Bottled Water Packaging Policy Statement

IBWA Policy

The International Bottled Water Association (IBWA) is dedicated to the comprehensive management of bottled water packaging to provide the highest quality, cost effective and environmentally responsible containers possible. IBWA and its members approach packaging issues in a manner emphasizing the most effective and efficient solutions to reduce the strain on the environment while taking into account the equal responsibility of all solid waste generators. Consideration must also be given to behavioral solutions, such as public education and enforcement of existing recycling and litter control laws.

Background

Since the first Earth Day in 1970, environmental responsibility has become more than just a novel concept: it has become a part of American life. Through the years, businesses, governments and consumers have adopted more environmentally friendly practices in recognition of our duty to take responsibility for the world in which we live. Businesses and governments have implemented various measures aimed at reducing, reusing and recycling the packaging used to contain and deliver products to consumers. Today, Americans recycle more than 30 percent of the nation’s waste, up from 10 percent in 1987.

Since the beginning of the current environmental movement, programs once thought to be ideal for conserving resources have proven to be less effective and efficient than other, more comprehensive solutions. For instance, two specific programs once heralded as successful in their attempts to encourage recycling and reduce litter are 1) beverage container deposit systems, or “bottle bills;” and 2) mandatory recycling content for certain product packaging. To a degree, both endeavors are successful in achieving their intended goal, but fail to address the issue in a comprehensive manner.

More comprehensive solutions include public education and the implementation of curbside recycling programs. Curbside recycling programs accept a larger variety of materials than other solid waste programs and, therefore, divert a greater volume of solid waste from the waste stream. The convenience of curbside programs also offers consumers the ability to more easily recycle household products. The first curbside recycling program began in the early 1980s. By 1998, 9,000 curbside programs and 12,000 recycling drop-off centers had been established in the U.S.1

Bottle bills operate on the premise that placing a monetary deposit on a beverage container as an incentive to return that container to a recycling center is the most efficient and effective way to reduce the amount of solid waste sent to landfills or improperly discarded. In the late 1970s and early 1980s, ten states and one city implemented bottle bill programs. They include California, Connecticut, Delaware, Iowa, Maine, Massachusetts, Michigan, New York, Oregon, Vermont, and the city of Columbia, Missouri (repealed by voter referendum in 2002). California and Maine are the only states whose programs currently include non-carbonated bottled water and other non-carbonated beverages in their deposit system, although the inclusion of non-carbonated beverages in state programs is regularly discussed by state legislators.

With time, the inefficiencies of such programs became evident and better solutions have been identified. Bottle bills, even when expanded to include non-carbonated bottle water and other non-carbonated beverages, capture less than five percent of the total municipal solid waste stream. According to a 1997 study of the Massachusetts forced deposit law and a proposal to expand it to include noncarbonated beverages, the cost to recycle containers in the existing program was $320.00 per ton, while the expanded program would cost $1,500.00 per ton.2 A typical curbside program recycles beverage containers at an average cost of $120.00 per ton . The bureaucracy required to administer this type of program makes it an extremely inefficient way to address recycling and litter control. By effectively placing a bounty on certain types of containers, bottle bills also remove valuable recyclable materials from curbside programs, thereby hindering the financial viability of such quality programs.

For manufacturers, distributors and retailers, bottle bills create a financial and logistical nightmare by placing an undue strain on their operations and adding costs for the products. Bottle bills also create potentially unsanitary conditions when used containers are returned en masse to redemption centers that also serve as food retailers. In fact, a study released in January 2002 revealed that beverage container redemption had the effect of promoting the growth of bacteria, mold and pathogens in Iowa (a container deposit state) grocery stores serving as redemption centers. Ultimately, the costs incurred through the inherent inefficiencies of a beverage container deposit system are passed along to consumers in the form of higher prices.

Mandatory recycling content for plastic packaging is another idea with good intentions, but without merit. In an effort to reduce the reliance on virgin plastic for product packaging and create a market for post-consumer recycled plastic packaging, states have looked at requiring a specific percentage of recycling content to be used in plastic packaging. However, there is no technological guarantee that recycled content will not contaminate a food product. Without further research to determine what the acceptable level of recycled content is for food packaging, unsubstantiated government mandates for recycled content are incompatible with government requirements for food safety.

Additionally, a mandate for recycled content in bottled water containers is not an efficient way to achieve a significant reduction in litter or solid waste, since, in general, only about 2 percent of roadside litter consists of non-carbonated drink containers. More than any other segment of the food industry, the bottled water industry already contributes significantly to solid waste reduction through the use of refillable containers for home and office cooler service. Emphasis should be placed on the identification of other uses for which recycled content can be considered a viable option for non-food applications such as carpets, cushion fill, detergent bottles, motor oil bottles, etc.

Guiding Principles of Bottled Water Packaging

IBWA believes the following set of principles should guide the industry in addressing solid waste, recycling and litter. A comprehensive approach must be utilized, emphasizing efficient and effective solutions that address the broad array of solid waste and treat all solid waste generators in an equitable manner.

• Education and awareness – Behavioral approaches to solid waste reduction and litter control must be a part of any good public policy. Education of consumers, government and industry is the key to making all parties involved responsible citizens in environmental protection. Unfortunately, there has been very little public education on recycling, at both the local and national levels, for too many years. Without some level of public education professing ways to increase personal responsibility for recycling and litter control in conjunction with other waste reduction measures, the success of such programs is severely restricted and its purpose defeated from the outset.
  
• Efficient, yet effective, solutions – Any attempt to increase recycling rates and/or reduce litter should be evaluated to determine whether the successful attainment of its intended goal justifies the process by which that goal is achieved. Implementing a vast bureaucracy and creating logistical and financial hardships for all parties involved to successfully capture a small amount of the total municipal solid waste stream may not be the best solution. Programs that more properly balance cost and convenience with effectiveness should be given a higher priority.
  
• Curbside recycling programs – Curbside recycling programs offer a convenient way for the average consumer to participate in an effective recycling program. Curbside programs accept a greater variety of materials, thereby preventing a larger volume of solid waste from being sent to landfills Non-Home and Office Delivery (HOD) bottled water is generally sold in recyclable polyethylene terephthalate (PET) containers. While reasoned efforts should be made to increase the recycling rate of these types of materials, other categories of solid waste should be taken into account when addressing recycling rates. An expensive and cumbersome recycling effort focusing only on beverage containers, which comprise less than 5 percent of total municipal solid waste, ignores other recyclable solid waste such as newspaper, cardboard and food containers. When valuable materials such as PET and aluminum are removed from curbside programs by bottle bills, the stability of curbside programs is severely hindered.
  
• Equitable treatment for all waste producers – In order to effectively address the total municipal solid waste stream, proper solutions must look beyond a limited number of waste generators. For instance, bottle bills and recycled content mandates specifically target packaged consumer product manufacturers. Yet the packaging used in these products represent a small fraction of the total volume of waste destined for landfills. Focusing on one category type, and thereby singling out one industry, does not achieve total solid waste reduction. A shared responsibility between all producers and users of packaging must comprise any successful solid waste and/or litter reduction program.
  
• Enforcement of current laws – Prior to the drastic reform of current recycling and litter control programs or the implementation of new programs, policymakers must first determine whether or not the existing programs are being properly administered and enforced. If good public policy is not fully and properly implemented, the intended goal may not be achieved.

Conclusion

The above principles comprise a reasonable, comprehensive approach to the management of solid waste and litter and should be inherent in any policy seeking to address this issue. In cooperation with consumers and government, the bottled water industry must assert its commitment to the environment or face the reality of complying with new tougher and less reasonable laws and regulations.

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1. U.S. Environmental Protection Agency
2. The Solid Waste Project of the Massachusetts Food Association, by Northbridge Environmental Management Consultants; May 12, 1997

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