October 14, 2008

Consumers can remain confident that bottled water is a safe, healthy packaged food product that is comprehensively regulated by the United States

 Food and Drug Administration

A report that will be released by the Environmental Working Group (EWG) on Oct. 15, 2008, contains false claims and exaggerations about bottled water products, according to the International Bottled Water Association.

“The testing results show that only two bottled water brands didn’t meet a California state standard for one regulated substance,” said IBWA President Joe Doss. There are many hundreds of brands sold in the United States that are not involved in this study.

“While bottled water products should always comply with all established regulatory standards, the California requirement for this substance is eight times lower than the United States Food and Drug Administration (FDA) standard of quality for bottled water and the Environmental Protection Agency (EPA) maximum contaminant level for tap water,” Mr. Doss said.


The report provides results from of a market basket testing program that the EWG conducted on ten brands of bottled water in nine states and the District of Columbia. “This is certainly not a representative sample of bottled water products, which the report acknowledges,” he said.

In the report, the EWG frequently mischaracterizes substances found in the tested bottled water products and discusses them out of context with accepted scientific determinations, he said. 

“In general, the report is based on the faulty premise that if any substance is present in a bottled water product, even if it does not exceed the established regulatory limit or no standard has been set, then it’s a health concern.” 

For example, EWG was critical of the bottled water brands found to contain fluoride. However, fluoride can prevent tooth decay and the American Dental Association has stated that “Whether you drink fluoridated water from the tap or buy it in a bottle, you’re doing the right thing for your oral health.”  Moreover, the levels of fluoride found in the bottled water tested by the EWG were all in compliance with the applicable FDA standards.

Mr. Doss said the EWG repeatedly fails to draw any correlation between levels of substances found in the bottled water brands tested and the actual levels at which health effects would be evident.

“In another example of the EWG’s alarmist tactics, what they call “fertilizer pollution” are actually organic components that are a natural constituent in all water. Moreover, none of these substances was found to exceed any state or federal standard. The EWG also criticized the tested bottled water for alleged “bacterial contamination.” EWG mistakenly and erroneously alleges the presence of HPC bacteria as a contaminant. Again, the levels of HPC found in the bottled water didn’t exceed any state or federal standard. In fact, HPC is commonly found at these same levels in many foods including fruits, meats, produce, and dairy products and has no adverse health consequences,” he said.

The EWG also criticizes bottled water companies “who unscrupulously use taxpayer-supported tap water supplies” without recognizing that  bottled water companies who use public water systems as their source pay city taxes and monthly water fees.  In no way is the water “free”, said Mr. Doss. 

“In another unusual twisting of science, the EWG incorrectly labels “total dissolved solids” as “pollutants.”  While total dissolved solids are not permitted in distilled bottled water, they are important for the taste and character of spring and mineral water. In fact they are such an intrinsic part of what makes a mineral water that FDA has set a minimum level of 250 parts per million for these products.”

The IBWA Code of Practice limit for the reported substance in question is the same as the California standard. However, neither of the two brands mentioned by the EWG were made by IBWA members. The decision to set the IBWA standard at this level was made to ensure that IBWA members who complied with our Code of Practice requirements would meet all state and federal bottled water regulations.

Furthermore, contrary to EWG’s claim, the bottled water industry is a good steward of the environment, Mr. Doss said.

“The bottled water industry uses minimal amounts of groundwater to produce this important consumer product and does so with great efficiency. According to a report issued by the Drinking Water Research Foundation, annual bottled water production accounts for less than 2/100 of a percent of the total groundwater withdrawn in the United States each year. “

In addition, bottled water companies have been taking actions to reduce their environmental footprint. For example, the bottled water industry is using much lighter weight plastics for its containers, utilizing more fuel efficient means of transportation, and developing new technologies in product packaging, such as the use of recycled content. All bottled water containers are one-hundred percent recyclable. While the bottled water industry supports effective environmental conservation policies, we strongly believe that any efforts to reduce the environmental impact of packaging must focus on all consumer goods and not target any one industry. Because bottled water containers make up just one-third of one percent of the entire waste stream, any proposed solutions must cover all consumer products or they will be ineffective in dealing with the environmental issue.

EWG also raised the issue of providing consumers with information about what substances are in their bottled water.

“IBWA supports a consumer’s right to clear, accurate and comprehensive information about the bottled water products they purchase,” he said. “All packaged foods and beverages, including bottled water, are subject to extensive FDA labeling requirements that provide consumers with a great deal of product quality information. In addition, virtually all bottled water products include a phone number on the label that consumers can use to contact the company.” 

IBWA believes that the most feasible mechanism for consumers to obtain information not already on the label is through a request to the bottler. Consumers have many options when deciding which bottled water brand to drink. If a bottled water company does not provide the information that a consumer requests, he or she can choose another brand, he said.

Consumers should also consider these additional measures, which help ensure the safety and quality of all bottled water products:

  • Bottled water is fully regulated as a packaged food product by the U.S. Food and Drug Administration (FDA) and bound by FDA’s quality, safety, inspection and labeling requirements.
  • FDA and state governments recognize both groundwater and municipal water systems as legitimate and valid sources for bottled water production.  There are specific labeling and other standards to help ensure consumers are aware of the type of bottled water they choose.
  • Bottled water is not simply tap water in a bottle. Bottled water companies that use municipal source water often treat and purify the water employing processes such as reverse osmosis and distillation before it is bottled and delivered to consumers as a packaged food product.  The product will be labeled as “purified water,” or alternatively, “reverse osmosis water” if it is treated by reverse osmosis or “distilled water” if it treated by distillation.
  • If bottled water is sourced from a municipal water system and has not been further treated, FDA requires the label to state that it is from a municipal or community water system.
  • Natural bottled water products, such as mineral water, spring water or artesian water, come from well-protected, underground water sources not under the direct influence of surface water.
  • Bottled water products are required to comply at all times with FDA Standards of Quality.  As with other food products, bottled water is subject to the food adulteration requirements of the Federal Food, Drug, and Cosmetic Act and is also subject recall and the full array of FDA enforcement actions, including warning letters, civil (seizure and/or injunction) and criminal penalties.
  • In addition to federal and state regulations, members of the International Bottled Water Association (IBWA) are required to adhere to standards in the IBWA Bottled Water Code of Practice that, in several cases, are stricter than FDA and state bottled water regulations.  The IBWA Bottled Water Code of Practice is enforced through a mandatory, annual, unannounced plant inspection by an independent, third-party organization.


The following measures are employed by IBWA member bottlers to help ensure the safety of the bottled water brands they produce:

  1. A MULTI-BARRIER APPROACH – Bottled water products are produced utilizing a multi-barrier approach, from source to finished product, that helps prevent possible harmful microorganisms from contaminating the finished product as well as storage, production, and transportation equipment.  Measures in a multi-barrier approach may include source protection, source monitoring, reverse osmosis, distillation, filtration, ozonation or ultraviolet (UV) light.  Many of the steps in a multi-barrier system may be effective in safeguarding bottled water from microbiological, chemical, and other contamination.  Piping in and out of plants, as well as storage silos and water tankers are also maintained through daily sanitation procedures.  In addition, bottled water products are bottled in a controlled, sanitary environment to prevent contamination during the filling operation

  1. ROUTINE TESTING – Water used to produce bottled water is tested both as it enters the plant, during production and as finished product.  Multiple tests and regular screening are performed by trained quality control technicians to evaluate microbial, physical and chemical quality.  Such screening can be used to detect the presence of agents that may be an indicator of product contamination.  These protection measures and other quality control programs help ensure that substandard products do not reach the market.


  1. HAACP CONTROLS –IBWA members are required to employ a HACCP (Hazard Analysis Critical Control Point) approach to quality assurance.  This practice scrutinizes every step of the production process – from source to finished product – that are critically important to the safety of the product and puts in place systems to help ensure that all safety and quality control processes are functioning effectively.  Identification of risk and severity of health effects and control measures for specific biological, chemical and physical agents are included.  Widely used in the food and pharmaceutical industries, the FDA considers HACCP a comprehensive method for assuring product safety.

  1. SOURCES AND FACILITIES ARE SECURE AND MONITORED – Natural bottled water products, such as spring water or artesian water, come from well-protected, underground water sources that are required by FDA regulations to be free of direct influence of surface water contamination.  The water is collected at sites and bottled at facilities with security systems that may include controlled access to the plant and critical production areas, gating, motion sensors, electronic contact security alarms, and tamper-proof locks.  Water intake systems are sanitary and sealed.For brands that utilize community water systems as their source, bottlers work in concert with community water authorities to ensure the security and safety of the system’s source and the community’s water and employ equivalent security measures at the bottling plant.