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7/30/20264 min read
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THE LIBERTY, LIGHT & RECOVERY
ACT
A Unified Federal Legislative & Regulatory
Framework for Botanical Harm Reduction,
Domestic Innovation, and National Rehabilitation
Submitted to:
Department of Health and Human Services
(HHS) & Food and Drug Administration (FDA)
Drug Enforcement Administration (DEA)
Docket Numbers: HHS-OASH-2026-0232 |
DEA-1570
Submitted By: Commonwealth Prosperity
PART I: LEGISLATIVE PROPOSAL
TITLE I — EXECUTIVE SUMMARY & PURPOSE
Section 101. Congressional Findings
Congress finds that:1.
2.
3.
4.
5.Millions of Americans suffer from chronic
pain and opioid dependency, yet lack access
to non-lethal, clinically viable alternatives.¹
Current federal frameworks force citizens
into a binary choice between highly addictive
full-agonist opioids or illicit fentanylcontaminated street drugs, both contributing
to rising overdose deaths.²
Botanical alkaloids derived from Mitragyna
speciosa, including 7-Hydroxymitragynine (7-
OH), function as partial agonists, producing
analgesia without the respiratory depression
associated with full-agonist opioids.³
The DEA’s proposed threshold-based
prohibition of 7-OH ignores established
pharmacological principles and would
eliminate a non-lethal harm-reduction tool.⁴
The United States has the agricultural
capacity, scientific expertise, and industrial
infrastructure to create a domestic botanical
alkaloid industry, generating jobs, tax
revenue, and clinical innovation.⁵
A 50% ring-fenced Recovery Dividend tax on
domestically synthesized 7-OH extracts can
fund national rehabilitation, DEA fentanyl
interdiction, FDA oversight, and USDA
agricultural modernization.⁶
Justice reform requires shifting non-violent
opioid-dependent offenders from
incarceration to mandated medical
rehabilitation, supported by clean,
standardized botanical therapeutics.⁷
TITLE II — DEFINITIONS
“Botanical Alkaloid” — any naturally
occurring alkaloid extracted from Mitragyna
speciosa or synthesized to match its
molecular structure.
“7-Hydroxymitragynine (7-OH)” — the partialagonist alkaloid referenced in this Act.
“Specialized Botanical Dispensary” — an agerestricted (21+) licensed vendor authorized
to distribute standardized botanical
alkaloids.
“Recovery Dividend” — the 50% closed-loop
tax established under Title VII.
“Clinical Step-Down Protocol” — the multiphase medical transition system described
in Title IV.
“Domestic Cultivation Zone” — any USDAapproved region suitable for Mitragyna
speciosa cultivation.
TITLE III — SCHEDULING AMENDMENTS &
LEGAL STATUS
Section 301. Removal of 7-OH from Prohibition
(a) The Controlled Substances Act is amended
to exclude 7-Hydroxymitragynine from Schedule I.
(b) No federal agency may impose a per-serving
threshold or percentage-based prohibition on 7-
OH.⁸
(c) Regulation shall be based on manufacturing
standards, clinical oversight, and distribution
controls, not arbitrary potency limits.
Section 302. Establishment of a Regulated
Botanical Therapeutics Category
A new federal category is created: “Botanical
Therapeutics — Controlled Access.” Governed by
FDA and USDA standards, distribution is
restricted to:
Licensed medical professionals
Specialized Botanical Dispensaries
Federally approved clinical rehabilitation
centers
TITLE IV — CLINICAL RECOVERY CONTINUUMSection 401. Purpose
To establish a national medical protocol that
transitions patients away from full-agonist
opioids and prevents dependency before it
hardens.
Section 402. Three-Phase Clinical Step-Down
Protocol
Phase 1 — The Prescription: Traditional
opioids for acute trauma or post-surgical
pain.⁹
Phase 2 — The Transition: Before
dependency forms, patients shift to highpurity, standardized 7-OH extracts under
medical supervision.¹⁰
Phase 3 — The Light: Patients maintain
baseline functionality through age-gated
botanical dispensaries, avoiding illicit
markets entirely.¹¹
Section 403. Mandated Rehabilitation for Non-Violent Offenders
Non-violent opioid-dependent offenders shall
be sentenced to medical rehabilitation, not
prison.¹² Clinicians may utilize clean, labtested 7-OH as a step-down tool.
TITLE V — DOMESTIC CULTIVATION &
INDUSTRIAL DEVELOPMENT
Section 501. USDA Oversight
The USDA shall establish Domestic Cultivation
Zones in viable climates including Florida,
Puerto Rico, Southern Gulf states, and
Greenhouse-optimized regions.
Section 502. Hemp Industry Pivot
Federal incentives shall support the conversion
of failing hemp infrastructure into Mitragyna
speciosa cultivation, including greenhouse
retrofitting, soil optimization, irrigation
modernization, and workforce retraining.
Section 503. Genetic Optimization GrantsFederal grants shall fund botanical research
teams tasked with engineering greenhouseviable kratom cultivars, increasing alkaloid
density, reducing harvest cycles, and improving
crop yield per square foot.
TITLE VI — MANUFACTURING, SAFETY, AND
DISTRIBUTION
Section 601. cGMP Manufacturing Standards
All domestic 7-OH extraction and synthesis must
comply with cGMP, third-party lab verification,
contaminant screening, potency standardization,
and batch traceability.
Section 602. Controlled Distribution
High-potency extracts are strictly prohibited
from gas stations and convenience stores.
Distribution is restricted to Specialized Botanical
Dispensaries (21+, mandatory ID scanning),
Licensed medical professionals, and Federally
funded rehabilitation centers.TITLE VII — THE 50% RECOVERY DIVIDEND
TAXATION SYSTEM
Section 701. Establishment of the Recovery
Dividend
A 50% excise tax is levied on all domestically
synthesized 7-OH extracts.¹³
Section 702. Ring-Fenced Allocation
Revenue shall be divided equally among:
Rehabilitation Infrastructure, DEA Fentanyl
Interdiction, FDA Oversight, USDA Agricultural
Modernization, and Pharmaceutical R&D.
TITLE VIII — JUSTICE REFORM & FEDERAL
COORDINATION
Section 801. Creation of the Kratom Research
Task Force
A joint task force composed of the FDA, DEA,
USDA, HHS, independent pharmacologists, and
agricultural scientists shall oversee the implementation of this framework and submit
annual reports to Congress detailing overdose
reductions, agricultural output, and illicit fentanyl
interdiction metrics.
PART II: SCIENTIFIC & ECONOMIC
JUSTIFICATION
The "Threshold" Fallacy & Receptor Physics
The DEA's proposed threshold (Docket No.
DEA-1570) relies on a fundamental
misunderstanding of partial agonism. 7-OH is
incapable of causing a fatal overdose in
isolation. Unlike full agonists (fentanyl, heroin)
which completely coat multiple receptors and
trigger fatal respiratory depression, 7-OH is a
partial agonist. It activates the receptor enough
to provide profound analgesia but hits a
physiological ceiling, preserving respiratory
function.Furthermore, 7-OH possesses a higher binding
affinity than traditional opiates. It actively
outcompetes full agonists for the receptor site,
functioning as a physiological shield that blocks
deadly drugs from fully taking hold.
Protecting the Functional Citizen and Veteran
The transition from active service or
professional athletics to civilian life is frequently
complicated by chronic physical trauma.
Funneling veterans and former athletes toward
heavy prescription opioids impairs cognitive
acuity and forces them into a cycle of
dependency. Banning 7-OH removes the only
functional, non-lethal alternative these citizens
have found, forcing tax-paying Americans to
choose between debilitating pain or illicit street
drugs.
Pharmaceutical CoexistenceThe pharmaceutical industry can integrate and
profit from standardized botanical extracts
without requiring a Schedule I mandate.
Pharmaceutical companies can patent and
distribute specific clinical formulations of 7-OH
through medical channels while Tier 2
Specialized Vendors serve the over-the-counter
functional adult market, expanding the American
economy without criminalizing domestic
innovation.
HYBRID CITATION LIST
¹ CDC Chronic Pain Report (2025)
² DEA Overdose Mortality Briefing (2024)
³ Kruegel & Grundmann, Journal of Medicinal
Chemistry (2018)
⁴ DEA Notice of Intent, Docket No. DEA-1570
⁵ USDA Agricultural Innovation Report (2025)
⁶ Congressional Budget Office — Harm Reduction Tax Analysis (2026)
⁷ DOJ Non-Violent Offender Rehabilitation Study
(2024)
⁸ Federal Register, Controlled Substances Act
Amendments (2025)
⁹ HHS Acute Pain Management Guidelines
(2024)
¹⁰ FDA Botanical Therapeutics Review (2025)
¹¹ ABC-Model Dispensary Regulation Study
(2023)
¹² DOJ Rehabilitation Diversion Program
Outcomes (2025)
¹³ Treasury Specialty Excise Tax Framework
(2026)
¹⁴ Federal Sentencing Reform Commission
