By Jill Culora

America’s favorite packaged drink—bottled water—made history in 2021 by becoming the largest beverage category ever (by volume). Bottled water’s total volume of 15.7 billion gallons (59.4 billion liters), surpassed carbonated soft drinks’ all-time peak of 15.3 billion gallons (57.9 billion liters), which was reached in 2004. According to the Beverage Marketing Corporation (BMC), volume grew by 4.7 percent in 2021 and retail sales of bottled water grew by 11.2 percent, reaching $40.2 billion. In addition, per capita consumption was up 3.9 percent in 2021, with every person in America drinking an average of 47 gallons (171 liters) of bottled water last year. Home and office delivery (HOD) water, which made up 9.3 percent of the bottled water market in 2021, increased in volume sales by 3 percent from 2020. While individual size PET, which made up 71 percent of the market, increased in volume sales by 5.9 percent from 2020.

BMC also reported that bottled water has increased its “share of stomach” within the overall beverage market from 14.1 percent in 2009 to 24.6 percent in 2021. Carbonated soft drinks hold the second position, with 18.6 percent, reflecting a clear trend of consumers increasingly choosing healthy, convenient, zero-calorie bottled water instead of sugar-sweetened beverages. In fact, 44 percent of the growth in bottled water sales (from 2010 to 2020), has come from people switching from soft drinks and fruit drinks to bottled water.

The International Bottled Water Association (IBWA) advocates on behalf of the industry by focusing on the issues that are important to our members, consumers, and government officials through our numerous departments: government affairs (local, state, and federal), environmental sustainability, science, tech­nology, and communications. The Association unifies the bottled water industry and represents uncompromising commitment to the safety and availability of bottled water.

Water Cooler Tariffs
IBWA continues to lead efforts to reduce the impact of 25 percent tariffs imposed on water coolers and component parts from China. IBWA and its members have submitted several op-eds with news agencies across the country to help shed light on the impact of these tariffs on the home and office delivery sector of the industry, held numerous meetings with influential members of Congress to discuss industry concerns, met with Biden Administration officials to plead our case, and supported action by the U.S. Customs and Border Protection to alter the import code for hot and cold water dispensers in order to remove the tariffs imposed on Chinese imports. IBWA is an active member of the Americans for Free Trade coalition, which is a group of industry trade organizations whose members are similarly impacted by tariffs imposed on Chinese imports.

Safety of BPA
IBWA continues to actively monitor new developments regarding the safety of bisphenol A (BPA), a chemical compound used in the manufacturing of polycarbonate plastic, which is used in many 3- and 5-gallon water cooler bottles. This includes responding to news stories and social media posts that contain false or inaccurate information about BPA and opposing local, state, and federal bills that would restrict its use or negatively impact bottled water products. Recently, the U.S. Food and Drug Administration (FDA) agreed to a scientific review of BPA based on a petition filed by organizations that include the Environmental Defense Fund (EDF), Consumer Reports, and Endocrine Society. The petition requested that the FDA “revoke uses of [BPA] for adhesives and coatings and strictly limit the migration of the substances into food from various plastic food contact articles.” The FDA is accepting comments on the food additive petition, and IBWA will work together with other industries and associations in responding to this petition.

Communications and Media Activity
IBWA’s communications efforts work to ensure that our members and the public have access to fact-based information about healthy hydration and the bottled water industry. While we’re always on the front lines—monitoring news clips, responding timely to media requests, and informing editors and writers when a false or misleading article requires a correction—during the last year, IBWA has paid special attention to the following issues:

  • As water scarcity issues continue to worsen in the western part of the United States, many misleading comments about bottled water are being published on social media. IBWA’s hydratethestates.org website acts as an information hub to help educate and advocate using third-party facts and figures. The site provides the facts about the bottled water industry’s small water use as social media and news reports often incorrectly claim that the industry is a large water user. But here’s the truth: Of all the water used in the United States, bottled water uses a very tiny amount—just 0.01 percent. In addition, because most bottled water is consumed in the same region where it is sourced (whether from a municipal or groundwater source), consumers need not worry that their bottled water is being trucked great distances. That’s just not an economically viable strategy for the vast majority of bottled water businesses.
  • In absence of any federal regulation or recommended limits for PFAS (per- and polyfluoroalkyl substances) in bottled water, IBWA set self-imposed, mandatory testing require­ments and standards of quality (SOQ) for our member company’s bottled water products. IBWA’s PFAS SOQs of 5 parts per trillion (ppt) for one PFAS and 10 ppt for more than one PFAS are more stringent than any state PFAS regulation. By testing for PFAS, IBWA bottler members provide their consumers, local and state governments, and disaster and emergency relief personnel further assurance that bottled water is a safe and convenient product for everyday use and in times of need—such as when tap water is compromised. This industry-led action underscores the commitment of IBWA members to always provide consumers with the safest and highest quality bottled water products. In addition, IBWA has asked FDA to issue a national SOQ for PFAS that would preempt any state standards. This effort would prevent bottled water companies from being subject to a patchwork of differing state laws on this issue.
  • When IBWA developed a series of infographics that actively promote the fact that, in addition to being the lowest water user to produce its contents, bottle water’s PET packaging also has the smallest environmental footprint of all other packaging types, including aluminum, glass, paperboard cartons, and even PET soda bottles, the public’s initial response was disbelief. The facts countered everything they had been told about plastic bottled water containers. However, once the initial shock wore off, consumers reviewed the details provided in the infographics and we began to observe the public’s disbelief level out. The Trayak LCA study shows how the production of 16.9 oz PET bottled water containers (the most popular size among consumers) uses less water and less fossil fuels, and emits less greenhouse gases than the produc­tion of any similarly sized packaging alternative. (See graphic here: https://bottledwater.org/wp-content/uploads/2021/05/Environmental_Impact_of_Drink_Packaging_2021_800.jpg)
  • The industry is working with partners (such as Keep America Beautiful and The Recycle Partnership) to educate consumers about the importance of recycling. All bottled water containers are 100-percent recyclable—even the cap. And, according to the National Association for PET Container Resources, PET plastic bottled water containers can be recycled over and over again (https://napcor.com/frequently-asked-questions/). Research shows that bottled water drinkers are the best recyclers, with water containers making up approximately 55 percent of curbside recycling programs.

Government Affairs
At the federal, state, and local levels, IBWA works on numerous legislative issues that could either benefit—or potentially harm— the bottled water industry. Nearly every state addresses bottled water issues—a fact that is reflected by the more than 1,000 pieces of legislation that are introduced in state legislatures and various state government agencies each year. In addition, the states consider more than 400 proposed regulations annually that could impact the bottled water industry.

Water Stewardship
Bottled water companies have a long, deeply held tradition of effectively and responsibly protecting, managing, and using all of their water resources. Having long-term and sustainable water sources is essential for the bottled water industry, so IBWA members are notably efficient users of those water sources. As the leader for the bottled water industry on these issues, the association helps to bolster its members’ water stewardship practices by developing guidance documents, such as the IBWA Water Stewardship Best Practices Framework Guidance and Water Stewardship Best Practices Guide.

The guides are designed for all bottled water companies to use—regardless of production size, location and/or the development stage of their water stewardship programs. Key aspects of each best practice were divided into three approach categories:  initial, advanced, and leading. Members can use the information contained in these documents to evaluate their current water stewardship practices against others in the industry and identify opportunities for improvement or outreach.

In addition, all IBWA bottler members that produce bottled water from a groundwater source comply with the IBWA Bottled Water Code of Practice, which sets out the following criteria for source water monitoring and protection:

  • An evaluation of the chemical, physical, microbiological, and radiological characteristics of the source.
  • A report on the regional geology surrounding the site and the specific site geology. A description of the vertical and horizontal extent of the source aquifer using existing data. The information will be used to define the recharge area of the aquifer, or in the case of regional aquifers, the zone of influence of the subject source.
  • A report detailing the development of the source and the method of construction, including spring design, well instal­lation, surface catchment, intake structures, and transmission facilities, as appropriate.
  • A watershed survey of the recharge area or zone of influence of subject source that identifies and evaluates actual and potential sources of contamination, which shall be updated every three years, including any reported discharge that may affect the source.
  • Based on the findings of the watershed survey, a plan for special monitoring of any significant contaminant source and for taking restrictive preventative or corrective measures as appropriate to protect the source water.

Bottled Water Plant Siting and Permitting Opposition
Activist groups have seized upon plant siting and permitting activities as an opportunity to attack the bottled water industry. Their stated objective is to prevent bottled water companies from siting, permitting, and re-permitting bottled water plants and is aimed at both groundwater and public water source bottling facilities. These actions are often aimed at large bottled water companies; however, many of their proposals would also impact small- and mid-size bottlers. Anti-bottled water groups perpetuate false claims that are built around fear, conspiracy, and corporatization and directly tie them to the siting, permitting, or re-permitting of bottled water plants. IBWA’s Plant Siting and Permitting Working Group has developed a Best Practices Guide for Plant Siting. That guide is a tool that bottlers can use to review the requirements for developing a bottling facility and help them integrate with the community and develop a working relationship that is mutually beneficial.

FSMA Compliance
IBWA continues its efforts to assist members in complying with FDA’s Food Safety Modernization Act (FSMA). All bottled water companies, including very small companies, must comply with FDA’s final rule for Current Good Manufacturing Practices, Hazard Analysis and Risk-Based Preventive Controls for Human Food. Among other things, the rule requires food facilities to have preventive controls-qualified individuals (PCQIs) on staff. IBWA also prepared a detailed guidance document on the require­ments of the FSMA Preventive Controls Rule. That document, combined with the audit check sheets, are the best tools available from IBWA to help companies prepare for an FDA inspection.

Microplastics
IBWA continues to follow microplastics developments, through its working group and collaboration with the Natural Mineral Waters Europe (NMWE), to monitor and assess research and news stories reporting on claims about microplastics being found in food and beverages, including bottled water. It is important to note that there is currently no scientific consensus on the potential health impacts of microplastic particles, which are found in all aspects of our environment—soil, air, and water.

IBWA’s Microplastics Working Group reviewed the strengths and weaknesses of available testing methods, based on publicly available studies. The Working Group identified two detection methods that are effective for bottled water: FTIR Spectroscopy and Raman Spectroscopy. In addition, the IBWA Working Group coordinated its efforts with the NMWE. They have also identified the same two detection methods to determine if microplastics are in bottled water. NMWE has also been working with the academic community to develop laboratory protocols for conduct­ing testing—from sampling through the reporting of results.

A research study titled, “Analysis of microplastics in drinking water and other clean water samples with micro-Raman and micro-infrared spectroscopy: minimum requirements and best practice guidelines,” was published in July of 2021 in The Journal of Analytical and Bioanalytical Chemistry following three years of work by the NMWE Technical Working Group. The paper proposes quality criteria for analysis of microplastics including the sampling method, sample size, sample processing and storage, laboratory preparation, clean air conditions, positive and negative controls, sample treatment, and polymer identification using micro-Raman and micro-infrared spectroscopy. This research study provides a framework for harmonization and standardiza­tion of methods in Europe and globally for microplastic analysis.

IBWA is also monitoring the implementation of a 2018 law that requires the California State Water Resources Control Board (SWRCB) to adopt a definition of microplastics in drinking water. This definition would apply only to tap water, but the Board’s decision could influence California and other state regulators who may want to regulate microplastics in bottled water. The Control Board adopted its definition in June 2020. The Control Board has delayed adopting test methodologies and developing accreditation requirements for laboratories to analyze microplastics until later this year. It is unlikely the SWRCB will set a health-based regulatory standard due to lack of scientific data to support such action. A May 2022 publication in The Journal Microplastics and Nanoplastics titled “Development and application of a health-based framework for informing regulatory action in relation to exposure of microplastic particles in California drinking water” noted that: “… While it was possible to derive a conservative screening level to inform monitoring activities, it was not possible to extrapolate a human–health-based threshold value for microplastics, which is largely due to concerns regard­ing the relative quality and reliability of current data, but also due to the inability to extrapolate data from studies using mono-disperse plastic particles, such as polystyrene spheres to an environmentally relevant exposure of microplastics.”

COVID-19 Impact
The temporary office closings during the height of the COVID-19 pandemic impacted the office delivery segment of the bottled water industry; however, bottlers experienced record highs in residential business throughout the past year. Many consumers recognized the benefits of e-commerce and rapidly adopted direct-to-consumer services as an added convenience to their lifestyle. Those consumers report that they plan to continue having bottled water delivered to their homes post-pandemic. With more and more offices reopening in the United States, the industry is optimistic that office deliveries will rebound.

Looking Ahead
BMC predicts that bottled water will continue to build upon its growth history and gain more market share. As consumers continue to increasingly choose bottled water as their healthy hydration beverage, IBWA will continue to work hard to create a favorable business and public affairs climate for the bottled water industry, as well as to proactively promote and strongly defend the interests of all its member companies.

About the Author
Jill Culora is VP of Communications for IBWA. She holds a Post-Baccalaureate Degree in journalism from the University of King’s College (Halifax, Nova Scotia) and a Bachelor of Arts Degree in political science from Dalhousie University (Halifax, Nova Scotia).

About the organization
IBWA is the authoritative source of information about all types of bottled waters, including spring, mineral, purified, artesian and sparkling. Founded in 1958, its membership includes US and international bottlers, distributors and suppliers. IBWA is committed to working with FDA, which regulates bottled water as a packaged food product, to set comprehensive and stringent standards for safe, high-quality bottled water products. In addition to FDA regulations, member bottlers must adhere to the IBWA Bottled Water Code of Practice, which mandates additional standards and practices that in some cases are more stringent than federal and state regulations. A key feature of the Code is a mandatory annual plant inspection by an independent, third-party organization.

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