What This Is, Why the Board Acted, and What Each Factor Means — In Plain Language

This page explains, in plain language, how the Ohio Board of Pharmacy applied Ohio law to mitragynine. The Board’s full eight-factor analysis is linked below for direct verification.

Open the Ohio Board’s Eight-Factor Analysis (PDF)


What Is This Document?

This document is a formal proposal from the Ohio Board of Pharmacy to classify mitragynine — the primary psychoactive alkaloid in kratom — as a Schedule I controlled substance in Ohio.

Schedule I is reserved for substances that:

Because this action affects businesses and consumers, Ohio law requires the Board to explain its reasoning publicly and allow for comment.

This summary explains how the Ohio Board of Pharmacy applied Ohio law to mitragynine. It does not introduce new evidence or reinterpret the Board’s findings.


Why the Board Took Action

Ohio law (ORC 3719.44) does not allow the Board to act based on opinion or politics. It requires the Board to evaluate eight specific statutory factors using scientific data, public-health evidence, and real-world outcomes.

After reviewing those factors, the Board concluded that mitragynine met the statutory criteria necessary to support Schedule I placement.

Below is what each factor is called officially, what it means in everyday language, and what the Board determined.


Factor 1: The Actual or Relative Potential for Abuse

What this means:
Does the substance get people high? Do people misuse it or lose control over use?

What the Board found:
Mitragynine activates the mu-opioid receptor, the same receptor responsible for opioid euphoria, dependence, and overdose. At low doses it can feel stimulating; at higher doses it produces morphine-like sedative and narcotic effects.

Consumers frequently escalate doses and report inability to stop.

Board determination:
Mitragynine has a high potential for abuse.


Factor 2: Scientific Evidence of the Pharmacological Effect of the Substance

What this means:
How does the substance actually work in the body and brain?

What the Board found:
Scientific evidence shows mitragynine:

This is drug-level pharmacology, not nutritional support.

Board determination:
Mitragynine produces opioid-like pharmacological effects.


Factor 3: The State of Current Scientific Knowledge Regarding the Substance

What this means:
Has this substance been adequately studied like a medicine?

What the Board found:
Mitragynine and kratom:

The FDA, WHO, and DEA all confirm there are no FDA-approved drugs containing kratom or mitragynine.

Board determination:
Scientific knowledge is limited and insufficient to establish safety or medical use.


Factor 4: The History and Current Pattern of Abuse

What this means:
How are people actually using this today?

What the Board found:
Modern kratom products are far more concentrated than traditional leaf use. Extracts and tablets often contain multiple times the alkaloid content of the plant.

People use mitragynine to:

This pattern closely mirrors early opioid misuse.

Board determination:
There is a clear and ongoing pattern of abuse.


Factor 5: The Scope, Duration, and Significance of Abuse

What this means:
How widespread is the problem, and how serious are the consequences?

What the Board found:
Millions of Americans use kratom. In Ohio:

Use is no longer rare, isolated, or short-term.

Board determination:
The abuse is widespread, sustained, and significant.


Factor 6: The Risk to the Public Health

What this means:
Does this substance cause serious harm to the public?

What the Board found:
From 2019–2024, Ohio recorded over 200 deaths in which kratom was identified on death records or toxicology reports, including cases where it was listed as a cause or contributing factor.

Reported harms include:

The FDA has issued repeated warnings about kratom’s dangers.

Board determination:
Mitragynine poses a significant risk to public health.


Factor 7: The Potential of the Substance to Produce Psychic or Physiological Dependence Liability

What this means:
Does the substance cause addiction and withdrawal?

What the Board found:
Many users develop:

Physicians are now treating kratom dependence with buprenorphine, a medication used for opioid addiction.

Board determination:
Mitragynine has high dependence liability.


Factor 8: Whether the Substance Is an Immediate Precursor

What this means:
Can the substance be used to create or enable more dangerous drugs?

What the Board found:
Mitragynine presents a precursor risk in the regulatory sense: it is chemically modifiable into more potent opioid analogs, and similar compounds have already been detected in commercial products.

The Board warned this follows the same trajectory as synthetic drug classes like bath salts, where chemical tweaks are used to evade the law.

Board determination:
Mitragynine presents a future escalation risk.


Final Finding of the Board

After reviewing all eight statutory factors, the Ohio Board of Pharmacy formally found that mitragynine:

Based on these findings, the Board authorized Schedule I classification and a ban on sale and possession in Ohio.


What This Means for the Average Consumer

Many people believed kratom was safe because it was legal, labeled “natural,” and sold openly.

Legal does not mean safe.
Herbal does not mean harmless.
And supplements are not medicines.

Ohio acted because the evidence showed continued access would lead to more addiction, more overdoses, and more families harmed.

This process exists to stop preventable harm before it becomes irreversible.