Bottled Water Position

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CIWEM’s Position on Bottled Drinking Water 1. Sustainability: branding and bottling of water where there already exists a wholesome and safe supply of mains drinking water cannot be seen as a sustainable use of natural resources, and adds to the overall levels of waste and pollution to be managed in modern society. 2. Health: there is no general health advantage in replacing tap water with bottled water, and people should be protected from false claims in this regard. 3. Quality: as a minimum, b
  CIWEM’s Position on Bottled Drinking Water 1. Sustainability: branding and bottling of water where there already exists a wholesome andsafe supply of mains drinking water cannot be seen as a sustainable use of naturalresources, and adds to the overall levels of waste and pollution to be managed in modernsociety.2. Health: there is no general health advantage in replacing tap water with bottled water, andpeople should be protected from false claims in this regard.3. Quality: as a minimum, bottled waters should meet the requirements of the appropriateCodex Standard 1 of the Food and Agriculture Organization of the United Nations WorldHealth Organization.4. Labelling: the labels on bottles in which any treated or untreated water offered for sale tothe public should include a chemical and bacteriological analysis of the water and the datesof bottling and analysis. An EU-defined standard for the labelling of bottled waters would behelpful.5. Infant nutrition: except where it can be demonstrated that a bottled water is suitable for thepurpose, it should be made clear to health officials and parents preparing infant formula or follow-on formula milk that tap water rather than bottled water should be used in itspreparation 2 . Bottles of water which have not demonstrated suitability should be requiredto carry a warning to this effect.6. Emergencies: drinking water suppliers should have available to them sufficient bottledwater or other means of providing their customers who are likely to be left without mainswater in an emergency with 7 litres per person per day of water3.7. Energy: use of energy should be minimised in the production, packaging, transportationand sale of bottled water, and in the transport of packaging for disposal.8. Disposal/refilling/recycling of empty water bottles: should be undertaken at the least costto the environment. The responsibility for this should lie with the bottled water producer.ContextBottled drinking water is now a multi-billion pound international industry. In the UK alone themarket grew from several hundred litres a year to two billion between 1993 and 2003.Potable water from the tap is subjected to stringent quality controls, and the public is able toeasily access information about its bacteriological and chemical content, for example via theDrinking Water Inspectorate website ( ). Its price is subject to rigorouscontrol and is, on average, 500 times lower than that of bottled waters.Bottled water is being consumed in huge amounts by the public, yet its labelling is notrequired to reflect its chemical and bacteriological content and, while some companieschoose to disclose this information, others do not and it is not mandatory that they shouldmake such information publicly available. While the 2003 EU Regulations10 now set qualitystandards for all bottled water, there are still no labelling requirements to enable people to judge for themselves from a standardised set of information whether the beverage is suitablefor their nutritional needs, nor how it compares in various respects to similar products and totap water.Bottled water marketing has driven a public perception of bottled waters as purer or healthier than water from the tap. Such perceptions are unfounded and can lead to undesirable  consequences: tor example, the high mineral content of some bottled waters makes themunsuitable for feeding babies and young children. This is recognised in the UK in statutoryRegulations11, which set specific standards for waters that wish to be labelled as suitable for use in making up infant formula. However, those waters which have not demonstrated their suitability are not required to display this fact, so parents might use such water to make upinfant formula feed in the mistaken belief that they are doing their best for their offspring.CIWEM considers that water which has not specifically demonstrated its suitability for makingup infant formula feed should be required to carry a warning to this effect.There is a range of environmental costs associated with bottled waters, which relate to theimpacts of abstraction on the local environment, packaging of the product, resource-use andpollution resulting from transportation of the product and disposal of the waste packagingonce the water has been consumed.Discussion:1. Definitions: There are a proliferation of definitions of bottled waters, some of which arecontradictory or vague. CIWEM recommends that the following definitions should be adoptedworldwide in order to avoid confusion.“Natural mineral water” means5 microbiologically wholesome water srcinating in anunderground water table or deposit and emerging from a spring tapped at one or morenatural or bore exits. Natural mineral water can be clearly distinguished from ordinarydrinking water:(a by its nature, which is characterised by its mineral content, trace elements or other constituents and, where appropriate, by certain effects;(b)by its srcinal state,both characteristics having been preserved intact because of the underground srcin of suchwater, which has been protected from all risk of pollution.“Spring water” means6 water that has been extracted from a spring.“Bottled drinking water” means6 water intended for sale for drinking by humans which is notnatural mineral water or spring water. In practice this means that bottled water may simplybe filtered tap water.Bottles can be containers of any size and of any food grade material. These will includeplastic and glass bottles and carboys. Plastic bags are also used for emergency water supply.2. Health benefits: Consumers need to be protected from false claims regarding the effects of tap water vis-à-vis bottled water on their health. Particular regard should be made toimplications that tap water damages human or animal health, and that bottled water ishealthier to drink.CIWEM supports the following WHO position on the health benefits of drinking bottledwater7:“In European and certain other countries, many consumers believe that natural mineralwaters have medicinal properties or offer other health benefits. Such waters are typically of high mineral content and, in some cases, significantly above the concentrations normallyaccepted in drinking water. Such waters have a long tradition of use and are often acceptedon the basis that they are considered foods rather than drinking water per se. Althoughcertain mineral waters may be useful in providing essential micro-nutrients, such as calcium,WHO is unaware of any convincing evidence to support the beneficial effects of consuming  such mineral waters. As a consequence, WHO Guidelines for Drinking Water Quality do notmake recommendations regarding minimum concentrations of essential compounds.“On the other hand, in some countries, bottled waters with very low mineral content, such asdistilled or demineralised waters, may be offered for sale. While a large number of peoplehave traditionally consumed rainwater which is similarly low in minerals without apparentadverse health effects, WHO has no scientific information on the benefits or hazards of regularly consuming these types of bottled waters.”3. Quality: Under European regulations, all bottled water both produced and imported withinthe EU is required to meet certain standards with regard to mineral composition,microbiological content etc10. Where national regulations are not in place to control thequality of bottled water it is appropriate to use for such control International standards of purity, such as those set out in the EU Regulations10 the Codex Standards1 published bythe Food and Agriculture Organization of the United Nations World Health Organization.4. Labelling: In Europe, practices and regulations for the labeling of bottled waters vary fromcountry to country with some requiring an analysis of the contained water to be shown on thelabel and some some not. CIWEM suggests that a uniform, EU-defined, standard would behelpful to customers.When formula or follow-on formula milk is prepared correctly in accordance with theinstructions of the manufacturer CIWEM considers that there should be no bacteriologicaldanger when bottled or tap water is used in their preparation. Where water quality equivalentto that of tap water cannot be guaranteed in bottled water, then using the bottled water tomake up formula or follow on formula milk for feeding to infants or young children isinappropriate. CIWEM also considers that advice should be available to health professionalsand parents that the high mineral contents of some bottled waters should preclude them frombeing used for preparing formula or forward formula milk. They should be aware that thereare certain bottled waters that have applied for a designation to indicate their suitability, andthat where the water has been proven to meet strict standards, this is shown on the label.5. Shelf life: At least one major bottled water trade association contends that bottled water stored correctly will have an indefinite shelf life. While this may or may not be true, CIWEMconsiders that customers need to be informed of the date when the water was bottledespecially since other sources put a viable shelf life for bottled water at one or two years.6. Emergency drinking water supplies: CIWEM considers that the stockpiling of bottled water is necessary, in order for public and private water suppliers to meet the requirement toprovide an adequate emergency supply of water for drinking. How they will provide theseemergency supplies needs to be planned and organised. In many countries water suppliersare required by regulation to do this and many use bottled water for this purpose. Other vehicles such as water bowlers and flexible plastics containers are used for the stockpiling of emergency drinking water and CIWEM considers these to be valid alternatives.7. Environment: The abstraction, processing, packaging, transportation and sale of bottledwater, and disposal of associated waste, involves a significant amount of energy use andpollution. When placed in the context of consumption of safe and wholesome tapwater, it ishard to view this as anything other than unsustainable. Nevertheless, in a free marketeconomy consumers have the right to purchase bottled water and companies to serve thisdemand. CIWEM therefore considers that there is a need to ensure that the environmentalimpacts of bottled water production are minimised and made clear to consumers in labelling. A major contribution to the cost of bottled water is likely to be transport, certainly wheretransport is international. The World Wide Fund for Nature argues that the distribution of   bottled water requires substantially more fuel than delivering tap water4. This is especiallytrue since over 22 million tonnes of the bottled liquid is transferred each year from country tocountry. Instead of relying on a mostly pre-existing infrastructure of underground pipes andplumbing, transporting bottled water burns fossil fuels and results in the release of thousandsof tonnes of harmful emissions. This situation could be ameliorated somewhat if internationalbrands were to licence local supplies to be bottled under their names.Since some bottled water is also shipped or stored cold, electricity is expended for refrigeration. Energy is likewise used in bottled water processing. In filtration, an estimatedtwo gallons of water are wasted for every gallon purified.Most containers for bottled water are made from non-degradable plastics and are not reusedor recycled: amounts of plastic waste generated every year are estimated at half a milliontonnes. With both landfill and incineration becoming the options of last choice, reusing andrecycling containers would benefit the environment and, increasingly, are likely to be cost-effective options. A WWF Discussion Paper points out that PET is increasingly chosen for bottles instead of PVC because of its properties: it is light, easy to work on and very transparent. It can be re-manufactured into many different products, such as fibres for the clothing industry. Whenincinerated, it does not release chlorine into the atmosphere, unlike PVC.Negative environmental impacts, in particular energy consumption, are reduced if PET,aluminium and glass packages are washed and re-filled rather than re-manufactured, andstrict hygiene criteria must obviously be applied in such situations. Regardless of the materialof manufacture, CIWEM considers that bottles should as far as possible be reused andrecycled locally. However, it is important that if bottles are to be washed and re-filled, this isonly undertaken where water is bottled and distributed to a local market, otherwise thebenefits of re-using bottles will be negated by transportation of empty bottles.References:1. Codex Alimentarius Commission: Codex Stan. 108 – 2001 “Codex Standard for NaturalMineral Waters and Codex Stan. 227 – 2001 “General Standards for Bottled/PackagedDrinking Waters (Other than Natural Mineral Waters).2. Department of Health: Bottle feeding. Leaflet No. 31640 2p 500k February 04.3. World Health Organisation: Technical Notes for Emergencies No. 9 – Minimum water quality needed for domestic use in emergencies. Author: Brian Reed.4. World Wide Fund for Nature: Discussion Paper – “Bottled Water: Understanding a SocialPhenomenon”. Author: Catherine Ferrier April 2001.5. European Commission: Council Directive 80/777/EEC – “COUNCIL DIRECTIVE of 15 July1980 on the approximation of the laws of the Member States relating to the exploitation andmarketing of natural mineral waters”6. Her Majesty’s Stationary Office: Statutory Instrument 1999 No. 1540 - Natural MineralWater, Spring Water and Bottled Drinking Water Regulations 1999 and Irish Regulation:European Communities (Natural Mineral Waters, Spring Waters And Other Waters In BottlesOr Containers) Regulations 2005 World Health Organisation: Fact Sheet No.256 – Bottled drinking water. October 2000.8. International Bottled Water Association: Answer to a question on their Website FAQs( ).9. U.S. Food and Drug Administration: Two years Health Canada: One year ( )( )
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