By Jill Culora
The United States’ favorite packaged drink—bottled water—hit new peaks in both U.S. volume and sales in 2022, data from the Beverage Marketing Corporation (BMC) shows. The total volume sold in 2022 was 15.9 billion gallons (60.2 billion liters), its highest volume ever, surpassing carbonated soft drinks for the seventh year in a row. In U.S. retail dollars, 2022 sales approached $46 billion, up from $40.8 billion in 2021.
Home- and office-delivery water, which made up 9.5 percent of the bottled water market in 2022, increased in volume sales by 4.9 percent from 2021. While individual-size PET, which made up 71.2 percent of the market, increased in volume sales by 1.4 percent from 2021.
BMC also reported that within the overall beverage market, bottled water has increased its share of stomach (or, as explained by Seed World, “how much of their purchasing consumers devote to a particular retail brand”) from 14.1 percent in 2009 to 24.6 percent in 2022. Carbonated soft drinks held the second position, with 18.7 percent, clearly reflecting consumers’ increasing preference for 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), came from people switching from soft drinks and fruit drinks to bottled water. U.S. consumers now drink 46.5 gallons (176 liters) of bottled water per person, compared to 36 gallons (136 liters) of carbonated soft drinks.
The International Bottled Water Association (IBWA) advocates on behalf of the industry by focusing on the issues that are important to IBWA members, consumers, and government officials through 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, quality, and availability of bottled water.
Safety of BPA
IBWA continues to defend the safety of bisphenol A (BPA), a compound used to make polycarbonate plastic, which is used in many three- and five-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.
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, Consumer Reports, and the 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 accepted comments on the food additive petition, and IBWA assisted interested groups in opposing this revision. The FDA continues its review of the petition.
PFAS and Bottled Water
PFAS—per- and polyfluoroalkyl substances—are a group of man-made chemicals that includes PFOA, PFOS, GenX, and many others. Currently, neither the U.S. Environmental Protection Agency (EPA), which regulates tap water, nor the FDA, which regulates bottled water, has legally enforceable regulations for PFAS in drinking water.
The EPA has a proposed regulation for six PFAS substances in tap water. By law, once the EPA PFAS regulation becomes final, the FDA will have 180 days to either issue a corresponding regulation for bottled water or publish a rationale for why the EPA’s regulation is not applicable to bottled water. If the FDA does neither within the prescribed time frame, then the EPA PFAS regulation will automatically become applicable to bottled water by operation of law. This ensures parity in the regulation of bottled water and tap water.
IBWA requires its members to test for 18 PFAS substances in all the products they sell. In addition, IBWA member companies must meet the following standards of quality (SOQs) for PFAS in their bottled water products:
- 5 parts per trillion (ppt) for detection of a single PFAS compound.
- 10 ppt for detection of two or more PFAS compounds.
IBWA’s PFAS actions underscore the commitment of IBWA members to always provide consumers with the safest and highest-quality bottled water products. Testing for PFAS provides 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 when tap water is compromised.
In November 2019, IBWA asked the FDA to establish an SOQ for PFAS in bottled water. The FDA responded to IBWA’s request, stating that “establishing an SOQ for PFAS in bottled water at this time would not significantly enhance FDA’s mission of public health protection.” This was based on the FDA’s testing and analysis of 30 bottled water products, none of which showed any detectable levels of PFAS. In June of 2023, the FDA released test results for PFAS in fresh and processed foods and bottled water. The bottled water results were all negative.
FSMA Compliance
IBWA continues its efforts to assist members in complying with the FDA’s Food Safety Modernization Act (FSMA). All bottled water companies, including very small companies, must comply with the FDA’s final rule for Current Good Manufacturing Practice, Hazard Analysis, and Risk-Based Preventive Controls for Human Food. Among other stipulations, the rule requires food facilities to have individuals on staff who are preventive-controls qualified.
IBWA released an updated 2023 version of the Plant Technical Reference Manual, which contains a detailed guidance document on the requirements of the FSMA preventive-controls rule. That document, combined with an audit check sheet, are the best tools available from IBWA to help companies prepare for an FDA inspection.
Microplastics
The microplastics issue continues to get a lot of attention from the media and government officials. When responding to media and others who have questions about microplastics, IBWA points out that research continues on this topic, and bottled water is just one of thousands of food and beverage products packaged in plastic containers. Microplastic particles are found everywhere—including in soil, air, and water. We also inform people that there is currently no scientific agreement on what amount of microplastics present a human health risk.
A World Health Organization (WHO) report concluded that due to minimal scientific research, no adverse health effects could be drawn from dietary exposure to nano- and microplastic particles less than 10 microns. The report looked at studies concerning water, food, and beverages. WHO recommended more research, as well as standardized methods for measuring and quantifying microplastics.
California is also looking at this issue. The state has defined and established testing methods and will begin monitoring for microplastics in tap water next year. As of publication of this article, California has not set a public health goal or regulatory level. IBWA continues to follow microplastics developments.
Communications and Media Activity
IBWA works to ensure that its members and the public have access to fact-based information about healthy hydration and the bottled water industry. While IBWA is 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:
Although water-scarcity issues have improved in the western part of the United States, many misleading comments about bottled water are still being published on social media. IBWA’s Hydrate the States website (hydratethestates
.org) acts as an information hub to help educate and advocate using third-party facts and figures. The site provides 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 of all the water used in the United States, bottled water uses a 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 most bottled water businesses.
As false information about bottled water products continues to spread in the news and on social media, IBWA issued an Earth Day press release centered on the industry’s small environmental footprint. “6 Important Bottled Water Facts for Earth Day” included the following true statements:
- The bottled water industry is not a major plastic user.
- Bottled water containers are recycled at rates that are higher than average.
- PET bottled water has the smallest environmental footprint of all packaged drinks.
- Bottled water drinkers litter less.
- Bottled water containers are not a major source of ocean pollution and microplastics.
- Water used by bottled water companies is replenishable.
The bottled water industry works with partner organizations to help promote and advance U.S. recycling efforts. Through coordinated efforts, Keep America Beautiful and The Recycling Partnership work with IBWA to educate consumers about the importance of recycling. All bottled water containers are 100 percent recyclable—even the caps. And, according to the National Association for PET Container Resources, PET plastic bottled water containers can be recycled over and over again. Research shows that bottled water drinkers are the most active recyclers, with PET plastic water containers making up approximately 49 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. These include potential bans on bottled water sales in national parks; extraction tax proposals in Florida; recycled-content use requirements in California, the state of Washington, and New Jersey; and extended producer-responsibility and bottle-deposit legislation in several states and the federal government.
Nearly every state addresses bottled water issues, which is reflected by the more than 1,000 pieces of legislation 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 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, and 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 preventive or corrective measures as appropriate to protect the source water.
Bottled Water Plant Siting and Permitting Opposition
Activist groups opposing the bottled water industry have seized upon plant siting and permitting. 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 midsize bottlers.
IBWA’s Plant Siting and Permitting Working Group has developed the Best Practices Guide for Plant Siting. It is a tool that bottlers can use to review the requirements for developing a bottling facility, help them integrate with the community, and develop a working relationship with the community that is mutually beneficial.
Drinking Water Safety and Quality
Bottled water companies are continually focused on ensuring the safety of their water—that’s why they stay on top of emerging contaminant issues. Most people likely don’t know that gallon for gallon, bottled water in the United States is tested 26 times more often than tap water. Many bottlers publish their water-testing results online for easy consumer access. By U.S. federal law, bottled water that does not meet strict SOQs implemented by the FDA can be recalled and removed from store shelves. This is in contrast to tap water, which is already distributed to people’s homes before the public is alerted to a water-quality problem. This is an important difference as PFAS contamination in public systems and private wells becomes more prevalent.
Bottled Water: There When You Need It
Each year, U.S. communities experience instances of compromised public water systems caused by emergencies such as boil alerts due to contaminated water, hurricanes, fires, and floods. Every time this happens, people can be confident that IBWA member-brand bottled water products offer a safe drinking-water alternative. The bottled water industry has a proven record of being ready to help when emergencies and disastrous events occur, and bottled water companies donate millions of gallons of their products every year to help ensure a reliable source of drinking water is available for the public during and after emergencies.
Looking Ahead
IBWA 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 proactively promote and strongly defend the interests of all its member companies.
About the Author
Jill Culora is vice president of communications for the International Bottled Water Association. 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
The International Bottled Water Association 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 U.S. and international bottlers, distributors, and suppliers. IBWA is committed to working with the FDA, which regulates bottled water as a packaged food product, to set comprehensive and stringent standards for safe, high-quality bottled water products.