Florida's composition limits

Emergency Rule 2ER26-2 took effect August 18, 2026, and is scheduled to expire June 30, 2027 unless it is replaced or extended.

Florida uses three separate checks. First, check the amount of parent 7-OH. Second, compare the amount of mitragynine with the amount of parent 7-OH. Third, look for separately scheduled substances. A product must clear all three checks. One passing result does not cancel a failing result.

1. Check parent 7-hydroxymitragynine

Start with the laboratory's parent 7-OH result. Do not add any other compound to this number. The product's form tells the laboratory which unit and limit to use:

  • Solid, powdered, and encapsulated products: NMT 1.00 mg/g
  • Liquids, beverages, extracts, and tinctures: NMT 1.00 mg/mL

The parent 7-OH result can be 1.00 or lower. A result above 1.00 is over the limit.

2. Check the 100:1 ratio

Next, compare the mitragynine result with the parent 7-OH result. This is a separate check, so a product must meet both the 1.00 limit above and this ratio.

For every one part of parent 7-OH, the product needs at least 100 parts of mitragynine by mass. Divide mitragynine by parent 7-OH:

mitragynine ÷ parent 7-OH ≥ 100

Here is one example using the full, unrounded results:

12.450 ÷ 0.100 = 124.5

The answer, 124.5, is at least 100, so the ratio meets the rule. The parent 7-OH result is 0.100 mg/g, which is also below 1.00 mg/g. This example clears both math checks.

3. Check separately scheduled substances

Finally, check the substances below one at a time. They do not use the 1.00 limit or the 100:1 calculation. Rule 2ER26-2 places them in Florida Schedule I without a stated concentration threshold:

  • 7-acetoxymitragynine
  • Dihydro-7-hydroxymitragynine (MGM-15)
  • MGM-16: Methyl (E)-2-((2S,3S,7aS,12aR,12bS)-3-ethyl-9-fluoro-7a-hydroxy-8-methoxy-1,2,3,4,6,7,7a,12,12a,12b-decahydroindolo[2,3-a]quinolizin-2-yl)-3-methoxyacrylate. The complete designation matters because 9-fluoro and 10-fluoro names vary with the numbering convention.

If the laboratory confirms one of these substances at or above the method's validated detection or identification limit, the product does not clear Florida-market review. “Not detected” means the method did not find the substance at or above that limit. It does not mean the amount is proven to be zero.

How Test Code 814 uses the results

Test Code 814 is the laboratory reporting workflow for Florida-market review. It keeps the checks above separate and shows how the laboratory reached each result.

The workflow uses six core analytical targets:

  • Mitragynine
  • 7-Hydroxymitragynine
  • 7-Acetoxymitragynine
  • Mitragynine pseudoindoxyl
  • MGM-15
  • MGM-16
  1. Check the amount of parent 7-OH. Compare the full, unrounded result with the 1.00 mg/g limit for solids or the 1.00 mg/mL limit for liquids.
  2. Check the ratio. Divide the full, unrounded mitragynine result by the full, unrounded parent 7-OH result. The answer must be 100 or higher. If parent 7-OH is below the method detection limit, Test Code 814 uses the MDL instead of zero. This avoids treating “too little for the method to detect” as if it meant “absolutely none.”
  3. Check the separately scheduled substances. Review each one as its own “not detected” check. Do not add their results or detection limits to the parent 7-OH result.

9-hydroxycorynantheidine and 10-hydroxycorynantheidine are optional informational targets. Florida does not require them for these decisions, so they are left out of the math. Their results do not change the parent 7-OH limit, the 100:1 ratio, the separately scheduled-substance checks, or label readiness.

Preparing the label values

FDACS Emergency Rule 5KER26-11 took effect August 24, 2026, and is scheduled to expire November 22, 2026 unless it is replaced or extended.

The composition rule above tells you which results clear the Florida checks. The labeling rule tells you which numbers must appear on the package. It uses the same laboratory data, but the final whole-package numbers are rounded for display.

  • Show the parent 7-OH concentration in mg/g for solids and powders or mg/mL for liquids.
  • If a covered 7-OH isomer, ester, ether, salt, or related salt is present, list it separately.
  • If a result is below the MDL, do not call it zero. Use the method's MDL or LOD as the stated concentration. This is allowed only when its LOQ or PQL is below 1 mg/g or 1 mg/mL. When the result is above the MDL, state the actual concentration.
  • To get whole-package milligrams, multiply the concentration by the package's total grams or milliliters. List the whole-package milligrams of mitragynine first, followed by parent 7-OH and any applicable covered derivatives.

concentration × total package weight or volume = milligrams in the whole package

Official example: The package contains 500.2 mg mitragynine and 0.9 mg 7-OH. For the label, those numbers round to 500 mg and 1 mg, so the display reads “Alkaloid Ratio 500 mg:1 mg.” This rounding is only for the package declaration. The laboratory still uses the unrounded results for the 1.00 limit and the 100:1 ratio.

Test Code 814 puts the final package declaration in this order:

Alkaloid Ratio [mitragynine mg]:[7-OH and applicable derivative mg]

Federal requirements also apply

Florida is not the only set of rules that matters. DEA's temporary scheduling order placed mitragynine pseudoindoxyl, MGM-15, and MGM-16 in federal Schedule I on August 26, 2026, without a minimum concentration threshold. Florida's 2ER26-2 list does not name mitragynine pseudoindoxyl, but Test Code 814 still checks it because federal law also applies in Florida.

DEA has a separate high-7-OH notice of intent. That notice is still a proposal, not a final scheduling order. HHS extended the comment period on the proposal.

A note for customers with earlier Test Code 814 reports

Older reports may look different because they added seven analytes into one total. That total is no longer used. Emergency Rule 2ER26-1 was superseded on August 18, 2026, and Emergency Rule 5KER26-9, which required the old seven-compound label calculation, was repealed on August 6, 2026. The current review checks parent 7-OH by itself for the concentration limit and 100:1 ratio. It checks the separately scheduled substances one at a time.

The Florida Kratom Consumer Protection Act and permanent Rule 5K-4.030 remain part of the broader state requirements.

Using Test Code 814

Test Code 814 organizes laboratory-generated analytical evidence for product and label review. It does not guarantee legal compliance. Product form, package size, matrix suitability, reporting limits, sample acceptance, and intended market still need to be reviewed for each project.

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Official sources