" the US attorney told the judge "They [FDA] have refused to provide us with witnesses or documents to support our position. The reason they gave was that they have not yet made a determination regarding whether kratom is dangerous."
Since this admission, it has conducted the Single Ascending Dose Study where test subjects were given up to 12 grams of botanical kratom and none experienced a severe adverse effect. The results are available as Trial NCT06072170 at: https://cdek.pharmacy.purdue.edu/trial/NCT06072170/
The FDA was also chastised by HHS in 2018 by then Undersec. Dr. Giroir for submissions to prohibit kratom as “embarrassingly poor evidence and data" when those were withdrawn by HHS.
CDPH is, at present, using these exact claims from FDA to justify their action, which FDA refused to make under oath, doesn't align with their newer studies, and that they have been chastised for in the past.
CA Narcotics Officers Assn, American Medical Assn (Res. 515), and the US Nat. Inst. for Drug Addiction support availability of botanical kratom for adults and further research.
I am again imploring you to re-consider this Ordinance to limit itself to adulterated high "7-OH" products and to exempt botanical kratom.
Doing so would create an ordinance in the City that is compatible with both SB 578 and AB 1088 that are progressing though the legislature with considerable support from legislators and members of the general public. These bills and the OC Ordinance limit sales to 21+, bar 7-OH products from sale, and prohibit products attractive to children (similar to regulations for marketing/labeling alcohol or tobacco).
It would allow for individuals such as myself who use it for important purposes, sometimes as a last resort or due to being under-treated by their limited medical options to still obtain botanical kratom which has been in regular sale since at least 2000 and centuries of indigenous use.
Thank you again.
To Whom It May Concern:
I am Abdullah Mamun, the owner of Authentic Kratom. For the past 12 years, I have operated as a responsible kratom retailer, committed to consumer safety, transparency, and regulatory compliance. I appreciate the City of Orange for bringing this important matter forward for discussion. I plan to attend in-person, but just in case sending my comment prior hand.
I respectfully oppose the proposed ordinance to ban “kratom products,” as the current language lacks clarity and risks unintentionally prohibiting natural kratom, which has been safely used by millions of Americans for decades. I believe this issue requires careful distinction between natural kratom and synthetic 7-hydroxymitragynine (commonly known as 7-OH) products.
Kratom is a natural botanical derived from Mitragyna speciosa, a plant belonging to the same plant family as coffee (Rubiaceae). Traditionally, kratom leaves are brewed into tea and consumed in many parts of Southeast Asia and the United States. Many consumers use kratom for energy, focus, and overall wellness, and in my personal experience, it has been helpful in managing chronic back discomfort.
Kratom contains multiple naturally occurring alkaloids, the primary ones being mitragynine and 7-hydroxymitragynine (7-OH). In natural kratom leaf powder, capsules, and even extracts, mitragynine is the dominant alkaloid, while 7-OH is present only in trace amounts. I have included laboratory test results demonstrating the full alkaloid profile of our products, which confirms these trace levels.
In contrast, around 2023, certain manufacturers began producing synthetic pills/liquids labeled as “7-OH”, containing unnaturally high concentrations of 7-hydroxymitragynine. These products do not reflect the natural composition of kratom and represent a fundamentally different—and far more concerning—category.
Research conducted by Dr. Chris McCurdy of the University of Florida College of Pharmacy, a leading authority in kratom science, has identified unknown and potentially dangerous chemical constituents in these synthetic 7-OH products (see attached study). Additionally, a comprehensive 8-factor abuse liability analysis conducted by Dr. Jack Henningfield and colleagues concluded that synthetic 7-OH presents a significantly elevated risk profile compared to natural kratom (see attached).
Furthermore, during a public press conference on July 29, 2025, the U.S. Food and Drug Administration (FDA) explicitly stated that natural kratom containing trace levels of 7-OH is not their regulatory target, and instead recommended that the DEA focus enforcement efforts on banning synthetic 7-OH products.
In summary, the emerging public health concerns are not caused by natural kratom, but rather by synthetic, chemically manipulated 7-OH products. I strongly urge the City of Orange to consider legislation that specifically bans synthetic 7-OH, while preserving legal access to natural kratom for the thousands of responsible adults who rely on it to maintain their quality of life—particularly when traditional treatments have failed.
That said, I fully support reasonable regulation of kratom, including strict age requirements, proper labeling, laboratory testing, and consumer education. At Authentic Kratom, we already enforce a minimum purchase age of 21, provide transparent labeling, and conduct rigorous third-party laboratory testing.
Thank you for your time and thoughtful consideration.
Abdullah
I urge you to reconsider this ordinace that would take away many chronic pain patients' quality of life. My kratom story: After waking up one day in 2005, paralyzed from my neck down, I was eventually diagnosed with Transverse Myelitis, and became a chronic pain patient. For years, I was able to manage my chronic pain with prescription medications, but eventually with more DEA cutbacks and new regulations over the years those were no longer an option for me. I was left to endure living in pain every single second of every single day just like so many other chronic pain patients in the same position. Luckily I discovered whole leaf kratom powder in May of 2019. I've been consuming it responsibly for 6 years and it has granted me a second chance at life! I no longer suffer every day, I can get out of bed and be a mom! I can go to school functions run errands, go to the store, and just live life without suffering. Though I regained mobility I still face many physical limitations, however I'm no longer confined by constant pain. Kratom gave me my life back. My story is just one of many chronic pain patients that have been able to manage their pain with kratom.
There is a big difference between natural whole-leaf kratom VS the semi-synthetic 7-OH products being marketed as kratom. I’ve been encouraged to see even the FDA has stepped in, not only to educate the public on this distinction, but also to warn about the risks of 7-OH. They’ve made it clear their concern is with 7-OH products, NOT with whole leaf kratom.
I’m asking you to support regulation instead of prohibition and keep natural, whole-leaf kratom legal. We need clear safety standards such as age restrictions, mandatory lab testing, accurate labeling, and limits on 7-hydroxymitragynine (7-OH). These are the kinds of measures that protect public health while preserving the freedom of choice for responsible adults.
Thank you so much for your time and letting me use my voice to represent the many others in the chronic pain community.
Sincerely, Jennifer Gillis
Dear Members of the City Council,
There is a critical scientific difference between whole-leaf kratom and the products being sold today as "7-hydroxymitragynine," or 7-OH.
Whole-leaf kratom is simply the dried leaf of Mitragyna speciosa. Its primary alkaloid is mitragynine. When someone consumes kratom, the human body naturally converts only a very small amount-typically well under one percent-into 7-OH through normal liver metabolism. This process is slow and self-limiting.
By contrast, the 7-OH products now appearing on the market contain laboratory-isolated or chemically converted 7-hydroxymitragynine in amounts far beyond what the human body could ever produce from kratom leaf. At those levels, 7-OH behaves much more like a conventional opioid and carries much higher risk.
When these high-potency 7-OH products are lumped with natural kratom, it leads to misleading risk assessments and poor public policy. Regulating or restricting 7-OH does not require banning whole-leaf kratom-and that distinction matters, because kratom saved my life.
From 2008 to 2019, I lived trapped in FDA-approved pain pills, benzodiazepines, and muscle relaxers prescribed for my degenerative disc disease. Over 11 years, chronic pain management turned into full-blown addiction. What began as dependency slowly became a cycle of misuse, desperation, and shame.
In April of 2019, I was dismissed from pain management after failing a required pill count. I was short on my medication and couldn't find what I needed. Cut off from prescriptions, I turned to the streets, and in that desperation, I slipped into cocaine use while trying to find another doctor.
By June of 2019, I was in withdrawal and at rock bottom when I watched a documentary called A Leaf of Faith. That moment changed everything. The next day, I walked into a shop, showed my ID, and bought whole-leaf kratom..not synthetic 7-OH.
Kratom quieted the relentless cravings. The voice that kept saying, "one more pill, one more snort, one more escape," finally went silent. For the first time in over a decade, I felt stable. Kratom gave me the breathing room to heal and allowed me to rebuild my life.
I have not returned to pain management in over six and a half years. Today, I am a thriving mother, a first-time grandmother, and a contributing member of society. I am no longer a burden to my children. I am an example of recovery.
I will always be grateful that I had access to safe, lab-tested, whole-leaf kratom. And that is why I speak out to protect others who are still fighting for their lives.
Misty Brown