Juul Labs has had a rough 2018. After skyrocketing to the top of the e-cigarette market, the company has undergone intense criticism from the media and the FDA about their previous marketing practices, which many people believe were targeted to underage vapers.

Within the past few months, the company has been completely revamping their marketing. They’ve committed to using only older, former smokers in their ad campaigns rather than the trendy, attractive early 20’s models that they previously used. They’ve shuttered their US-based social media accounts. They’ve ended their affiliate program, which compensated reviewers for sending sales their way.

Now that they’ve sold out to Big Tobacco (the company sold a large stake to Altria), they’ve decided to undertake yet another controversial advertising campaign. This time it’s on prime-time TV. Their new “Make the Switch” ad campaign features former smokers talking about why they use the Juul e-cigarette.

The total ad spend is expected to run about $20 million, with the majority of that going towards cable TV spots. The rest will be spent on radio, print, and online advertising.

Why are Juul’s new commercials so controversial?

Tobacco companies have long been restricted from advertising on television and print advertising, with the restrictions dating back all the way to the 1970’s. Electronic cigarettes are, however, a loophole. Federal and state regulators haven’t yet applied the restrictions to the relatively new e-cigarette market.

“It’s clear that we’re focused on the mission of the company to convert people off combustible cigarettes,” said Ann Hoey, Juul’s vice president of marketing. “This is campaign that is a sort of an honest, straight down the middle of the fairway, very clear communication about what we’re trying to do as a company.”

It remains to be seen if these new TV advertisements will draw the ire of the FDA, which has had Juul Labs in its crosshairs for a while now.