I N T E R N AT I O N A L B OT T L E D WAT E R A S S O C I AT I O N
PROGRESS REPORT
2023
2024 IBWA LEADERSHIP BOARD OF DIRECTORS: OFFICERS CHAIR Hih Song Kim BlueTriton Brands Stamford, Connecticut
IM M EDIATE PAST CHAIR Henry R. Hidell, III Hidell International Hingham, Massachusetts
VICE CHAIR Doug Hidding Blackhawk Molding, Co. Addison, Illinois
P RESIDENT AND CEO Joe Doss International Bottled Water Association Alexandria, Virginia
TRE ASURER Joe Bell Aqua Filter Fresh, Inc. Pittsburgh, Pennsylvania
EXECUTIVE COMMITTEE CHAIR Hih Song Kim BlueTriton Brands Stamford, Connecticut Joe Bell Aqua Filter Fresh, Inc. Pittsburgh, Pennsylvania Eric Devanie Primo Water Tampa, Florida CR Hall Hall’s Culligan Water Wichita, Kansas Brian Hess Niagara Bottling, LLC Diamond Bar, California
BOARD MEMBERS Eric Devanie Primo Water Tampa, Florida
Jillian Olsen Cherry Ridge Consulting Sciota, Pennsylvania
CR Hall Hall’s Culligan Water Wichita, Kansas
David Redick Steelhead, Inc. San Antonio, Texas
Tanner Hanstein Eureka Water Company Oklahoma City, Oklahoma
Robert Smith Grand Springs Distribution Alton, Virginia
Ryan Heiken Crystal Clear Bottled Water Des Moines, Iowa
Brad Wester Premium Waters, Inc. Minneapolis, Minnesota
Brian Hess Niagara Bottling, LLC Diamond Bar, California
Bill Young Absopure Water Company, Inc. Plymouth, Michigan
Dan Kelly Polymer Solutions International, Inc. Medford, New Jersey Lynette MacFee Oasis International Columbus, Ohio
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Doug Hidding Blackhawk Molding, Co. Addison, Illinois Henry R. Hidell, III Hidell International Hingham, Massachusetts Dan Kelly Polymer Solutions International, Inc. Medford, New Jersey Robert Smith Grand Springs Distribution Alton, Virginia Bill Young Absopure Water Company, Inc. Plymouth, Michigan
LETTER FROM THE PRESIDENT
Bottled water continues to be the No.1 packaged beverage in the United States. For the past eight years, Americans have consumed more bottled water than any other beverage on store shelves. That’s a big achievement for our industry, especially considering bottled water critics state that their goal is to remove our products from the market. They work to do that by using erroneous environmental claims and flawed logic to attempt to ban the sale of bottled water. In 2023, the industry faced numerous proposals at the city, state, and federal levels to ban the sale of bottled water. Proposals were considered in Irvine and Los Angeles, California; the state of Massachusetts; and at the U.S. Department of the Interior (DOI), focusing on the National Park Service (NPS). IBWA strongly opposed those attempts to ban the sale of bottled water, making sure to introduce facts into any discussion to reveal that plastic bottled water containers have the smallest environmental footprint of all beverage containers. Irvine, Los Angeles, and the DOI decided to gather more data before making final decisions. Only Massachusetts, via an Executive Order by the governor, banned the purchase of all single-serve plastic beverage containers (21 ounces or less), but only by state government agencies. Environmental issues are trending—like extended producer responsibility (EPR), bottle deposit bills, and recycling proposals— but more and more, policymakers are talking with IBWA and pausing to gather more data and learn the science behind the issues before passing legislation. Throughout 2023, IBWA met with state and federal legislators and provided oral and written testimony to ensure they had access to research highlighting the minimal impact plastic bottled water containers have on the environment compared to alternative packaging, such as aluminum cans, paperboard containers, and glass bottles. In conversations with legislators and the media, the positive influence credible research can have on their opinions is undeniable. Thus, IBWA continues to work with respected consulting firms to conduct studies about the environmental impact of bottled water. Two studies are currently underway, with results expected in 2024: “Water, Energy, and Emission
Use Benchmarking Study” and “Bottled Water Secondary Packaging Study.” A third study, “Bottled Water Tertiary Packaging Study,” is currently in the planning stages. Although bottled water is the healthiest packaged beverage product, IBWA faces challenges ensuring that consumers are aware of the health benefits of water consumption. Whether encouraging the U.S. Food and Drug Administration (FDA) to implement regulations allowing bottled water product labels to include the term “healthy,” working to add more water recommendations in the Dietary Guidelines for Americans, or advocating for water to be added to the MyPlate nutrition graphic, IBWA’s goal is to promote the important role water plays in a healthy diet and make sure that knowledge is broadly shared. Quite a few emerging contaminant issues made headlines in 2023. The most prolific was per- and polyfluoroalkyl substances (PFAS). IBWA first addressed PFAS back in 2019, acting swiftly to establish what are currently the toughest PFAS water quality standards: 5 parts per trillion (ppt) for one PFAS; 10 ppt for more than one PFAS. Meanwhile, FDA continues to wait for the EPA to finalize maximum contaminant levels for PFAS compounds before setting bottled water standards. California, the state that often sets the precedent for what happens in other states, looked into adding antimony (trivalent compounds) as a carcinogenic on the state’s Proposition 65 list. Once again, calmer heads prevailed after looking into the research, and antimony (trivalent compounds) were determined not to meet the criteria for being listed as causing cancer. IBWA, as a community of industry professionals, faced the many and diverse issues impacting bottled water companies head-on, working to create a legislative and economic climate where our members can flourish. IBWA’s 2023 Progress Report summarizes our most notable efforts to promote and defend our members’ products and ensure consumers continue to have the right to choose bottled water as their healthy hydration option.
Joe Doss IBWA President and CEO
2023 IBWA PROGRESS REPORT | 1
OUR ASSOCIATION Who We Are
Industry Statistics: Still No.1
The International Bottled Water Association (IBWA) is the trade association that represents the No.1 packaged beverage in the United States: bottled water. Our diverse membership consists of U.S. and international bottlers and distributors that produce great-tasting, safe, quality bottled water products that are consistently and reliably delivered and the suppliers that serve them. IBWA bottlers produce 73% of the bottled water sold in the U.S. market. The vast majority of our members are small, locally owned bottlers, with 60% reporting less than $2.6 million in annual gross sales and 90% reporting less
Bottled water first earned the No.1 packaged beverage in America (by volume) ranking in 2016, when it overtook carbonated soft drinks (CSD). In 2023, bottled water retained that title for the eighth consecutive year, according to Beverage Marketing Corporation (BMC), a research/analytics firm. BMC’s preliminary 2023 figures for bottled water reveal the following:
than $10 million in annual gross sales. They are local businesses with deep roots and strong ties within their communities. IBWA members are committed to providing not only healthy hydration products to the communities they serve but also highly sought-after jobs, generating 283,546 direct industry jobs and 414,767 ancillary jobs in the United States alone. IBWA unifies the bottled water industry and represents its uncompromising commitment to the safety, quality, and availability of bottled water.
Our Priorities IBWA focuses on any and all issues that impact our members’ ability to provide consumers the quality, healthy hydration they demand. The leadership team—including the board of directors, executive committee, and committees—develops a strategy dedicated to educating legislators, regulators, and the media and growing the bottled water industry. IBWA leadership, members, staff, and consultants implement that plan of action by using transparent, science-backed research and communications to educate policy decision-makers to help ensure they make informed legislative and regulatory decisions.
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• Consumption: 15.9 billion gallons – a 0.3% increase over last year • Retail sales: $48.7 billion dollars – a 6.3% increase • Per capita consumption: 46.3 gallons – a -0.5% decrease BMC’s DrinkTell database shows that inflation has impacted the performance of all liquid refreshment beverages (LRB). While bottled water has seen a small increase in volume, most other categories (including CSD) have declined. Looking ahead, BMC projects that bottled water will increase its market share, resulting in volume growth in line with population increases. Bottled water’s latest figures show that consumers continue to make healthy hydration and lifestyle choices—and bottled water helps them meet that goal. In fact, almost all bottled water’s gains in volume during the past 20 years have come from the decreased consumption of CSD and fruit drinks. Those statistics also demonstrate that despite the efforts by our critics to discourage people from drinking bottled water, sales and consumption continue to grow. That growth is thanks to the work of IBWA’s members, consultants, and staff. The following pages review some of the key topics the industry worked on in 2023 and provide a summary of the many activities IBWA members, staff, and consultants performed throughout the year to support the bottled water industry.
BOTTLED WATER INDUSTRY CREATES:
283,546 DIRECT JOBS
414,767
ANCILLARY JOBS
CSD
12 BILLION GALLONS
Tea 5.9%
$100.6 BILLION
CSD
CSD
PER CAPITA CONSUMPTION
Coffee 11.3%
Carbonated Soft Drinks 21.1%
Heat Map
$48.7 BOTTLED BILLION WATER
46.3 GALLONS
BOTTLED WATER
CSD
34.9 GALLONS
LIKELIHOOD OF STATE OR FEDERAL ACTION
Beer 10.6%
RETAIL SALES
Milk 8.5%
IBWA POLICY ISSUES - 2023
2023* VOLUME SHARE OF STOMACH
BY WATER SEGMENT
Ban/Restrictions on Sales
Deposit Return System (Bottle Bill) Mandates to Use Recycled Content Adding Water to MyPlate
Improving Recycling Infrastructure
Increase Requirements on Groundwater Management Extraction Fees
Increasing Truck Weight Limits Limits on Use of Groundwater
IMPACT TO THE INDUSTRY
CSD
Bottled Water 27.8%
Extended Producer Responsibility (EPR)
PET Single Serve 71%
Vended 6.8%
10.1%
Fruit Bevs 4.6%
15.9 BILLION GALLONS
BOTTLED WATER
Dom. Sparkling 3.1%
Others
HOD 9.8%
BY U.S. BEVERAGE SEGMENT
Retail Bulk 7.3%
VOLUME SHARE OF STOMACH
2023 HIGHLIGHTS: BOTTLED WATER AND CARBONATED SOFT DRINKS CONSUMPTION
2023*
Imports 2%
* Preliminary Source: Beverage Marketing Corporation Copyright © 2023 by Beverage Marketing Corporation
2023 IBWA PROGRESS REPORT | 3
Environmental Impact of Beverage Packaging Systems Trayak, a sustainability consulting company, used the COMPASS® method to analyze beverage packaging systems. The Life Cycle Assessment results for seven indicators are shown in the spiderweb chart below. Each of the packaging systems is displayed as a different color and the value closest to the center represents the least impactful package option for that indicator. The research shows that the PET water bottle is the least impactful packaging system for water across all indicators researched.
Source: Life Cycle Assessment for IBWA, Trayak LLC, 2021
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Education is an important part of IBWA’s efforts to oppose sales bans on bottled water. Using the latest research and social media strategies, we promote bottled water facts to consumers and legislators to help them make sound decisions based on science.
ENVIRONMENT
Opposing Sales Bans IBWA continues to fight proposed bans on the sale of bottled water at both the state and federal levels because they are not in the public interest. While legislators erroneously claim banning bottled water packaged in plastic will have a positive impact on the environment, the truth is that they do nothing but remove the healthiest packaged beverage from store shelves, which leads to consumption of unhealthy, sugary drinks. Science supports IBWA’s position that replacing plastic with alternative packaging (e.g., aluminum cans, paperboard containers, and glass bottles) actually causes more harm to the environment. The Science. While the scientific community continues to produce research acknowledging the environmental advantages of plastic over alternative packaging types, two studies have been the cornerstone of IBWA’s efforts to educate policy makers.
in its report, it is highly likely that the report would have found an even greater disparity between GHG emissions when compared with aluminum cans and glass bottles because bottled water containers use significantly less plastic than soda. Several states addressed the issue of single-use plastics in 2023 by seeking to ban plastic bags, food service ware, and various other packaging types. A few proposals targeted beverage containers, including bottled water, but most were not given serious consideration. The outliers were California and Massachusetts. California. Late in the year, the City Council of Irvine proposed an ordinance that would ban the sale of bottled water packaged in any size of plastic container, but that proposal was later amended to ban only bottled water packaged in plastic containers of 1 liter or less. Working with American Beverage Association (ABA), IBWA contested the ban, citing the science that shows
In 2021, IBWA funded research, conducted by product
PET and high density polyethylene (HDPE) plastic bot-
sustainability consulting firm Trayak, to review the life
tles have the least impact on the environment.
cycle analyses of the following types of single-serve beverage packaging: polyethylene terephthalate (PET) water bottles, PET soda bottles, aluminum cans, glass bottles, and paperboard cartons. The findings (illustrated on page 4) showed PET water bottles have less environmental impact than the alternatives in terms of greenhouse gas emissions (GHG), fossil fuel use, water use, freshwater eutrophication, and freshwater ecotoxicity. In 2023, McKinsey & Company issued a report that shows “PET bottles have the lowest [GHG]
Thanks to the hard work of IBWA members, staff, and allies, when the council met in late November, it did not vote to ban the sale of bottled water. Instead, it voted to explore other options, including increasing recycling education, conducting more research, and focusing on eliminating certain products (e.g., plastic and polystyrene products) from city property and city events. That policy could include bottled water, but the specific items to be eliminated have not yet been determined.
emissions because of their lightweight properties
Los Angeles, the largest community in California,
and the low amount of energy required to produce
is utilizing its LA Sanitation and Environment
them. By contrast, aluminum cans have two times the
(LASAN) department to continue its efforts to reduce
emissions of PET bottles, and emissions from glass
single-use plastics. LASAN is conducting a Program
bottles are three times higher.” It is important to note
Environmental Impact Report (PEIR) pursuant to the
that this report compares PET soda bottles, rather
California Environmental Quality Act (CEQA) for the
than PET water bottles, with other packaging types. If
proposed Comprehensive Plastics Reduction Program.
McKinsey & Company had included PET water bottles
During the public comment period, IBWA submitted 2023 IBWA PROGRESS REPORT | 5
BE A PART OF THE PAC
be realized. Los Angeles’ year-long assessment to determine what items the city will consider for future action continues. Massachusetts. On September 21, 2023, the governor issued an Executive Order (EO) banning the purchase of single-serve plastic beverage containers, 21 ounces or less, by state government agencies. The purchase ban includes the governor’s office and the offices of
IBWA’s Political Action Committee (PAC) is a vital tool we use to educate members of Congress and build champions for the bottled water industry. Your PAC contributions make it possible for IBWA to support political candidates who support the bottled water industry. Due to the generosity of our members, IBWA was able to support several key members of Congress in their reelection efforts for 2023. We thank our members for your continued support of the PAC. If you are not receiving information about the IBWA PAC, it’s because we don’t have an Authorization to Solicit form for your company. Under federal law, IBWA can’t contact you about PAC issues unless we have that form. Note: Submitting this form does not obligate you to contribute to the PAC. It just gives IBWA permission to let you know about PAC activities and events. To receive more information about joining IBWA’s PAC, please contact IBWA Vice President of Government Relations Cory Martin: cmartin@bottledwater.org.
various state departments, but it does not apply either to the legislature, schools, airports, or other state-run operations or the sale of bottled water on state property. IBWA worked with the Massachusetts Beverage Association (MBA) and ABA to educate staff at the governor’s office and the media about the minimal impact on the environment of plastic packaging compared to the alternative packaging options of aluminum cans, paperboard cartons, and glass; explain industry’s minimal water use; contradict the false claim that bottled water is a major source of ocean pollution; and promote bottled water’s role during times of emergency when tap water is compromised. We are continuing to evaluate the situation and working to get the EO withdrawn or modified. National Parks. On the federal level, the National Park Service (NPS) has reintroduced efforts to phaseout single-use plastics, in accordance with an Order by U.S. Department of the Interior (DOI). IBWA has had
comments making it clear that efforts by the state—which
numerous discussions with DOI and NPS staff and
include passage of AB 793 (legislation that requires
presented scientific research showing the fact that
recycled content for plastic beverage containers)
plastic packaging impacts the environment less than
and SB 54 [legislation that includes a comprehensive
other packaging types. Currently, NPS does not want
Extended Producer Responsibility (EPR) program
an outright ban on the sale of bottled water in plastic
for single-use plastics and packaging]—are already
packaging. Instead, NPS is offering DOI a plan that
making great strides in addressing the state’s
would focus first on gathering more data to better
concerns on plastic reduction. IBWA advised it would
understand the waste and litter problems occurring
seem premature for the City of Los Angeles to move
within NPS. In addition, the proposed plan would focus
forward with its Comprehensive Plastic Reduction
on more problematic single-use plastics (e.g., utensils,
Program without first allowing time for the impact
clamshell packaging) or plastics that are not as
of the current state regulations on plastic waste to
recyclable as plastic bottles.
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ENVIRONMENT
In time, a requirement may be made for companies providing bottled water in plastic bottles to “pay to play,” in order to help cover the costs of capturing and recycling post-consumer plastic bottle waste in the parks (similar to an EPR policy). DOI may choose to implement all, some, or none of the NPS plan offered to them earlier this year. Either way, IBWA will continue to engage with NPS, DOI, and Congress to put pressure on the Administration to reverse or otherwise pair back any sales ban proposal.
Extended Producer Responsibility While many states introduced and addressed EPR bills in 2023, none were enacted. Washington State legislators made a strong effort to get an EPR bill approved, and IBWA was heavily involved during negotiations before the vote. Ultimately, the bill did not have the necessary votes to move forward. We expect the issue to be back in 2024, and IBWA is already working with allies to prepare for the next version of the legislation.
IBWA’s position on bottle deposit systems is that they need to be performance-based with achievable targets, industry-led, focused on material collection, affordable, and convenient for consumers. Colorado’s new statewide recycling program, which was
Many states that introduced EPR legislation in 2023
created under the state’s new EPR Law. CAA is also the
ended up with watered down versions of final bills.
leading candidate to be California’s PRO, with the state
Legislators in Connecticut, Illinois, Maryland, and
scheduled to make a decision early in 2024.
New Hampshire passed bills that began as full EPR proposals but ended up either as a needs assessment, study groups, or other recycling proposals. In Con-
IBWA continues to monitor, participate in meetings and workshops, provide comments, and work with allies in
necticut, a final bill addressed different recycling and
these states on various components of EPR regulations.
waste management needs but also included a recycled
Bottle Deposit Bills
content mandate for plastic beverage containers. For the four states that have previously approved EPR
Modern, high-performing deposit return systems can offer beverage producers a collection method that improves
laws—California, Colorado, Oregon, and Maine—the
material quality, market value, and reduces processing loss,
focus has been on regulatory work. In May, Colorado
all of which lead to higher yields, and offers consumers
became the first to officially recognize a group as the
a convenient method for redemption. IBWA’s position is
program’s producer responsibility organization (PRO).
that deposit systems need to be performance-based with
The name of the new PRO is Circular Action Alliance
achievable targets, industry-led, focused on material
(CAA), which is a group made up of major manu-
collection, affordable, and convenient for consumers. In
facturers from the packaging industry. Some of the
2023, a dozen states considered legislation on beverage
major brands that are part of CAA include Unilever,
deposit programs, half with existing programs and half
General Mills, Nestlé, P&G, Coca-Cola, Pepsico, and
looking to implement new programs. Deposit programs
IBWA member Niagara. It is charged with implementing
are touted as a viable option when support for broader EPR 2023 IBWA PROGRESS REPORT | 7
PET recycling rates continue to hold steady, with the U.S. rate currently at 29%. Yet, there is a growing demand for postconsumer recycled content. IBWA produces social media campaigns that educate consumers on how to “recycle right” and provides policymakers with the science that shows, of all beverage packaging materials, the plastic bottle has the least impact on the environment.
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ENVIRONMENT
systems has been difficult to obtain. In states with
plastic containers have the smallest environmental
existing programs, we have seen work on increasing
impact of all beverages, using less water, emitting
fees, expansion, and studies.
fewer GHGs, and generating less waste.
Vermont. The most significant bottle bill develop-
Bottled water critics commonly use “waste” issues
ment was in Vermont where proponents have worked
against the industry; however, our mission is to be
for years to expand the state’s deposit program. After
part of the solution. In 2023, IBWA supported two
passage of a bill during a brief return to session by
bills in Congress that would improve the recycling
the legislature to address vetoed bills, lawmakers ap-
infrastructure in the United States: the Recycling and
proved a bill to expand the program to include bottled
Composting Accountability Act and the Recycling
water and other products. However, the governor
Infrastructure and Accessibility Act. An essential ele-
vetoed the bill. Lawmakers will have to wait until
ment of those bills is the collection of key data to gain
2024 to reconsider.
a better understanding of U.S. recycling capabilities
New York. On October 23, New York’s Senate and Assembly Standing Committees on Environmental Conservation held a public hearing to examine legislative solutions to update and increase the effectiveness of the state’s bottle deposit bill. IBWA submitted comments based upon the Association’s updated principles regarding bottle deposit recommendations, described above. Actions in response to the hearing have yet to be determined, but a legislative effort to increase the redemption fee from 5 cents to 10 cents is likely, along with possible expansion of the existing program to cover new products. Days after the hearing, the New York Department of Environmental Conservation announced “a statewide multi-agency effort to help prevent returnable container schemes that defraud the state of millions of dollars each year.” For several years, IBWA has supported legislation that would examine the occurrence of fraud in New York’s current deposit system and determine how best to
and improve access to recycling programs for disadvantaged communities. Although both bills passed the Senate, they have languished in the House. If any movement happens at all, it will occur in 2024. IBWA continues to work with members of Congress to seek passage of this legislation in the House.
Green Guides The U.S. Federal Trade Commission (FTC) is updating its Green Guides, a document designed to help marketers avoid making environmental claims that mislead consumers. IBWA has been engaged in the revision process, submitting two rounds of comments to the FTC. On April 24, IBWA submitted comments in support of changes that would help improve the utility of the Green Guides for marketers and the bottled water industry. Those changes include allowing the terms “re-
address improvements in the state’s program.
fillable” and “reusable” to be used interchangeably;
Recycling
packaging, including HDPE and PET plastic, meet the
declaring that certain highly accepted and recycled
IBWA actively engages and educates members of
current standard for recyclable (meaning if recycling
Congress and their staff about the environmental ben-
facilities are available to at least 60% of consumers
efits of bottled water packaged in plastic containers
where the product/packaging is sold, then the product/
compared to other packaging types. Through this di-
packaging is considered “recyclable”); considering
alogue, we push back on the false claims that bottled
both caps and labels as minor, incidental components;
water in plastic packaging is bad for the environment.
and allowing the mass balance calculation method to
Research shows that bottled water products in PET
support recycled content use claims. 2023 IBWA PROGRESS REPORT | 9
IBWA provided additional comments to the FTC on June 13. Continuing to support our April recommendations, we reiterated our suggestion that FTC, in coordination with the U.S. Environmental Protection Agency (EPA), provide more certainty on which materials meet the current standard for “recyclable” claims. We noted that “for those materials where the standard is easily met and has been for many years (including [PET] and [HDPE] water bottles), industry and consumers alike would benefit from the additional certainty of a clear declaratory statement from the FTC.” IBWA expects a revision of the Green Guides to be published in 2024.
Ongoing Research Water, Energy, and Emission Use Benchmarking Study. Water conservation/efficiency and energy and emission efficiencies are areas of concern for retailers and bottlers. IBWA is currently working with the Antea Group to conduct a 2023 Water and Energy Use Benchmarking Study, an update to the Association’s 2018 benchmarking study. The update was proposed
as a point of comparison with the 2022 BIER Global Benchmarking Study. For the first time, facility emissions will be included in the 2023 study. The next steps are to finalize data collection and publish a final report in 2024. Bottled Water Secondary Packaging Study. Data on the availability and recyclability of secondary and tertiary packaging for bottled water will become more important in discussions on EPR legislation. IBWA is moving forward with a study on the availability and recyclability of secondary packaging for bottled water, with RRS conducting the study. The study currently is in the data collection stage with a final report expected in 2024. Bottled Water Tertiary Packaging Study. IBWA has contacted Trayak and is awaiting a proposal to determine the amount of tertiary packaging used by the bottled water industry and the amount of tertiary packaging recycled. IBWA’s Environmental Sustainability Committee will review Trayak’s proposal before proceeding with the study.
IBWA continues to look for new ways to promote healthy hydration habits. These images are stills from an influencer video we produced and posted on IBWA’s TikTok account that educates consumers about the benefits of drinking bottled water. Check it out for yourself at www.tiktok.com/@bottledwatermatters.
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HEALTHY HYDRATION
Label Regulations While bottled water is the healthiest packaged bev-
use “healthy” on product labels. Fifteen members of Congress signed on to the letter, which included the
erage product, surprisingly, current FDA regulations
following text:
don’t allow bottled water to be labeled as “healthy.”
Based on the consensus in dietary guidance and the public
For the past several years, IBWA has been working
health community that water is a vital part of a healthy diet,
on changing that by submitting written and oral
we believe it is appropriate for the agency to permit “healthy”
comments to FDA and meeting with agency officials
claims on bottled water…The Dietary Guidelines 2020-2025
to urge them to revise the regulations so our product
consistently recommend consumption of water as a part of a
labels can use the word “healthy.”
healthy diet, as do other government agencies, including the
IBWA has also worked with Congress to gain support
Disease Control and Prevention (CDC). The guidelines state
U.S. Department of Agriculture (USDA) and the Centers for
on this issue. In 2018, a bipartisan congressional let-
that water, among other beverages that contribute beneficial
ter was sent to FDA requesting that the term “healthy”
nutrients, should be the primary beverages consumed…As
be allowed on bottled water containers. We were,
such, we encourage the FDA to move forward with provisions
therefore, happy to learn FDA issued a proposed rule
in the proposed rule to allow for the use of the term “healthy”
on September 28, 2022, that would allow bottled water
on the labels of bottled water.
products to be labeled as “healthy.” FDA asked for
The next step is for FDA to publish the final rule.
comments on the proposed rule, including whether allowing bottled water to be labeled as “healthy”
Dietary Guidance Statements
could potentially lead some consumers to believe that
To provide industry with recommendations on how
it is healthier than tap water.
and when to use Dietary Guidance Statements on the
IBWA commented the proposed rule would not cause consumers to believe that bottled water is healthier than tap water and would remind consumers that drinking “plain water” is “healthy” for them, regardless of whether it is tap, filtered tap, or bottled water. We requested that FDA exercise enforcement discre-
label of food products to ensure the label statements promote good nutrition, provide greater consistency in labeling, and assist consumers in making informed choices, FDA issued the following draft guidance document: “Questions and Answers About Dietary Guidance Statements in Food Labeling: Guidance for Industry.”
tion from the nutrition labeling requirements for bot-
IBWA staff worked with our counsel, Hogan Lovells,
tled water that bears a healthy claim but is otherwise
on draft comments regarding Dietary Guidance
exempt from nutrition labeling because it contains
Statements for use on bottled water labeling. After
insignificant amounts of the mandatory nutrients. We
those comments were reviewed by IBWA’s Healthy
also requested that the proposed “healthy” allowance
Hydration Task Force and interested members for
for plain water and plain carbonated water be ex-
additional input, they were submitted to FDA on
tended to waters with added minerals or electrolytes
September 25, 2023.
added for taste, as those are recommended beverages under dietary guidance.
This FDA guidance document is part of the agency’s overall nutrition initiatives, which include empower-
In addition, IBWA spearheaded a bipartisan con-
ing consumers by providing more informative label-
gressional letter sent to FDA on May 15, led by
ing and education, including tailored messages for
Representatives Tim Walberg (R-MI) and David Scott
various audiences to help consumers identify foods
(D-GA), requesting that bottled water be allowed to
that can contribute to healthier diets. 2023 IBWA PROGRESS REPORT | 11
*IBWA’s Proposed MyPlate Revision
Senator Roger Marshall (center) met with IBWA members and staff to discuss adding water to the MyPlate nutrition graphic.
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HEALTHY HYDRATION
MyPlate Nutrition Guide The process of updating the Dietary Guidelines for Americans (DGAs) for the 2025-2030 edition is underway, and IBWA continues our work to have water
At least 48 countries include water in their healthy eating nutrition guides. The United States does not—but IBWA is working to fix that by having water, in addition to dairy, added to MyPlate.
added to MyPlate, the nutrition guide published by the U.S. Department of Agriculture’s Center for Nutrition Policy and Promotion. Our efforts include submitting recommendations to the Dietary Guidelines Advisory Committee and holding briefings and events on Capitol Hill in support of adding water to MyPlate. At least 48 other countries include water in their nutrition guidance documents. The United States needs to catch up with the rest of the world on this important issue. When the current edition of the DGAs was issued in 2020, we were pleased that several of IBWA’s recommendations were included. Notably, the current guidelines state that calorie-free drinks—especially
how important it is for older adults to drink plenty of
water—should be the primary beverages consumed.
water. IBWA’s goal is to ensure the continued recogni-
The guidelines also encourage a shift to healthier,
tion of the important role water plays in a healthy diet
no-sugar added beverages, such as water, in place of
and to have water included on the MyPlate nutrition
sugar-sweetened beverages. The 2020 DGAs stress
guidance, in addition to dairy.
For IBWA’s “Summer of Influence” communications campaign, we collaborated with two social media influencers to expand the reach of our healthy hydration messaging. By partnering with influencers and working with them to produce content, IBWA capitalized on one of the latest trends in social media—reels—and it proved to be an effective strategy for amplifying our message, building trust with consumers, and engaging with new audiences. Visit IBWA’s Bottled Water Matters Instagram page to view the reels: www.instagram.com/bottledwatermatters.
2023 IBWA PROGRESS REPORT | 13
SCIENCE AND TECHNOLOGY
PFAS In 2023, nearly 300 pieces of legislation and 200 regulations were introduced that potentially could impact the bottled water industry. One of the more prolific issues to be addressed in the states was perand polyfluoroalkyl substances (PFAS). Most of the dozen or so bills focused on PFAS were introduced in the northeastern United States. The passage of legislation in Maine is the most noteworthy because it will require bottled water to comply with the PFAS standards the state sets for community water systems. The state has yet to set those levels, and there are still questions to be answered in the regulatory process. But bottlers with
established the following SOQs for PFAS in bottled water: • 5 parts per trillion (ppt) for a detection of one PFAS compound • 10 ppt for detection of two or more PFAS compounds IBWA established a PFAS subcommittee under the auspices of the Technical Committee. The subcommittee has created a PFAS regulatory matrix of state and federal regulations for bottled water and drinking water, which is available on the IBWA website for members. The subcommittee will continue to discuss the evolving federal and state PFAS requirements and how best to incorporate them into the IBWA Bottled
products in Maine should be prepared to report to
Water Code of Practice.
the state on PFAS levels.
Antimony
Currently, there aren’t any federal PFAS standards
IBWA continues to monitor developments surrounding
for food or water products, including public drinking
antimony (trivalent compounds), particularly in
water and bottled water. EPA has an advisory limit for
California, as the state often sets a precedent for
tap water and, in March, published a proposed Na-
what will happen in other states across the country.
tional Primary Drinking Water Regulation (NPDWR)
In October of 2022, the California Environmental
setting maximum contaminant levels (MCLs) for six
Protection Agency’s Office of Environmental Health
PFAS in drinking water.
Hazard Assessment (OEHHA) issued a notice that it
In the absence of any federal regulations, and with pressure from the public and media, many states are adopting their own standards. Some of those regulations apply to bottled water. However, they are all
intended to list antimony (trivalent compounds) as known to the state to cause cancer under the Safe Drinking Water and Toxic Enforcement Act of 1986 (i.e., Proposition 65).
different. For a public water system operating in one
That action was proposed pursuant to the Labor Code
state, the impact of non-uniform PFAS standards is
listing mechanism that is incorporated into Prop 65.
minimal. However, for companies that make and
The Labor Code requires certain substances iden-
sell bottled water in multiple states, those new state
tified by the International Agency for Research on
requirements are burdensome and expensive. When
Cancer (IARC) to be listed as known to cause cancer
FDA issues a PFAS regulation, it will preempt state
under Prop 65.
requirements. Unfortunately, FDA will wait for EPA to finalize tap water MCLs for PFAS compounds before acting on bottled water standards of quality (SOQs).
IBWA worked with American Beverage Association, our state counsel, and a scientific consultant to provide input to a coalition of the California Chamber
In order to help ensure consumer safety, and to
of Commerce, Consumer Brands Association, and
provide the highest quality products, IBWA has
American Chemistry Council, who jointly submitted
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PFAS REGULATIONS AROUND THE WORLD US FDA: No PFAS monitoring required. US EPA: Proposed Maximum Contaminant Level: PFOA, PFOS 4 parts per trillion (ppt); Hazard Index of 1.0 is proposed for assessing the impact of PFNA, PFHxS, PFBS, and HFPO-DA. EU: Sum of 20 PFAS at 100 ppt; proposed 100 ppt for individual and 500 ppt for sum. Canada: 600 ppt PFOS, 200 ppt PFOA; proposed 30 ppt sum. China: PFOS and PFOA standards in drinking water are 40 and 80 ppt, respectively.
IBWA has a standard of quality (SOQ) for bottled water of 5 ppt for detection of a single PFAS compound and 10 ppt for two or more compounds; members test using EPA Method 537.1.
2023 IBWA PROGRESS REPORT | 15
comments to OEHHA on this issue. The coalition
Currently, there is no scientific agreement on what
requested that OEHHA delay determining if antimony
amount of microplastics presents a human health
(trivalent compounds) should be included under Prop
risk. The World Health Organization (WHO) published
65 until after the release of IARC’s Monographs on the Identification of Carcinogenic Hazards to Humans, entitled “Cobalt, Antimony Compounds, and Weapons-Grade Tungsten Alloy.” That document was released on May 5, 2023.
a report, after reviewing the available studies concerning water, food, and beverages, and concluded that no adverse health effects could be drawn from dietary exposure to nano and microplastic particles less than 10 microns due to minimal scientific research.
After reviewing the 2023 Monograph, OEHHA has
WHO’s recommendation is for more research to be
determined that antimony (trivalent compounds)
conducted, as well as establishing standardized meth-
does not meet the criteria for being listed as causing
ods for measuring and quantifying microplastics.
cancer via California’s Labor Code mechanism.
Microplastics
As you might expect, California is also looking at this issue. The state has established testing methods, yet
Microplastics continue to get a lot of attention from
monitoring for microplastics in tap water sources has
the media and government officials. When respond-
been delayed until 2024. For the moment, no Public
ing to media or other questions about this issue, IBWA points out that research continues to be produced on this topic and that bottled water is just one of thousands of other food and beverage prod-
Health Goal or regulatory level will be set due to a lack of scientific evidence on the health impact of microplastics on humans.
ucts that uses plastic containers. Perhaps even more
IBWA continues to follow this matter closely because
important is the fact that microplastic particles are
whatever standards are adopted for tap water in Califor-
found everywhere—including the soil, air, and water.
nia will likely be applied to bottled water at a later date.
IBWA developed www.HydrateTheStates.org as an online resource to offer reliable, fact-based information about water scarcity issues, bottled water, and the importance of healthy hydration. It also highlights the vital role bottled water plays in the lead up to and recovery from disasters and other emergencies.
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COMMUNICATIONS AND EDUCATION
Legislators, Media, and Consumers IBWA communications play a crucial role in the Association’s efforts to educate legislators, media, and consumers, particularly in today’s digital age. With the rapid evolution of communication platforms and the changing expectations of stakeholders, the value of strong and strategic messaging is more important than ever before. IBWA’s communications not only convey the Association’s mission and goals—but also the fact that bottled water is: • the No. 1 packaged beverage choice in the United States • strictly regulated by FDA • healthy hydration packaged in containers that have the smallest environmental footprint of all beverage packaging materials • a life-saving necessity during disaster relief efforts. By expanding our digital media efforts, IBWA reaches a much larger audience. We have significantly more influence by conveying our messaging through the more engaging, more interactive mediums of websites and social media. We strive to produce compelling content that empowers people to make informed, healthy hydration—and healthy planet—decisions and take meaningful action. Throughout the year, IBWA has crafted compelling content that shares bottled water facts with our target audiences on social media. The end result of producing these social media projects is that in 2023 IBWA reached nearly 2 million people with our probottled water messaging. IBWA considers correcting false claims made against the bottled water industry in the media a very important responsibility. We use tried-and-true methods like letters to the editor to correct and educate many print and online editors when they publish false or misleading information about bottled water. We work not only to get corrections printed but also to educate decision-making editorial staff—so they
can spot inaccurate stories and either not run those articles or, at a minimum, reach out to IBWA for industry’s perspective. For 2023, here’s just a sampling of issues we spent time correcting the media about: PFAS, expiration dates, bottled water’s environmental footprint, ocean plastics, food safety, and water use—the list goes on. Central to all of IBWA’s traditional communications efforts are actions that promote positive bottled water stories. We do this through press releases, articles submitted to trade journals, opinion pieces, IBWA’s websites, and our award-winning print and digital quarterly magazine: Bottled Water Reporter. IBWA will continue to vigorously defend and promote the industry by sharing bottled water facts and finding new and innovative ways to communicate bottled water’s incredible story.
Hydrate The States As issues surrounding water scarcity and water rights intensified, IBWA developed its Hydrate The States website (www.HydrateTheStates.org). Launched in 2021, IBWA ran a robust campaign in 2022, promoting the industry’s small water use and environmental footprint. While our 2023 media monitoring continued to show very little mention of bottled water in relation to drought concerns, a few news articles reported that bottled water is needed to provide life-saving water. Yet, we anticipate our critics will again push the bottled water industry into the center of any water scarcity media coverage, especially if drought conditions worsen. If that occurs, IBWA will be ready—and we will again aggressively promote the story of industry’s minimal water use through social media and traditional advertising options, media plant tours, and working with other pro-bottled water organizations to oppose any groups that unfairly criticize bottled water.
2023 IBWA PROGRESS REPORT | 17
IBWA offers members a variety of ways to keep current on hot industry topics. Whether attending education sessions at our annual conference and trade show, reading Bottled Water Reporter articles, or participating in virtual or in-person plant tours, IBWA members have access to industry experts who can help them grow their businesses.
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COMMUNICATIONS AND EDUCATION
CPO Program Developments In 2023, IBWA made three significant updates to our certified plant operator (CPO) and education programs. First, the revised IBWA Plant Technical Reference Manual (PTRM) was released in January. The new manual consists of two volumes and contains the following improvements: information on IBWA’s CPO program; updates to key regulatory issues, including FDA’s Food Safety Modernization Act (FSMA) requirements; and an enhanced chapter on plant and facility security programs. Members who take the revised CPO exam now have two options for taking the exam: three separate one-hour modules or as a single exam. IBWA’s online training platform includes webinars on the 2023 PTRM to help prospective CPOs study for the exam. Second, IBWA moved from in-house proctoring of the online CPO exam to a third-party proctoring service: Proctor U. Third-party proctoring allows CPO exams
Members have two options for taking IBWA’s CPO exam: three separate, one-hour modules or as a single exam. IBWA’s online education platform includes webinars to help prospective CPOs study for the exam.
to be scheduled at any time 72 hours after registering for the exam. Third, we continue to enhance our online education platform. Members can earn CEUs remotely, and several new recorded webinars and other programs have been uploaded to IBWA’s website. Members can access IBWA’s archive of webinars by logging on to
Rule, and IBWA also provides guidance via Splash enewsletter articles; Bottled Water Reporter magazine articles; and timely, topic-specific members-only bulletins. The PTRM, combined with the audit check sheets, are the best tools available to help companies prepare for an FDA inspection.
www.bottledwater.org.
Environmental Sustainability Plant Tour
Inspection Program
On August 10, IBWA members participated in a virtual
The IBWA annual plant inspection program returned to on-site audits in 2023, and we also reverted back to the two-business day advance notice of those audits. IBWA awarded new 2023-2025 audit company contracts to EAGLE Certifications Group, Eurofins Food Assurance, and NSF International.
tour of the Orange County Water District (OCWD) Ground Water Replenishment System (GWRS), which focused on the plant’s purification process. The GWRS is the world’s largest purification system for indirect potable reuse. Attendees learned about the groundwater basin; viewed the control room, where operators can monitor what is occurring within the plant
IBWA continues to provide implementation and
24 hours a day, 365 days a year; viewed each of the
compliance guidance to our members on FSMA. The
facility’s purification locations, which includes micro-
2023 PTRM includes a detailed guidance document
filtration, reverse osmosis, and ultraviolet light; and
on the requirements of the FSMA Preventive Controls
concluded the tour stopping in front of two sample 2023 IBWA PROGRESS REPORT | 19
sinks to showcase the difference between the incom-
Chicago, November 4-7, for the 2024 conference, which
ing brine water and the end product of purified water.
will also be in conjunction with PACK EXPO.
IBWA members can watch a recording of the tour on the members’ only side of www.bottledwater.org.
Annual Business Conference and Trade Show
More to Do IBWA accomplished a great deal in 2023, and there’s much to be proud of. However, there is still plenty more for us to do. Our status as America’s favorite
The 2023 IBWA Annual Business Conference and
packaged drink is a testament to the great-tasting,
Trade Show, held September 11-14 in Las Vegas in
safe, healthy, and convenient products that we make—
conjunction with PACK EXPO, was very productive,
and that consumers enjoy and depend on. While we
bringing together 300+ attendees, 20 educational
can expect new challenges in the years ahead, there
speakers, and 33 trade show exhibitors for an event
will also be numerous opportunities to share the good
that was a resounding success. The festivities kicked
news about bottled water.
off with a Welcome Reception, offering attendees an excellent opportunity to network and catch up with their peers. Industry experts and thought leaders lead the stellar educational program, providing fresh perspectives on hot industry topics, including PFAS, market trends, fleet management, water rights, and
We will continue to promote the benefits of bottled water and push back against the false claims that our critics make about our products. IBWA will continue to educate people about how they can improve their lives with one simple act: drinking more water.
more. Many productive conversations were held during
We will also continue to fight hard every day to defend
the well-attended trade show, which gave IBWA’s
our member companies. We are confident that our
supplier members a chance to showcase their latest
talented team of members, consultants, and staff will
products and services. IBWA looks forward to building
help ensure the continued success and growth of your
upon the success of this event when we gather in
companies, the bottled water industry, and IBWA.
2024 IBWA MEETING DATES FEBRUARY 27-29 IBWA Virtual Winter Board of Directors and Committee Meetings JUNE 3-6 IBWA Summer Board of Directors and Committee Meetings and Capitol Hill Visits Hilton Old Town Alexandria, Virginia
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NOVEMBER 4-7 IBWA Annual Business Conference and Trade Show Chicago (in conjunction with PACK EXPO)
OUR VISION The International Bottled Water Association will be the leading voice for healthy hydration and the bottled water industry.
OUR MISSION To serve our members and the public by championing bottled water and other healthy hydration choices, while promoting an environmentally responsible and sustainable industry.
THE INTERNATIONAL BOTTLED WATER ASSOCIATION (IBWA) is the authoritative source of information about all types of bottled waters, including spring, mineral, purified, artesian, and sparkling. Founded in 1958, IBWA’s membership includes U.S. and international bottlers, distributors, and suppliers. IBWA is committed to working with the U.S. Food and Drug Administration (FDA), which regulates bottled water as a packaged food product, to establish comprehensive and stringent standards for safe, high-quality bottled water. In addition to FDA regulations, IBWA 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 IBWA Bottled Water Code of Practice is a mandatory annual plant inspection by an independent, third-party organization. WWW.BOTTLEDWATER.ORG