September 13, 2008
Safe, FDA-Regulated Bottled Water is a Popular Consumer Choice
(Washington, DC, September 10, 2008) — International Bottled Water Association (IBWA) President and CEO Joe Doss today presented testimony to the U.S. Senate, Environment and Public Works Committee, Subcommittee on Transportation Safety, Infrastructure Security and Water Quality’s hearing on Quality and Environmental Impacts of Bottled Water. Addressing these issues, Mr. Doss stated: “Bottled water is a safe, convenient, healthful packaged beverage product that consumers find refreshing and use to stay hydrated. In many instances, consumers choose bottled water because it does not have the calories, caffeine, or other ingredients that they may wish to eliminate or moderate in their diets. And with the rise in obesity and diabetes in the United States, any actions that discourage the consumption of bottled water are not in the public interest.”
Bottled Water Safety
Bottled water is comprehensively and stringently regulated in the United States at both the federal and state levels, which helps ensure its safety and quality. At the federal level, bottled water is regulated as a packaged food product by the FDA under the Federal Food, Drug, and Cosmetic Act (FFDCA). It must meet FDA’s general food regulations as well as standards of identity, standards of quality, good manufacturing practices and labeling requirements specifically promulgated for bottled water.
According or Mr. Doss: “All food and beverage products are regulated under the same statutory regime and bottled water is no different in this respect than juice, carbonated soda, or energy drinks. Bottled water is subject to the same general prohibitions against adulteration and misbranding as other beverage products, and is subject to the same general requirements for ingredient labeling, nutrition labeling, and product claims as other beverage products, as well as good manufacturing practices.” Mr. Doss added: “From a market and legal perspective, bottled water is the same as other beverages such as soft drinks, teas, and juices, which also have water as their primary ingredient.”
Mr. Doss told the Senate hearing: “FDA has determined that the containers used by the bottled water industry to be safe for use with food products, including bottled water, must be made from FDA approved food contact substances.” The plastic and glass containers used by the bottled water industry have undergone FDA scrutiny prior to being available for use in the market place.
To ensure across-the-board bottled water safety, in 1995 the FDA established standard of identity regulations for bottled water, determining uniform definitions for the following bottled water classifications: bottled, drinking, artesian, groundwater, distilled, deionized, reverse osmosis, mineral, purified, sparkling, spring, sterile and well water.
“A bottled water product must meet the appropriate Standard of Identity and bear the required name on its label or it may be deemed misbranded under the FFDCA,” said Joe Doss. “By law, FDA’s standards of identity regulations pre-empt state laws that are different from the FDA regulations. If a bottled water product’s source is a municipal water system and it does not meet the FDA Standard of Identity for purified or sterile water, it must indicate the public water system source on the label.”
The current system of federal labeling laws and regulations protects the public health (including providing consumers with useful product information) and permits bottled water companies to sell their products in an efficient and cost effective manner in interstate commerce. All packaged foods and beverage products, including bottled water, have extensive labeling requirements,
Consumers Right to Know
“IBWA supports a consumer’s right to clear accurate and comprehensive information about the bottled water products they purchase,” said Joe Doss. “IBWA agrees with the FDA’s conclusion that placing this information is not feasible for many reasons including limited space available. We believe the most feasible mechanism for consumers to obtain this information is through a request to the bottler or distributor.”
IBWA believes that consumers should have timely and easy access to information about their bottled water products. To help ensure that consumers have access to useful and meaningful bottled water product information, the IBWA Code of Practice requires all members to comply with the following:
- All proprietary brand products must include a telephone number on their labels so consumers can easily contact the company and request product information.
- IBWA maintains an online member database, which also contains a specific link to a member company’s water quality information and/or contact information that may be used to secure a company’s water quality report.
A visit to IBWA’s website: www.bottledwater.org will provide consumers with Water Quality Information for every IBWA member, with a web link to the company or with posted data provided by the company.
The bottled water industry is also strongly committed to stewardship of the environment. Whether it is developing groundwater protection areas, supporting state groundwater management programs or developing new technology to reduce the plastic needed for its containers, the bottled water industry has been on the forefront of innovation in the food and beverage industry in developing policies and technology to promote environmental stewardship.
Bottled water is one of thousands of food and beverage products that are packaged in plastic containers. “Any debate about the post-consumer use or re-use of plastic bottled water containers must include how we, as a nation, increase the recycling rates and capture more of the plastic packaging for reuse,” Mr. Doss commented.
To put the issue in perspective, in 2006 a total of 244 billion units of ready-to-drink beverages were sold, and only 33% of those units were packaged in plastic. A total of 36 billion units of bottled water were sold in 2006, amounting to only 15% of all beverage units sold. That means that 85% of all the beverage units sold in 2006 were for products other than bottled water. With regard to the lack of recycling of beverage units, bottled water critics claim that our products are filling up municipal landfills. Beverage containers are recycled at an overall rate of approximately 25%, a much higher rate than other food containers, and that rate continues to increase. Bottled water containers, as a subset of all beverage containers, has a recycling rate of approximately 21%. However, bottled water containers make up only 0.3% of the entire municipal waste stream in the United States. Clearly, bottled water containers are not significantly contributing to municipal landfills. Significant overall progress with recycling and the management of municipal waste streams cannot be made unless the public policy net is cast much more broadly than just bottled water. Efficiently capturing and recycling of all plastic products should be a priority.
Light-weighting bottled water containers is a top priority for the bottled water industry. These new bottles use far less plastic than they did 10 years ago. The gram weight of plastic in a PET bottled water container is one of the lowest in the food industry, with less than 12.5 grams for a 500 ml container. This has resulted in substantial decrease in plastic per container in the industry. “This innovation is readily apparent to consumers as they can actually feel the difference in their bottled water container,” Mr. Doss pointed out.
Bottled Water’s Role in Disaster Response
Bottled water plays a vital role in disaster response. Clean, safe water is a critical need for citizens and first responders immediately following a natural disaster or other catastrophic event. Unfortunately, the availability of water from public water systems is often compromised in the aftermath of such an event. During these times, bottled water is the best option to deliver clean safe drinking water quickly into affected areas.
The bottled water industry has always been at the forefront of relief efforts during natural disasters and other catastrophic events. Throughout the years, bottled water companies have immediately responded to the need for clean water after natural disasters, such as Hurricanes Andrew, Charlie, and Katrina, or the terrorist attacks on the Pentagon and World Trade Center. More recently, our member companies provided bottled water to those in need in the aftermath of the spring flooding in the Midwest and just two weeks ago to the victims of Hurricanes Gustav and Hanna. The bottled water industry looks to IBWA to help coordinate activities with state and federal government agencies and organizations, such as the American Red Cross and Salvation Army. Working together, we determine the quickest and most effective way to deliver safe bottled water into affected areas to augment other relief efforts. Realistically, it takes vibrant, commercial bottled water industry to produce the much-needed bottled water that is made available for disaster assistance.
Overview of the Bottled Water Industry
According to the Beverage Marketing Corporation, in 2007, the total volume of bottled water consumed in the United States surpassed 8.8 billion gallons, a 6.9% advance over the 2006 volume level. That translates into an average of 29.3 gallons per person, which means U.S. residents now drink more bottled water annually than any other beverage except carbonated soft drinks.
“Yet, even at these levels, bottled water accounts for less than 0.02% percent of all groundwater withdrawals annually,” Mr. Doss stated. “
“The U.S. bottled water market is truly a consumer driven market, in which consumers are making healthier choices in the beverage category,” Mr. Doss said. “The strength of consumer self-generated demand is illustrated by the relatively modest amount spent on advertising. The 2006 bottled water advertising expenses totaled only $52 million. For comparison purposes, $637 million was spent on advertising for carbonated soft drinks (over ten times that for bottled water) and advertising expenses for beer totaled $1 billion (approximately 20 times that for bottled water.)”
IBWA membership statistics indicate that bottled water companies in the United States are primarily family owned and operated small businesses. Over 60% of the IBWA membership has sales less than $1 million and 90% have sales less than $10 million. Almost all bottled water brands are sold on a local or regional basis with the exception of imports and purified waters. Thus, the purchase of most bottled water brands allows consumers to “buy local.”
A copy of Mr. Doss’ written testimony is also available on the IBWA web site at www.bottledwater.org.