MYTH The bottled water industry takes water from other parts of the world who need it.
issue of tying the availability of bottled water to the access of safe drinking water
in other parts of the world has become a communications tool for some anti-bottled water
groups seeking to completely eliminate bottled water in any form as a consumer choice.
And, while the issue of providing access to safe drinking water to all people is of vital
importance, the argument presented is a false one.
About 98.5% of all bottled water sold in the United States is sourced domestically.
The existence of a bottled water industry in the United States has no impact on the
availability of drinking water in, or the public service infrastructure of, any other country.
MYTH Bottled water costs 1,000 times
more than tap water.
According to the Beverage Marketing Corporation (BMC), the average wholesale price
per gallon of domestic non-sparkling bottled water was $1.13 in 2010. As a popular retail
food product, bottled water is available at many differing price points. Also, according to
BMC, consumers most often tend to buy bottled water in bulk from supermarkets or large
Bottled water critics tend to cite prices from the most expensive retail outlets they
can find - which, accroding to BMC's research are often the least utilized by the average
consumer - and use them as the basis for such dramatic claims.
MYTH It takes 17 million barrels of
oil a year to make bottled water bottles
This is an interesting non-verifiable statement typically attributed to researchers
at the University of Louisville. Except, according to the school, they have never even
heard about it. Our source is University's Director of Media Relations Mark Hebert, who
had this to say:
“We don’t have anyone who ever wrote about ‘17 million barrels of oil used to make PET
water bottles.’ We have no idea where the ‘University of Louisville researchers’ has come
from. We’ve asked all our environmental guys, our researchers in the engineering school
and nobody has touched that one. The only thing, the closest that we can come, is there
was a student last who was trying to get folks on campus to quit using bottled water, but
she didn’t have anything like that in her literature that even came close to that statement.
So we don’t have clue where it came from, and if you find out, please let us know.”
MYTH FDA standards allow
‘contaminants’ in bottled water not allowed in tap water.
The FDA has also established bottled water Standards of Quality
for more than 90 substances [21 C.F.R. § 165.110 (b)]. Most FDA bottled
water quality standards are the same as the EPA’s maximum contaminant
levels (MCL) for tap water systems. The few differences are usually the
result of the substance not being found in bottled water or the substance
is regulated under another provision of law such as FDA’s food additives
Additionally, Section 410 of FFDCA requires the FDA to review all EPA
National Primary Drinking Water Standards (NPDWS) for public water systems
to determine their applicability to bottled water. If the FDA determines that
the NPDWS is applicable to bottled water, it must establish standards of
quality for bottled water that are as stringent and protective of public
health as the EPA's standards for public drinking water. If the FDA fails
to act within 180 days of the effective date of any new EPA NPDWS for public
water systems, the FDA must then apply the new NPDWS to bottled water. This
section of the FFDCA is commonly known as the "hammer provision."
MYTH FDA has no authority over bottled water made and sold within a single
FDA's jurisdiction over bottled water products (and any other product
regulated by FDA) extends not only to those products that move in interstate
commerce but also to those products sold within a single state that are enclosed
in packaging materials that have moved in interstate commerce.
Known as the component theory of FDA jurisdiction, courts have long held that
if any component of a food product moves in interstate commerce, FDA has
jurisdiction over the finished product, regardless of whether the finished
product itself moves in interstate commerce [e.g., United States v. An Article
of Food, 752 F.2d 11 (1st Cir. 1985)].
In the case of bottled water, if the plastic used in the bottles, the plastic
used in the caps, the paper and ink used on the labels, any other outer packaging
materials, and even the water itself comes from out of state, then FDA has jurisdiction
over that product. And in today's commercial society, that will almost always be the
case. Congress has recognized this fact by enacting a law that expressly presumes that
all food and beverage products are sold in interstate commerce. (21 U.S.C. § 379 (a)).
MYTH Only one staffer at the
FDA oversees regulation of the entire bottled water industry.
The FDA management of the bottled water program is based out of the
FDA/Center for Food Safety and Applied Nutrition (CFSAN), located in College Park,
Maryland. In addition to staff directly responsible for oversight of bottled water,
CFSAN has over 800 employees, including highly specialized professionals such as
chemists, microbiologists, toxicologists, food technologists, molecular biologists,
pharmacologists, nutritionists, and physicians. While these individuals and their
staffs oversee regulatory enactment and enforcement of the bottled water industry,
the significant work is done by both FDA regional offices in the United States and
the states themselves. Inspections and enforcement all happen in these locations,
not in College Park. All 50 states have delegation agreements with FDA, meaning
that when they inspect a bottled water plant (or ANY food processing facility)
they act with the full authority of the FDA.
MYTH Bottled water isn’t as regulated
as tap water.
By federal law, the FDA regulations governing the safety and quality
of bottled water must be as stringent as the EPA regulations which govern
tap water. To suggest in any way that bottled water is less stringently
regulated than tap water is simply not true.
Bottled water companies produce a safe, healthy, and convenient packaged
food product that is comprehensively and stringently regulated by the FDA
under the Federal Food, Drug, and Cosmetic Act (FFDCA), 21 U.S.C. §§ 301 et
seq., and applicable sections of Title 21 of the Code of Federal Regulations (CFR).
Bottled water must meet the FDA’s general food regulations, as well as
standards of identity, standards of quality, good manufacturing practices
and labeling requirements specifically promulgated for bottled water. The
FDA has issued comprehensive bottled water Standards of Identity, which
provide uniform requirements and definitions for the following bottled
water classifications: bottled, drinking, artesian, groundwater, distilled,
deionized, reverse osmosis, mineral, purified, sparkling, spring, sterile,
and well water [21 C.F.R. § 165.110 (a)].
MYTH Bottled water companies are
draining water supplies.
According to a 2005 study by the Drinking Water Research Foundation
(DWRF), annual bottled water production accounts for less than 2/100 of
one percent (0.02%) of the total groundwater withdrawn in the United
States each year. Additionally, based on information gathered in the
DWRF study, in 2001, 87% of the water withdrawn by bottled water
companies, on average, was actually bottled for consumption by humans,
so the bottling process is a very efficient one.
At 55 billion gallons per day, the largest user of groundwater is the
agriculture industry. That amount equals 68% of total groundwater extracted
in 2010. The second largest user of groundwater is public drinking supplies,
which takes 16 billion gallons per day, or 19% of all U.S. groundwater extraction.
Compared to those figures, bottled water barely registers on the radar.
MYTH: Bottled water bottles are not
Bottled water containers, as with all food packaging materials,
must be made from FDA-approved food contact substances.
So, the plastic and glass containers that are used for bottled water
products (which are made from the same materials used in other food
product containers) have undergone FDA scrutiny prior to being available
for use in the market place. The FDA has determined that the containers
used by the bottled water industry are safe for use with food and
beverage products, including bottled water, and that they do not
pose a health risk to consumers.
Sometimes, the claim is made that individual retail-sized bottled
water bottles contain Bisphenol A (BPA). This is not true; PET plastic,
from which these bottles are made, does not contain BPA.
MYTH: Most bottled water is just tap
water in a bottle.
It is important to note that purified bottled water is not just
tap water in a bottle. Once the municipal source water enters the bottled
water plant several processes are employed to ensure that it meets the
purified or sterile standard of the U.S. Pharmacopeia 23rd Revision. These
treatments can include ozonation, reverse osmosis, distillation, or
de-ionization. The finished water product is then placed in a bottle
under sanitary conditions and sold to the consumer.
Some anti-bottled water activists imply that people may be unaware that
they are consuming bottled water that is from a municipal water source
and has been placed in a bottle without being purified. As stated above,
this is not the case. If a bottled water product’s source is a public water
system and the finished bottled water product does not meet the FDA Standard
of Identity for purified or sterile water, the product label must disclose
the public water system source.