348 



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under the bUl. Such an arrangement, despite Rep. Synar's assurances to the contrary, 

 would be unprecedented and should trouble other industries deeply. 



The labeling and advertising provisions of H.R. 2147 are both unnecessary and 

 highly objectionable. Rep. Synar would add a great deal of extraneous information to 

 cigarette packages, thus discouraging smokers from reading any of the information 

 currently appearing there. He also would restrict cigarette advertising in ways that, 

 in many respects, are the functional equivalent of an explicit ban. The advertising 

 provisions of H.R. 2147 are every bit as objectionable as the explicit advertising ban 

 proposals that Rep. Synar has offered in the past. 



PUNITIVE INGREDIE^^■ REGULATION 



Instant ban. H.R. 2147 would direct FDA to issue regulations requiring that 

 all additives (Le., ingredients) used in tobacco products be "safe." If the bill 

 contemplates that FDA must find current tobacco additives to be "safe" before they can 

 be used, the result would be an instant ban on all tobacco products currently on the 

 market pending a review of all additives by the agency. H.R. 2147 would impose 

 elaborate regulatory requirements with respect to tobacco additives even though, as 

 noted, former HHS Secretary Sullivan told Congress just four years ago that no 

 additional regulatory authority in this area is required. Indeed, Secretary Sullivan 

 stated that he considered tobacco product ingredients to be a "peripheral" concern. 



For more than a decade, the cigarette manufacturers have submitted ingredient 

 information to HHS - first on a voluntary basis and later pursuant to the ingredient 

 reporting provisions added in 19S4 to the Federal Cigarette Labeling and Advertising 



