Corporate Accountability International Campaign Serves to Confuse Consumers and Provide Bottled Water Misinformation

November 14, 2006

Activist group Corporate Accountability International (CAI) today issued a press release that contains many factual errors and subjective viewpoints on bottled water. The press release is the latest attempt by CAI to confuse and misinform consumers. Bottled water is comprehensively regulated as a packaged food product by the U.S. Food and Drug Administration (FDA) and state regulatory agencies. The current system of bottled water regulation provides consumers with outstanding bottled water safety, quality and public health protection.

The CAI release states incorrectly that bottled water is less regulated and less safe than tap water and does not offer any substantiation for these erroneous claims. The fact is that, under federal law, FDA bottled water standards of quality (SOQs) must be as stringent and protective of public health as Environmental Protection Agency (EPA) tap water regulations. Contrary to CAI's claims, bottled water--like other food products--is subject to rigorous testing and monitoring requirements. And similar to the EPA system, FDA helps ensure regulatory compliance through its partnerships with local and regional FDA offices as well as through state regulatory agencies. EPA itself does not, as a matter of routine practice, conduct tests on tap water treatment plants. However, like EPA, FDA maintains the authority to test product and conduct plant inspections at any time.

With regards to providing consumers with bottled water quality information, FDA on August 25, 2000 published in the Federal Register, the "FDA Final Study Report: Feasibility of Appropriate Methods of Informing Consumers of the Contents of Bottled Water." FDA concluded that not all information found in a CCR for public water systems is applicable to bottled water and that certain content information already found on bottled water labels - combined with the consumer's access to company contact information on the label - are reliable means of providing information to the consumer.

Based on current bottled water labeling requirements and regulation, there is no public health or public policy basis to single out bottled water from other food products for additional label reporting or methods of reporting.

The bottled water industry strongly believes that consumers should be able to obtain information about the safety and quality of bottled water in a timely fashion. By law, FDA requires all food product labels, including bottled water, to include the name and address of the manufacturer, packer or distributor. In addition, virtually all bottled water products in the commercial marketplace include a telephone number on the label.

What CAI failed to mention is that that tap water systems can distribute drinking water to consumers as long as the annual average level of a standard meets the EPA standard. Therefore, if test results from three months exceed a standard and the remaining nine months are in compliance with the maximum contaminant level (MCL, which is EPA's standards as applied to tap water) the public water system is considered to be in compliance as long as the 12-month average meets the standard. As a result, information contained in a tap water quality report (known as a "Consumer Confidence Report," or "CCR") would not report that a standard had been exceeded.

As with all food in the United States, specific product lots that are not in compliance with myriad FDA standards can be identified, removed from the marketplace and thus made unavailable to consumers. Once it is determined that a bottled water product is not in compliance with FDA standards, it may be immediately withdrawn from the consumer marketplace.

Another complaint mentioned in the CAI release alleges that bottled water companies threaten local control of water resources. Again, this has no basis in fact. Ground water withdrawals for bottled water production represent only 0.02% of the total fresh ground water withdrawals in the U.S. Furthermore, ground water supplies are continuously "recharged" or replenished by precipitation, thus they are considered "renewable." If CAI were truly concerned about protecting water resources, a narrow focus on the bottled water industry does nothing to protect and sustain ground water. Bottled water is one of thousands of products to use water as an ingredient or in production.

Consumers are demonstrating their choice of bottled water based on the merits of bottled water's consistent safety, quality, convenience, and good taste. Bottled water marketing and advertising does not serve to undermine consumer confidence in tap water. Rather, it focuses on the benefits of choosing water for hydration and the attributes of a specific brand.

CAI strives to frame the issue as a "bottled water versus tap water debate," thereby missing the point. Consumers are not uniformly replacing tap water with bottled water; rather they are choosing bottled water over the other beverages available at the store and home. Consumers across the United States choose bottled water as an alternative to other packaged beverages when they want to avoid or moderate calories, caffeine, sugar, artificial flavors or colors, alcohol and other ingredients. Or, they choose bottled water because they are not always satisfied with the aesthetic qualities (e.g., taste, odor, color) of their tap water. There are thousands of tap systems across the US, most of which are succeeding; but others are faced with occasional "challenges" or natural events that may cause service interruptions.

Consumers can remain confident in making bottled water their beverage of choice. The bottled water industry will continue to work closely with FDA and state agencies to help ensure that consumers have access to safe, high-quality bottled water.