| Bottled
Water Regulations
Bottled
Water Is Regulated on 3 Levels
FEDERAL
REGULATIONS
Bottled
water is fully regulated as a packaged food product by FDA. As such,
bottled water companies must adhere to FDA’s Standard of Quality,
labeling standards and GMPs.
- Standard
of Quality: All bottled water products must comply with
FDA’s Standard of Quality in Section 165.110(b) of Title 21
of the Code of Federal Regulations (CFR). These standards, along
with FDA’s Good Manufacturing Practices, help ensure the safety
of all bottled water products from production to packaging to consumption.
By law, FDA is required to review EPA’s drinking water standards
and regulate bottled water no less stringently.
-
Standard of Identity:
FDA’s labeling rules for bottled water include a Standard
of Identity, which are standardized definitions for terms found
on bottled water labels, such as “artesian,” “drinking,”
“mineral,” “purified,” “sparkling
bottled water,” and “spring.” Seltzer, soda water
and tonic water are considered soft drinks; therefore they are excluded
from these regulations.
- Nutrition
Labeling Education Act: In addition to Standard of Identity
requirements, bottled water companies must follow the Nutrition
Labeling Education Act (NLEA), which sets rules for labels, including
serving sizes, format and placement of the label on the food package.
- Good
Manufacturing Practices: Bottled water is subject to both
general food GMPs and GMPs specific to bottled water processing
and bottling. General food GMPs govern such areas as plant and ground
maintenance, sanitary maintenance of buildings and fixtures, and
sanitary facilities, including water supply, plumbing and sewage
disposal. Bottled water GMPs govern plant construction and design,
sanitary facilities and operations, equipment design and construction,
production and process controls specific to the production and processing
of bottled drinking water and extensive record keeping.
STATE
STANDARDS
In addition
to FDA’s extensive regulatory requirements, the bottled water
industry is subject to state regulatory requirements as well.
- Inspections:
A significant responsibility of a state government is to inspect,
sample, analyze and approve water sources. Under the federal GMPs,
only approved water sources can be used to supply a bottling plant.
Many states also require bottled water plants to be registered with
the state and comply with their specific requirements.
- Laboratory
Certification: Another area in which some states have important
responsibilities that complement federal regulation is the certification
of testing laboratories. As with any food production establishment,
states can perform unannounced plant inspections. Some states perform
annual inspections.
INDUSTRY
STANDARDS
In addition
to the federal and state standards for bottled water, IBWA bottler
members are subject to another level of oversight through the IBWA
Model Code, which in several cases contains standards that are more
strict than FDA, state or public drinking water standards.
- Third-party
Inspections: As a condition of membership, bottlers must
submit to an annual, unannounced plant inspection administered by
an independent, internationally recognized third-party inspection
organization. This inspection audits quality and testing records,
reviews all areas of plant operation from source to finished product,
and checks compliance with FDA’s Standard of Quality, GMPs,
principles of HACCP and any state regulation.
- HACCP:
Developed by FDA and USDA for a sciencebased approach toward food
safety, this system was implemented voluntarily by IBWA bottler
members to help ensure safety in every step of the bottled water
process.
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