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Horn himself believed that if an outright ban on cigarette advertising could not be achieved, confining the advertising that was done to low-tar-and-nicotine brands had some value, since his own research on smoking habits had shown that for some habitual smokers a switch from high- to low-tar-and-nicotine cigarettes was a way station toward ridding themselves of the habit altogether

Menthol cigarettes and flavored, mass-produced cigars and cigarillos, however, are not always subject to such premarket review (as they may be grandfathered or eligible for the substantial equivalence (SE) or SE exemption pathways)

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