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W W W. B O T T L E D W AT E R . O R G


IN THIS ISSUE What State How FDA's Why Visuals Work in Legislators Do in Labeling Revisions Social Media the "Off-Season" Affect You



Also Inside:


VOL. 57 • NO. 6


20 | No Off-Season for State Legislatures Why interim periods are a great time to educate legislators about bottled water issues. COMMUNICATIONS

22 | Why Visuals Work When "show don’t tell” is the name of the social media game. TECHNICAL UPDATE

24 | What FDA’s Revised Labeling Regulations Mean for Bottled Water How sweeping revisions to FDA labeling regulations may affect your business. VALUE OF IBWA MEMBERSHIP

28 | IBWA as a Hub of Information Jean Valvis, owner and founder of new IBWA bottler member AQUA Carpatica, discusses his company and how the industry information IBWA shares with him has helped his business.

TABLE OF CONTENTS 8 | Sustainable Innovation Designing Bottles to Be Recycled

The bottled water industry is a pioneer in innovative packaging. Now, when there’s so much focus on environmental sustainability, what considerations should designers keep in mind to ensure the recyclability of bottled water plastic containers? By Kim Wheeler

DEPARTMENTS CHAIRWOMAN'S COMMENTARY...........................2 PRESIDENT’S MESSAGE.......................................4 WATER NOTES.....................................................6 CPO QUIZ..........................................................26 ADVERTISERS....................................................27 CALENDAR........................................................27


14 | H2Overwhelmed

Getting the Facts Straight About Bottled Water As the No.1 packaged beverage in America, bottled water can expect its critics to become more vocal than ever. Thus, now is the time to ensure the industry is promoting bottled water facts that will help consumers feel good about their purchasing decisions. By Kim Wheeler

BOTTLED WATER REPORTER, Volume 57, Number 6. Published six times a year by The Goetz Printing Company, 7939 Angus Court, Springfield, VA, 22153, for the International Bottled Water Association, 1700 Diagonal Road, Suite 650, Alexandria, VA 22314-2973. Tel: 703.683.5213, Fax: 703.683.4074, www.bottledwater.org. Subscription rate for members is $25 per year, which is included in the dues. U.S. and Canadian subscription rate to nonmembers is $50 per year. International subscription rate is $100 per year. Single copies are $7. POSTMASTER: Send address changes to Bottled Water Reporter, 1700 Diagonal Road, Suite 650, Alexandria, VA 22314-2973.


My tenure as your Chairwoman is ending and it has been an honor to serve in this capacity. This past year has reaffirmed what I’ve known for many years, as I’ve worked along-side IBWA bottlers, suppliers, distributors, candidate bottlers—BOTTLED WATER IS THE BEST INDUSTRY ON THE FACE OF THE EARTH! As IBWA Chairwoman, I asked our members to continue to spread the good news about our industry and to build and maintain relationships with our elected officials in our State capitals and on Capitol Hill. The collective, dedicated work of all our IBWA members and staff resulted in the National Park Service rescinding its policy to ban the sale of bottled water in single-serve plastic bottles. This great news is the direct outcome of the many meetings that the IBWA members, staff, and consultants had with members of Congress over the past several years. Several Congressional members were supportive of our goal to rescind a policy that banned the sale of a healthy product like bottled water, in individual parks. I challenged our members to invite their elected officials to visit their companies and tour their bottling facilities. Our members have risen to this challenge, with approximately eight plant tours to date and counting. Thank you for arranging these meetings with your elected officials and affording them the opportunity to see the complexities of a bottled water manufacturing plant, meet your employees and their constituents, and learn firsthand that the bottled water industry is relevant and bottled water does matter. I want to also thank the IBWA members for reinforcing the adage “bottled water is always there.” Our members donated bottled water to those affected by Hurricanes Harvey, Irma, and Maria. To ensure their customers had adequate quantities of safe, drinking water before, during and after these three destructive natural disasters, companies efficiently managed production and delivery to locations such as homes, offices, hospitals and nursing homes. Finally, my heart-felt thank you to the IBWA Board of Directors, staff, consultants, committee chairs, committee members and all the members of this great trade association. Because of your hard work, tenacity and dedication; I now know more than ever before that we are ALL associated with the best industry—BOTTLED WATER. Thank you for allowing me to be a part of what has been a great and challenging year for our industry. Let’s continue to work together to support our industry and its healthy products.

Shayron F. Barnes-Selby Shayron Barnes-Selby IBWA Chairwoman


International Bottled Water Association OFFICERS Chairwoman Shayron Barnes-Selby, DS Services of America, Inc. Vice Chair Lynn Wachtmann, Maumee Valley Bottlers, Inc. Treasurer Brian Grant, Pure Flo Water Company, Inc. Immediate Past Chairman Joe Bell, Aqua Filter Fresh, Inc.

BOARD OF DIRECTORS Shayron Barnes-Selby, DS Services of America, Inc. Joe Bell, Aqua Filter Fresh, Inc. Charlie Broll, Nestlé Waters North America Philippe Caradec, Danone Waters of America Andy Eaton, Eurofins Eaton Analytical Brian Grant, Pure Flo Water, Inc. Brian Hess, Niagara Bottling LLC Doug Hidding, Blackhawk Molding Co. Scott Hoover, Roaring Spring Bottling Dan Kelly, Polymer Solutions International Greg Nemec, Premium Waters, Inc. Bryan Shinn, WG America Company Robert Smith, Grand Springs Distribution Louis Vittorio, Jr., EarthRes Group, Inc. Lynn Wachtmann, Maumee Valley Bottlers, Inc. William Patrick Young, Absopure Water Co., Inc.

IBWA EXECUTIVE COMMITTEE Chairwoman Shayron Barnes-Selby, DS Services of America, Inc. Joe Bell, Aqua Filter Fresh, Inc. Charlie Broll, Nestlé Waters North America Philippe Caradec, Danone Waters of America Brian Grant, Pure Flo Water Company, Inc. C.R. Hall, Hall’s Culligan Henry R. Hidell, III, Hidell International Scott Hoover, Roaring Spring Bottling Dan Kelly, Polymer Solutions International Ed Merklen, DS Services of America, Inc. Bryan Shinn, WG America Company Lynn Wachtmann, Maumee Valley Bottlers, Inc. William Patrick Young, Absopure Water Co., Inc.

COMMITTEE CHAIRS Communications Committee Julia Buchanan, Niagara Bottling, LLC Audrey Krupiak, WG America Company Education Committee Glen Davis, Absopure Water Co., Inc. Douglas R. Hupe, Aqua Filter Fresh Environmental Sustainability Committee Leslie Alstad, Pure Flo Water Company, Inc. Jeff Davis, Blackhawk Molding Co. Government Relations Committee Derieth Sutton, Niagara Bottling, LLC Lynn Wachtmann, Maumee Valley Bottlers, Inc. Membership Committee Marge Eggie, Polymer Solutions International Kelley Goshay, DS Services of America, Inc. State and Regional Associations Committee Joe Cimino, ChoiceH2O Supplier and Convention Committee Brian Grant, Pure Flo Water Company, Inc. Dan Kelly, Polymer Solutions International Technical Committee Andy Eaton, Eurofins Eaton Analytical Kevin Mathews, Nestlé Waters North America




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International Bottled Water Association


BOTTLED WATER REPORTER is published for: International Bottled Water Association 1700 Diagonal Road, Suite 650 Alexandria, VA 22314-2973. Tel: 703.683.5213 Fax: 703.683.4074 www.bottledwater.org


More and more, I hear people acknowledge that bottled water is, indeed, the best healthy packaged beverage option. Yet, they still show concern about the delivery method: the plastic container. The bottled water industry has been very active in implementing innovations that reduce the impact of bottled water on the environment. In fact, our hard work has paid off by giving us the smallest water-use and energy-use ratios of all beverages packaged in plastic and the highest recycle rate in curbside recycling systems. But, because we know we can do even more, the cover story in this issue of Bottled Water Reporter, “Sustainable Innovation” (p.8), offers tips from the Association of Plastic Recyclers (APR) that can help bottlers enhance the quality and increase the supply of recycled PET (rPET). Interestingly, the APR Design® Guide for Plastics Recyclability reviews how the materials used to create labels—paper, PVC, inks, etc.—can have a positive or negative effect on the recycling process. Labels are again the focus of our Technical Update column (p.24), which examines how the U.S. Food and Drug Administration’s (FDA) revised nutritional labeling regulations will affect bottlers. In short, several revisions will impact bottled water, specifically sodium claims on the label and how fluoride content is expressed on the label. Consumers often look on our labels for answers to the questions they have about bottled water products. In our second feature, “Overwhelmed: Getting the Facts Straight About Bottled Water” (p.14), we provide answers to some of the most often asked questions about bottled water. Feel free to share these bottled water facts with consumers to help them make informed purchasing decisions. This issue’s Government Relations column (p.20) reveals how in today’s political landscape there’s no such thing as a part-time legislator. Even when a state legislature doesn’t meet year-round, the “off-season” interim period is a great time to reach out to legislators to educate them more about bottled water. Our Communications column (p.22) reviews the power of using visuals to communicate in the digital age—proving once again that a picture is worth a thousand words. This issue of Bottled Water Reporter presents a lot of valuable and educational content. We hope you learn something new when you read it—and that you share that information with your coworkers and consumers!

President Joe Doss jdoss@bottledwater.org Vice President of Education, Science, and Technical Relations Robert R. Hirst bhirst@bottledwater.org Vice President of Communications Jill Culora jculora@bottledwater.org Vice President of Government Relations Cory Martin cmartin@bottledwater.org Director of Conventions, Trade Shows, and Meetings Michele Campbell mcampbell@bottledwater.org Director of Government Relations J.P. Toner jtoner@bottledwater.org Director of Science and Research Al Lear alear@bottledwater.org Director of Communications Sabrina E. Hicks shicks@bottledwater.org Manager of Member Services Cheryl Bass-Briscoe cbass@bottledwater.org Education and Technical Programs Coordinator Claire Crane ccrane@bottledwater.org Communications Coordinator Chris Torres ctorres@bottledwater.org Executive Assistant Patrice Ward ibwainfo@bottledwater.org Bottled Water Reporter Layout and Design Rose McLeod rozmack@gmail.com Tel: 315.447.4385 Editor Sabrina E. Hicks shicks@bottledwater.org

Joe Doss IBWA President 4



Advertising Sales Stephanie Schaefer stephanie@bottledwater.org

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Dr. Eugene W. Rice Elected to the DWRF Board of Trustees The Drinking Water Research Foundation (DWRF) is pleased to announce that Eugene W. Rice, PhD, has been unanimously elected by trustees to serve as a board member for a three-year term. Dr. Rice's expertise in microbiology will be a welcome addition to the research foundation. During the June 2017 DWRF meeting, Rice spoke to the trustees on the topic of “Microbial Inactivation Studies” and discussed some of the interesting disinfection studies he has conducted using chlorine, ozone, ultraviolet irradiation, and heat. DWRF trustees recently asked Rice to analyze and evaluate a research proposal that will examine the effectiveness of microbial inactivation by ozone in sealed, finished bottled water containers. Rice retired in 2016 after 38 years at the U.S. Environmental Protection Agency (EPA) Office of Research and Development, located in Cincinnati, Ohio. While with the EPA, he worked in both the Water Infrastructure Protection Division and the Drinking Water Research Division.

Rice has received many awards, including the Distinguished Career Service Award in 2016 and the Office of Research & Development Statesmanship Award in 2015. He has served with fellow DWRF Trustee Andrew Eaton, PhD, on the joint editorial board of Standard Methods for the Examination Dr. Eugene W. Rice of Water and Wastewater, in addition to editorial duties with the journal Applied and Environmental Microbiology. Rice has also published more than 100 peer-reviewed articles on topics ranging from ozone inactivation of cryptosporidium to the occurrence and control of tularemia in drinking water.


Kristin Safran College Scholarship Awarded to Madison Sas Penn State University freshman Madison (Maddie) Sas is the 2017 recipient of the Kristin Safran College Scholarship. Maddie, whose father James works at Creekside Springs in Ambridge, Pennsylvania, began her studies at Penn State this fall with plans to study engineering. She graduated from Ambridge Area High School and, while she excelled academically, she also participated in numerous extracurricular activities. Maddie was active in sports, including varsity soccer and track, and was a member in many clubs, including National Honor Society and Young Women’s Leader Club. Maddie graduated in the top 10 percent of her class with a 4.0 grade point average—an impressive achievement considering the majority of her coursework consisted of honors 6



or AP classes. Maddie received many awards for her achievements, including the Society of Women’s Engineers Award, and she was heavily involved in community service and volunteering efforts at her high school and in her community. During the judging process, the Kristin Safran College Scholarship Selection Committee—made up of Drinking Water Research Foundation (DWRF) Trustees Jack West, Stew Allen, and Kristin’s widower, Russ Safran—blindly reviewed applications from children or grandchildren of IBWA members (i.e., judges did not know the names of the children or parents, or the company the parents work for when reviewing applications). DWRF created the Kristin Safran College Scholarship Fund in February 2010 in honor of former IBWA Board

Madison Sas

of Directors member Kristin Safran (ARK Specialty Services), who passed away in 2009. The scholarship was established to help high school seniors pursue their college studies. For more on DWRF, visit www. thefactsaboutwater.org.


(Tweet in November) It's #AmericanDiabetesMonth. Swap sugary beverages like soda for healthy, refreshing #BottledWater to help prevent or manage diabetes.

for new opport unities to conn ect with educate them about bottled w at er issues, feel share any of th free to e following on yo ur so ci al media sites dur November and ing December—or be inspired and write your own!

consumers and

November is #NationalDiabetesMonth. More than 30 million Americans suffer from diabetes, and another 84.1 million are prediabetic. The National Institute of Diabetes and Digestive and Kidney Diseases recommends that diabetics "drink water instead of juice and regular soda." (Read more: www.niddk.nih.gov/health-information/ diabetes/overview/managing-diabetes/4-steps.) #ManageYourDisease #BottledWater.

National Campaigns November: American Diabetes Month, Veterans Day (November 11), America Recycles Day (November 15), Thanksgiving (November 24)

(After December 21): It's officially winter! Remember to stay properly #hydrated even when the temperature outside drops #healthyhydration #bottledwater #drinkup

December: World AIDS Day (December 1), First Day of Winter (December 21), New Year's Eve (December 31)

Novem be 15th! r

(Post on November 15) Today is #AmericaRecyclesDay. The EPA estimates that 75 percent of what Americans throw away is recyclable, but we only recycle about 30 percent of it. Recycling conserves resources and energy, reduces carbon emissions, and decreases pollution. #BottledWater containers are 100 percent recyclable— even the caps! Remember to recycle your empties today and every day. #PutItInTheBin Download: bit.ly/H2OWinter

Wishing you and your family a happy, safe, and hydrated holiday season! (Repost: www.instagram. com/p/BOdfiMGBUsP/?takenby=bottledwatermatters)

The holidays can easily become a time for overindulging. To help limit your calorie intake at parties, the Academy of Nutrition and Dietetics suggest that you "ask for sparkling water and lime, which doesn't supply calories, and start mingling." For more tips on how to enjoy the holidays guilt-free, visit www.eatright.org/ resource/health/lifestyle/holidays/enjoyguilt-free-holiday-celebrations.

November is PTA Healthy Lifestyles Month. Encourage students at your child's school to choose healthy, refreshing water when they're thirsty with this visual reminder of the sugar content of different drink options. www.pinterest.com/pin/414964553157638642 Download: bit.ly/TakeItToCourt

(Tweet on November 17) Today is #TakeAHikeDay. Grab a healthy, refreshing #BottledWater and visit www.alltrails.com to find a trail near you.

Learn how to make a holiday wreath out of plastic water bottles. www.pinterest. com/pin/414964553157638698

November is #Movember, an awareness month focused on reducing the number of men dying prematurely. Proper hydration is essential to men's health—both physical and mental—and is part of a lifestyle that leads to health and longevity. Take hydration seriously. Choose healthy, refreshing #BottledWater instead of sugary beverages to stay hydrated, cut calories, and avoid sugar, sweeteners, and added chemicals. (Read more: www.mensfitness.com/nutrition/what-to-drink/5-reasonsnever-neglect-water.)


Sustainable Innovation:

Designing Bottles to Be Recycled By Kim Wheeler

As the global bottled water market continues to grow and bottled water remains the No.1 packaged beverage in the United States, the pressure on bottlers to produce products with a reduced environmental impact increases as well. Fortunately, the bottled water industry is a pioneer in packaging innovation and has worked since 2000 to halve the amount of plastic used in its single-serve PET bottles to produce the lightest-weight bottles in the packaged beverage market. But in order to continue this trend of progressive packaging, beverage container designers must consider many factors to ensure the recyclability of a plastic bottle. A product’s recyclability can be impaired by seemingly harmless design choices that ultimately render it unsuitable to the recycling infrastructure, resulting in contaminated batches of rPET or, in some cases, disposal in the landfill. Innovative bottled water design accounts for not only the look, function, and composition of the bottle but also its practical recyclability. But what design factors influence a bottle’s recyclability? How do bottlers know whether or not the containers they use to convey the bottled water they produce can be recycled effectively? The Association of Plastic Recyclers (APR)—the international trade association for the plastics recycling industry that works to enhance quality

and increase supply of postconsumer plastics— provides designers and engineers with preferred protocols for plastic packaging. The APR Design® Guide for Plastics Recyclability offers a comprehensive overview of seven key design features that impact a PET plastic product’s recyclability: base polymers; barrier layers, additives, and coating; color; dimensions; closures and dispensers; labels, inks, and adhesives; and attachments. According to a recent study conducted by Plastic Technologies, Inc. (PTI), the most common issues bottled water containers present during the recycling process relate to labels, inks, and adhesives, as well as the low weight of the bottles themselves. Using the APR Design® Guide, we present on the following pages a user-friendly resource of the basics to remember when designing packaging for recyclability.

NOV/DEC 2017



The APR Design® Guide offers a comprehensive overview of design features that impact a PET plastic product’s recyclability.

tions are made based on how materials perform in the “float-sink” systems that recyclers rely on to separate nonPET materials from the PET bottles. In the case of bottle labels, any parts of the label that fail to separate from the bottles sink with the PET to the bottom of the tank and end up in the rPET stream as contaminants.

Label suppliers offer product designers an array of label options. Labels can be made from materials such as coated or laminated paper, PVC, polypropylene, synthetic composites, metal foils, etc. They can be truncated wraparounds or full-bottle sleeves. Each type of label may offer different advantages for form or function, but not all label types can be easily separated from PET during the recycling process—the determining factor in whether or not it is conducive to effective recycling.

“The APR Design® Guide for plastics recycling lists the paper label as detrimental to PET recycling,” says APR Technical Director John Standish. “When you recycle PET, all of the plastic is washed at 85 degrees centigrade in a caustic wash, and that nice paper label turns into pulp in the wash tank. The recycling process has to have special machinery to filter and rinse all that paper pulp out of the water and PET. Now, instead of disposing of a little piece of dried paper, you have to send to waste a glob of sopping wet pulp. And when you pay to dispose of things by the pound, that wet pulp is costly.”

The APR Design® Guide categorizes labels—as well as all other design features—into four different classifications of recycling compatibility, rating them as APR-preferred, detrimental to recycling, non-recyclable according to APR standards, or in need of more testing. These determina-

Pulp that cannot be separated and removed contaminates the rPET, creating visible black specks that make it less viable for use in new products, Standish says. Disposing of pulp and ending up with contaminated batches of rPET are costly for recyclers, leading some facilities to manually




NON-RECYCLABLE PER APR DEFINITION Consider alternative features



Do any features REQUIRE TESTING to classify?


Have all specified tests been completed?

Classify feature(s) according to test outcome(s)

*For items meeting the 60% collection system access for a plastic material that is addressed in the APR Design Guide.

Source: Association of Plastic Recyclers




RECYCLING sort out brands known to use paper labels, in turn leading bottles to the landfill. “Companies might use paper labels because they are less expensive or they might use paper labels thinking they’re doing the right thing to be sustainable,” Standish says. “They mean well, but they might not realize that they’re actually yucking up the recycle system.”

Disposing of pulp and ending up with contaminated batches of rPET are costly for recyclers. Leon Farahnik, chairman and CEO of CarbonLITE, one of the world’s largest producers of food-grade postconsumer rPET, says PVC labels are another offender in recycling facilities. Because of its similarity in density to PET, PVC is exceptionally difficult to separate and remove. Even in very small amounts, PVC contaminants can critically diminish the quality of the resulting rPET. “PVC just doesn’t go along well with PET,” says Farahnik, whose company processes more than 4 billion plastic bottles annually into bottle-grade PET resin flakes and pellets that can be used to produce new plastic beverage packaging and other products. “It creates a lot of issues with the raw materials and problems in all aspects of the process—processing the material, cleaning the material, the extrusion process, and so on. It’s just a very bad thing to have labels made from PVC.”

Another important label design consideration is the length of the label. Full-bottle sleeve labels cover a large amount of the bottle’s surface with a polymer that is different from that of the bottle. This creates two potential problems, according to the APR Design® Guide. Large labels can cause a false reading on a recycling facility’s automatic sorter and direct a PET bottle to another material stream. They are also more difficult to remove during the recycling process and can leave behind remnants that contaminate the rPET produced.

Inks While inks are a necessity for bottlers to brand their bottles, the type of ink they use can actually impact the bottle’s recyclability. “The inks on the labels can be developed so that they don’t interfere with recycling,” Standish says. “If your ink isn’t properly selected, it will wash off the label [during the caustic wash] and get into the wash water. And if you have a label with a lot of white ink in it, the label might come off but will sink with the PET.” Standish explains that white ink is made using a very dense pigment called titanium dioxide, which weighs down the label and causes it to sink. Yet, all colors of ink can wash off into the caustic wash water if they are not caustic-resistant, tinting the PET resin brown and limiting its potential for reuse. The APR and the National Association for PET Container Resources (NAPCOR) established a testing protocol to evaluate whether a label ink will bleed color in conventional PET reclaiming systems. Label inks that have

CarbonLITE's raw material consists of used post-consumer plastic bottles, which arrive at the recycling facility compressed into half-ton bales. Photo credit: CarbonLITE NOV/DEC 2017



been tested accordingly and do not bleed color under this protocol are the best choice when considering recycling compatibility. Learn more at www.plasticsrecycling.org/ images/pdf/design-guide/test-methods/Bleeding_Label_ Test_PET-S-01.pdf.

Adhesives While Farahnik understands that adhesives are necessary to keep the label attached to the bottle, he says these binding agents cause trouble in recycling facilities. Current recycling technology is capable of removing enough adhesive contamination from the surface of the PET during the caustic wash to render it reusable, but some adhesives are resistant to removal and can cause contamination and discoloration of the rPET.

Glue has no easy answer. Anytime you have a label adhered with glue, chemicals must be used to remove the glue. “Glue has no easy answer, but any time you have a glue involved, you are creating a headache for the recycler,” Farahnik says. “Chemicals must be used to remove glue.” Promisingly, Standish says there has been some recent progress in the development of adhesives that are less likely to interfere with the recycling process. He urges designers to check their adhesives to ensure they are using an option that washes off cleanly from PET and remains adhered to the label. If you want to make it easier on the recycler, Standish provides the following advice: “Companies should choose a pressure-sensitive label. In the last two or three years, there’s been tremendous innovation in pressure-sensitive labels designed with adhesives that readily wash off and remove in the recycle process . . . Companies making or buying labels can know that they have a good label because it will have APR Critical Guidance recognition, meaning it’s very compatible with PET recycling.” APR advocates the use of pressure-sensitive, wrap-around polypropylene film labels that avoid heavy application of white ink and adhesives. These labels are made by applying printing to a thin film, then layering a second film over it. Because the ink is sandwiched between two layers of film, it doesn’t contaminate the wash water. Meanwhile, the polypropylene labels separate easily from PET in the caustic wash, floating up to the top of the water for collection and recycling while the PET sinks to the bottom. 12



Bottle Weight The light-weighting of single-serve plastic bottled water containers has been the industry’s major achievement in packaging sustainability, but the PTI study suggests that this advancement could hinder effective recycling. Unlike labels, inks, and adhesives, light-weighted bottles don’t adversely affect recycling machinery or contaminate rPET batches—there’s a chance they could simply fall through the cracks. Plastic bottles arrive to recycling facilities in bales. Because light-weighted bottles are thinner, they tend to “crush up like an accordion” inside the bales, Standish says, making them smaller than the average bottle and vulnerable to falling through gaps in the facilities’ size-sorting streams, thus becoming waste. “Lighter bottles have a tendency to get lost in the recycling process more than heavier bottles,” Farahnik agrees, “though I wouldn’t call that a major issue for recycling. Lighter bottles reduce production rates, but they use less raw material, and that’s good for the environment.”

“PET water bottles are the answer that allows people to have clean water available in any situation. Today, it costs companies more to use postconsumer raw materials because of the lower cost of virgin materials. But it’s also a savings in the sense that [PET bottles] don’t end up in landfills, oceans, and waterways.” Room to Grow As technologies advance, so do opportunities for new innovation in bottled water packaging. Farahnik urges designers and engineers to explore new ways to label bottles without using adhesives. “We are hoping that the technology is achieved so the day will come when PET bottles can be shrinkwrapped with no glue involved or somehow [labeled] without any kind of [adhesive],” he says. Meanwhile, Standish encourages the exploration of ways to increase the intrinsic viscosity (IV) of bottled water containers while maintaining their hallmark low weight.


Purified flakes (shown here) are created at the CarbonLITE recycling facility after plastic bottle washing and cutting. The flakes are then melted and extruded into pellets—the final product that is sold to produce new plastic beverage bottles. Photo credit: CarbonLITE

IV measures the molecular weight of a polymer and indicates the material’s melting point, crystallinity, and strength. The grade of PET needed to create a product depends on what the product will be used for and the necessary specifications for that purpose. For example, most soft drink bottles are made with a PET resin with an IV of 0.84 units, Standish says, while bottled water containers are made with PET resin with an IV of 0.76 units. When the bottles are recycled together, the overall IV of the resulting batch is lower. Because many plastic products will need to be stronger than a bottled water container and will thus need a grade of PET with a higher IV, this can limit the use of rPET made with a large number of water bottles. “As people buy fewer soft drinks and buy more water beverages, the average IV of recycled PET resin is dropping,” Standish says. “Recyclers then have to take steps . . . to build the IV back up. Higher IV is always better for recycling.”

Recycling for the Win Whether simply choosing recycling-compatible design features or actively working to develop new packaging technologies, considering the design impact on a product’s recyclability is crucial to producing bottled water containers that are both sustainable and recyclable. “Bottled water has surpassed every other beverage,” Farahnik says. “PET water bottles are the answer that allows people to have clean water available in any situation. Today, it costs companies more to use post-consumer raw materials because of the lower cost of virgin materials. But it’s also a savings in the sense that [PET bottles] don’t end up

To learn more about how design factors impact recyclability, read the following APR documents: • PET Design Guide: www.plasticsrecycling.org/ apr-design-guide/apr-design-guide-home • PET Critical Guidance: www.plasticsrecycling.org/ images/pdf/PET-Resins/PET-Bottles/pet_critical_ guidance.pdf

in landfills, oceans, and waterways. And using [rPET] reduces the carbon footprint by a tremendous amount versus using virgin materials.” This is why creating products that can be recycled effectively is so important, Standish says. “Something that unifies the plastic value chain is that it’s in everyone’s best interest to design the package to be compatible with recycling,” he says, explaining that a higher volume of high-quality rPET lowers the cost of the recycled resin and enables more manufacturers to use more rPET. “Recycled resin requires less energy and generates less greenhouse gas, probably by a factor of about half. So, when companies are very concerned about sustainability, reusing a high level of recycled resin is one of the most important things they can do to be environmentally sustainable. And consumers like to buy things that are sustainable, so it’s a win-win.”

Kim Wheeler recently held the position of communications coordinator at IBWA. NOV/DEC 2017



Visit www.bottledwater.org/education/myths to learn bottled water facts.


More and more, consumers are choosing bottled water because it is a safe, healthy, and convenient packaged beverage option that is free of calories, sugar, artificial sweeteners, dyes, caffeine, alcohol, and other additives. Despite its benefits and popularity, bottled water has critics, and they seek to ban the sale of, or restrict access to, bottled water. Those critics have established a strong presence online and in the media, where they promote misinformation about the safety and quality of bottled water, how it is regulated, and its environmental impact. 14



Some bottled water critics attempt to discourage people from buying or drinking bottled water by spreading what they call “truths about bottled water.” The problem is they usually don’t have the best—or accurate— information. Instead, they share many myths about bottled water, which have no verifiable source, are falsely credited, or cite studies that have been shown to have misrepresented or outdated data. But because there is far less accountability for critics than there is for the industry, these myths continue to be presented as fact by anti-bottled water activists. As Peter Roff notes in a Weekly Standard article lamenting the fact that proven science is often ignored, “Perhaps it is time to apply the same rigorous standards to the claims of critics as to those made by manufacturers.”

Because consumers want to make informed decisions about the products they buy, they search the internet for answers. Often, their research will turn up the faulty propaganda spread by bottled water critics. To combat all that misinformation, below we provide factual answers to some of the most common questions about bottled water.

The Basics Where does the water we drink come from? The vast majority of our drinking water—both tap and bottled—comes from either groundwater or surface water. Groundwater comes from wells, springs, and aquifers, where water from rain and snow has, over time, seeped into the ground and collected. Surface water comes from rivers, streams, lakes, and glaciers.








W y Kim


? D E LM T

bottled-water-testing or www.bottledwater. org/health/water-quality.

IBWA produced a video to demonstrate how bottled water is collected, treated, and packaged. Check it out at bit.ly/ TheInnerWorkingsOfBWPlant. According to BMC, about 64.3 percent of small-pack bottled water in PET plastic containers comes from public water systems. However, it is important to note that this is not "just tap water in a bottle." To produce this purified water, source water is processed and treated with a multi-barrier approach, which can include reverse osmosis, distillation, micro-filtration, carbon filtration, ozonation, and ultraviolet (UV) light. The other 35.7 percent of small-pack bottlers draw their water from other sources such as springs, aquifers, and wells.

bottling spring water from protected underground aquifers or producing high-quality purified bottled water from a municipal source, the water enters the bottling plant where it undergoes several treatments to ensure the finished product meets FDA’s bottled water standards. As mentioned previously, those treatments can include reverse osmosis, distillation, micro-filtration, carbon filtration, ozonation, and UV light. The finished water product is then placed in a bottle under sanitary conditions and sold to the consumer.

What are the different types of bottled water? To quench their thirst, consumers can choose from several different types of bottled water: spring water, purified water, mineral water, sparkling water, artesian water, and well water. IBWA provides a helpful breakdown of what each type of water is and where it is sourced at www.bottledwater.org/types.

How is bottled water tested? Virtually all bottled water facilities test their water multiple times every day in order to ensure the safety of their products. Bottled water is required to be tested up to 36 times more often than tap water on a gallon-for-gallon basis. In addition to the bottlers’ testing, FDA may enter the plant and collect samples for testing at any time, whether for cause or during a routine inspection.

How is bottled water bottled? Bottling water is a complex process. First, the water is drawn from a source approved by the U.S. Food and Drug Administration (FDA). Whether 16



For more information about bottled water testing, visit www.bottledwater.org/ education/bottled-water-production/

How is bottled water regulated? Many people mistakenly believe that bottled water is less regulated than tap water, but that simply is not true. Tap water is regulated by the Environmental Protection Agency (EPA). Bottled water is considered a food product and, as such, is regulated by FDA. By federal law, FDA regulations governing the safety and quality of bottled water must be as stringent as the EPA regulations that govern tap water. And, in some cases (such as lead), the FDA bottled water regulations are more stringent. In fact, bottled water is one of the most highly regulated packaged food products. Water bottlers must meet current food good manufacturing practices (GMPs) and specific bottled water GMPs, in addition to standards of identity (SOIs) and standards of quality (SOQs). Bottlers also provide sanitary facilities and operations, and maintain the required labeling standards and quality production controls and processes. Bottled water facilities and products are also inspected by FDA and/or state regulatory agencies. In addition, IBWA member bottlers must meet IBWA Bottled Water Code of Practice standards, which is verified by annual plant inspections conducted by an independent, third-party food safety organization. Read more about the way bottled water is regulated at www. bottledwater.org/education/regulations. What is all that information on the labels? Bottled water is considered a packaged food product. As such, bottled water is regulated by FDA and must comply with the FDA’s extensive labeling requirements. Bottled water labels must include what type of water is in the container; the name and place of business of the manufacturer, packer or distributor; and net weight. All bottled water products also have contact information (e.g., phone number and/or

In addition, IBWA’s website has a searchable tool listing IBWA member company bottled water brands, and contact information is provided for those interested in receiving water quality information. Check it out at www. bottledwater.org/bottled-water-brands. But isn’t bottled water really just “tap water in a bottle”? This is a common criticism of bottled water because many bottlers draw their water from the same public water systems that provide tap water. But no matter what its source, bottled water is not the same as tap water. The difference comes in the way that the water is treated and delivered. Bottled water products are produced utilizing a multi-barrier approach, from source to finished product, that helps prevent possible harmful contaminants (physical, chemical, or microbiological) from adulterating the finished product as well as storage, production, and transportation equipment. Measures in a multi-barrier approach may include source protection, source monitoring, reverse osmosis, distillation, micro-filtration, carbon filtration, ozonation, and UV light. Many of the steps in a multi-barrier system may be effective in safeguarding bottled water from microbiological and other contamination. Piping in and out of plants, as well as storage silos and water tankers, are also protected and maintained through sanitation procedures. In addition, bottled water products are bottled in a controlled, sanitary environment to prevent contamination during the filling operation. Tap water, on the other hand, must travel through miles of often aging pipes to reach homes and business, so it requires chlorination and other disinfectants to ensure it is potable. In addition, chlorination and pipe conditions can affect the taste of tap water.

Why do bottled water companies use plastic bottles as packaging? FDA regulates bottled water as a packaged food product and, for bottled water and all other foods and their packaging, the agency has determined that polyethylene terephthalate (PET) and polycarbonate (PC) plastics meet standards for food contact materials. Bottlers opt to use PET and PC plastic for their containers because they are strong and will not create a hazard if damaged. PET and PC plastics are also easy to mold, which allows bottlers to vary the shapes and sizes of their bottles more efficiently. In addition, PET bottles can be “light-weighted,” which means they require less plastic to make, less energy to transport, and are 100 percent recyclable. We should note that in addition to PET and PC plastics, many bottlers opt to package their water in glass, aluminum cans, and paper cartons. All of which have been deemed safe for food contact by FDA. Don’t plastic chemicals migrate into the water? This is another popular myth that just doesn’t hold water. Bottled water is a packaged food product regulated by FDA, which means that its packaging must be made from materials approved for food contact. The containers used for bottled water products are made from the same plastic materials used in other food product containers and have undergone scientific testing and intense FDA scrutiny. That review includes assessing the migration or potential migration of plastics and substances within plastic into liquid contents, and FDA has determined that PET and PC containers do not leach harmful amounts of substances into their contents. And yes, the safety of these plastics holds up—even if subjected to a hot car (as noted by FDA) or frozen in a freezer (according to experts at the Johns Hopkins Bloomberg School of Public Health).

For more information about the differences between bottled water and tap water, visit bit.ly/ SmallWaterUser.


website address) to allow consumers to get additional details about the water that might not be on the label.

Learn more about PET and PC plastic, the truth about bisphenol A (BPA), and the safety of bottled water containers at www.bottledwater.org/health/containersafety and bit.ly/FoodSafetyMag_bwplastics. Why does water have an expiration date? How can water go bad? FDA does not require an expiration date for bottled water products because it has determined that there is no limit to the shelf life of bottled water. Because it is packaged under sanitary conditions, is in a sealed container, and does not contain substances that cause food spoilage, bottled water can be stored for extended periods of time without concerns. Some companies place date-based lot codes on bottled water containers, which are typically used to assist in managing stock rotation at distribution and retails points. Like other beverages packaged in plastic, bottled water should be stored in a cool, dry place away from chemicals. More information about bottled water expiration dates and proper storage can be found at www.bottledwater.org/education/bottled-water-storage.

Environmental Concerns Why do some people claim bottled water is bad for the environment? Anti-bottled water activists claim that bottled water is clogging up U.S. landfills and draining U.S. water supplies. But according to independently produced EPA data, this just isn’t true. Bottled water containers account for less than 0.03 percent of the U.S. waste stream, and bottled water production accounts for less than 0.02 percent of the total groundwater withdrawn each year. NOV/DEC 2017



You can get the facts about the bottled water’s environmental footprint at bit.ly/BW_Footprint. Since 2000, bottled water packaging weight has been reduced by more than 51 percent. Those light-weighting efforts mean that bottled water containers take less plastic to make and less energy to transport than any other packaged beverage. PET plastic bottled water packaging makes up less than 1 percent of all the plastics produced in the United States, and all bottled water containers are 100 percent recyclable. What about all those plastic bottles that end up in landfills? Measured in tons of landfill space, PET plastic bottled water containers make up just 3.3 percent of all beverage containers that end up in landfills. Waste percentage numbers are much higher for glass (66.7 percent), aluminum (7.9 percent), and plastic soft drink bottles (13.3 percent). The problem is, despite the fact that all plastic bottled water containers are 100 percent recyclable, only 33.4 percent are actually recycled. However, bottled water's recycling rate is higher than the general rate for PET, which stands at 30.1 percent. In addition, bottled water remains the No. 1 item in curbside recycling, at 53.1 percent. The low recycling rates are an alarming trend that extend well beyond bottled water—more than 70 percent of what Americans throw away is actually recyclable. While the concern about bottled water containers ending up in landfills is valid, this is not a “bottled water issue.” This is a recycling issue that extends to all food and beverage packaging, as well as countless other recyclable products that end up in the trash. 18



To learn how plastic water bottles can be put to good use through recycling, watch bit.ly/RecyclingEmptyPlasticBottles. What are the water-use and energyuse ratios for bottled water? IBWA commissioned a study to be conducted by Antea Group, an independent thirdparty consultant, to determine the water and energy use of the bottled water industry in the United States. The results showed that, even though it is the most-consumed packaged drink in America, bottled water has the smallest water and energy use footprint of any packaged beverage. On average, 1.32 liters of water (including the liter of water consumed) and 0.24 mega joules of energy are used to produce 1 liter of finished bottled water. Other packaged beverages, such as soft drinks, sports drinks, juice, tea, and beer, use much larger amounts of water and energy to produce because of higher intensity processes like flavor mixing, blending, carbonation, fermentation, etc. To learn more about bottled water’s environmental impact, visit bit.ly/BW_ WaterEnergyUseRatio. What are bottled water companies doing to protect the environment and improve recycling? Bottled water companies actively work to protect the environment and promote comprehensive groundwater management and recycling practices. Even though it is a small groundwater user, the bottled water industry has been instrumental in encouraging states to develop comprehensive, sciencebased groundwater management and sustainability policies and laws. Although bottled water is just one of thousands of food and beverage products packaged in plastic containers and bottled water containers make up less than one-third of 1 percent of the solid waste stream in the United States, bottled water companies continue to play an important role in promoting the recycling of all consumer goods—not just bottled water.

IBWA members work with legislators, regulators, civic leaders, recycling advocates, and others to support legislation and initiatives that improve curbside recycling efforts and increase recycling at parks, sporting venues, other on-the-go locations, and in the home and office. Visit www.bottledwater.org/content/recyclingand-environment and www.bottledwater. org/education/recycling to learn more about IBWA and bottled water industry efforts to protect the environment. If bottled water is a sustainable industry, then why is there so much opposition to it? Bottled water is consistently singled out from other packaged beverages because water is also available from the tap. But this argument fails to consider that most consumers drink both bottled and tap water and assumes that safe, potable tap water from a clean, appealing source is readily available wherever consumers go. While bottled water is but one of thousands of packaged beverage options available to consumers, it is by far the healthiest choice for both their bodies and the environment. What’s the truth behind the news that bottled water has been banned from being sold on college campuses, in national parks, and even in whole towns or cities? In a handful of places, bottled water sales bans were introduced with the intention of protecting the environment by getting rid of bottled water—even though it has the smallest environmental impact of any packaged beverage and is the No.1 item in curbside recycling. As a solution, these bans promoted the use of reusable drink containers and refill stations. Yet, this is just another example of activists singling bottled water out from other packaged beverages. Although these bottled water sales bans were established to reduce plastic waste, the schools or parks or small towns that banned bottled water sales still allowed consumers to buy other goods packaged

Refill stations are a wonderful addition to any public space, but they do not help consumers who didn’t know to bring a reusable water bottle or perhaps forgot theirs at home—or have medical conditions that preclude them from drinking tap water. However, that same consumer who forgot his or her reusable water bottle can walk into any store on that campus or at that park or in that town and choose from a wide variety of other less healthy drinks packaged in plastic bottles—beverages that took more water and energy to produce and transport, beverages that created more carbon emissions during production, beverages that contain more plastic in their packaging, beverages that have a lower recycling rate for their containers. But they can’t buy bottled water. A study of a bottled water sales ban at the University of Vermont showed how such bans are actually counterproductive, resulting in an increase of plastic waste and consumption of sugary beverages. Is it really a better choice for consumers to purchase soda or sports drinks instead of bottled water? The answer is No—from both an environmental and health perspective. Bottled water has the smallest environmental


in plastic, including sodas, sports drinks, teas, milk, beer, and wine. All of those products could still be purchased in plastic, glass, cans, and cardboard containers—but bottled water in plastic containers was not available. On August 16, 2017, the National Park Service (NPS) issued a press release stating it had rescinded its 2011 policy that allowed individual parks to ban the sale of bottled water to “expand hydration options for recreationalists, hikers, and other visitors to national parks.” NPS also stated that it chose to rescind this policy after noting that “the ban removed the healthiest beverage choice at a variety of parks while still allowing for the sales of bottled sweetened drinks.”

For details on why the NPS's recently rescinded bottled water sales ban policy was unwarranted, visit www.bottledwater.org/ public/Advocacy.pdf. footprint of any packaged beverage. It is also the healthiest drink option, containing no calories, sugars, artificial dyes or sweeteners, caffeine, or alcohol. So, it's important that bottled water remains available where other packaged beverages are sold. Is bottled water expensive? As with any packaged beverage, bottled water is available at various price points, depending on where you buy it. Consumers who buy in bulk from a grocery store will pay far less for their bottled water than consumers who purchase bottles individually at convenience stores or from vending machines. According to BMC, the average wholesale price per gallon of domestic non-sparkling bottled water was $1.11 in 2016. To read more about the price of bottled water, visit www.bottledwater.org/economics/real-cost-of-bottled-water.

Consider the Source Your current and prospective customers may ask why they should believe these

facts from the International Bottled Water Association. IBWA is the authoritative source of information about all types of bottled waters and has been since 1958. This organization does promote bottled water, but its activities also promote the interests of consumers by requiring additional inspections of its members’ facilities, opposing new taxes on bottled water, and fighting bottled water bans that take away the consumer’s right to choose bottled water as a healthy alternative to packaged beverages that contain calories, artificial flavors, dyes, sugar, or caffeine. Unlike much of the anti-bottled water material on the internet, which is often incorrect or misleading, information produced by IBWA is fact-checked and reviewed for accuracy. And to provide credibility, IBWA links to independent, third-party sources to ensure that the information it publishes is true.

Kim Wheeler recently held the position of communications coordinator at IBWA. NOV/DEC 2017



No Off-Season for State Legislatures By James Toner, IBWA Director of Government Relations

As the famous quote from legendary New York Yankees Coach Yogi Berra goes, “It ain’t over til it’s over.” That sentiment is definitely true about state legislative sessions. Envision this: you’re a state legislator and the hours and minutes are ticking away, bringing closer the time to adjourn from another raucous session at the state house. You can hardly wait until the break. But guess what…it really never comes. It was normal 15, even 20, years ago for part-time state legislators to take a significant break once the gavel sounded to end a legislative session. However, today the term “part-time legislator” is a misnomer. Only a 20



handful of states have legislatures that meet throughout the year; however, that doesn’t mean that members of part-time legislatures are sitting around waiting for the next session to begin. The limited time allocated to a part-time legislature means that the interim period is all about addressing issues and teeing them up for the coming session.

Studies and Commissions and Task Forces, Oh My! Getting real work done on complicated issues is a difficult task during a state legislative session. Lawmakers are

bombarded by constituents vying for their attention, which makes diving into a weighty issue—while juggling interests in a dozen other issues—nearly impossible. Oftentimes, more substantial issues that require extra time for review will be deferred to a working group during the interim session. Interims, which can be of varying lengths, are a time for lawmakers to focus on specific issues important to them. Most interim workloads are set prior to the end of a regular legislative session. For those of us who closely follow session activity, this means we are not surprised by what is planned for review


IBWA MUST CONTINUE TO GET A SEAT AT THE TABLE TO ENSURE OUR PERSPECTIVE IS HEARD. during the “off-season.” Whether interim work consists of a study or a task force, there is often a seat at the table for both private and public entities. This is one advantage of the interim session: during these breaks, we are able to work handin-hand with lawmakers, which trumps only being able to testify on a bill during legislative sessions.

Off to Work We Go Working groups that meet during interim periods usually have opportunity to hear testimony—and they may even attempt to flush out a compromise on any given issue. Do all of these groups come up with equitable solutions? No, but failure to do so gives legislators an idea of how difficult it could be to pass meaningful legislation that doesn’t have unified support after interim activity. Often working groups, workshops, or hearings are held in various locations throughout the state. Those events provide local citizens a great chance to have their voices heard on issues that are important to them. After those hearings, open forums, and comment and rebuttal periods, the legislative group will hash out a proposal. Such proposals vary in scope, size, and detail— and they may or may not accommodate the issue needs originally identified (which motivated the forming of the working group in the first place). Input from the private sector and local citizens is key in moving a proposal forward with the hope that something meaningful will be discussed in a future legislative session. But not all interim work looks forward. Some groups are formulated to review past legislative or regulatory

work. Measuring successes and failures and determining what, if any, changes might be put in place to better address an issue, is an important task that helps ensure the productiveness of the next legislative session.

A Place for Industry So, where does the bottled water industry fit into this equation? What role can we play in helping to determine favorable outcomes? As IBWA has done in the past, we must continue to get the bottled water industry a seat at the table. If possible, during the formation of an interim committee or study group, IBWA will seek opportunities to ensure

an industry representative can be part of the group. At the very least, we will be available and ready to provide testimony and data to support an issue or stance. At the local level, we encourage IBWA members to be involved. As a business that is in tune with the local needs and concerns, you can provide great insight at listening events. Finally, there is one interim event that impacts every elected official: Election Day. In an election year, you can pretty much expect limited interim work and a strong focus on campaigning and fundraising. During election years, you rarely see sessions go into overtime. Lawmakers want every day possible to be on the campaign trail because it is getting harder for them to raise money, have their issues heard, and claim that coveted “legislator” title. So, whether it is an interim period or a campaign season, there are multiple opportunities to have an impact on future legislative issues even before the first day of a new session.

Learn More Want to know more about what is happening in the state legislatures? IBWA members have exclusive access to iStateLink, a state legislative and regulatory tracking database provided by Stateside Associates. In any given year, IBWA monitors nearly 800 pieces of legislation and another 400 regulations that could impact the bottled water industry. iStateLink allows you to sort items by state, topic, or status; get detailed synopses of bills and regulations, as well as links to the actual materials; track the history of any item; read insightful outlooks on potential future action; discover who supports or opposes a proposal; and find out what the state requirements are for moving a bill or regulation forward. With this unique database, IBWA members can also leave comments on any bill or regulation, see an interactive map of currently active items, and run various reports on legislation and regulations. If you are interested in getting access to this members-only resource, please contact IBWA Director of Government Relations J.P. Toner: 703.647.4616 or jtoner@bottledwater.org.

NOV/DEC 2017



Why Visuals Work “Show don’t tell” is the name of the social media game By Jill Culora, IBWA Vice President of Communications

The old adage “a picture is worth a thousand words” could not be any truer in today’s digital age. Everyone from toddlers to aging boomers lose patience if it is necessary to wait more than five seconds for a webpage to load—and if they have to read more than one short sentence to discover the information they’re searching for, the likelihood is high that they’ll move on to another webpage. For this reason, visual communication is becoming more important than words, mainly because information-saturated consumers can more quickly determine the material’s relevance to them. Think about it. When you scroll through your newsfeeds, you stop at images that catch your eye. Headlines, captions, and text are secondary to 22



the overwhelmed reader. Visually rich social media channels, such as Instagram, Pinterest, and Snapchat, together with digital slideshow stories, used by bloggers and traditional media alike, have taught us to discern and consume information at lightning speed—and settle for nothing less. So, what does this mean for marketers and communicators? We need to understand this evolution and change the way we create our business communications materials.

The Power of Visuals Graphics, diagrams, charts, and images can tell stories that simply take too many words to convey in text. Which makes sense because our

brains are wired to process images far faster than words—60,000 times faster. Modern-day consumers searching for information have neither the time nor the willingness to read long-winded communication/marketing materials. Text-heavy flyers, posters, and email correspondence fall in the category of TL;DR (Too Long; Didn’t Read). Having staff create wordy promotional materials is a waste of time and effort. Consumers want to know at a glance whether the information is something they need to know, and they can’t make this quick decision when they’re searching through three paragraphs of running text searching for an answer— so, your collateral gets designated as TL;DR.

COMMUNICATIONS Visuals can also be stronger than words in their ability to convey feelings—such as humor, well-being, or happiness—instantaneously. When a consumer can see himself or herself in an image, the meaningfulness of your message is amplified. That’s why marketers use images of middle-aged women with children to target the “mom” audience, which, as Harvard Business Review points out, is an important target because 73 percent of American women make the purchasing decisions for their households (hbr.org/2009/09/ the-female-economy). Marketers also use images that attract the attention of moms, which is something staff kept in mind when creating IBWA’s summer social media campaign: “Bottled Water: Where You Live, Work, and Play.” Analytics from the campaign’s Facebook ads showed that the poster with a friendly home and office delivery (HOD) sales representative was overwhelmingly popular with women (see image at left). A deeper dive into the analytics showed that while the ad “reached” many more women than men (65 percent vs. 35 percent), it is in the ad “engagement”— the likes, comments, and shares—where women really pulled ahead, with 73 percent engaging with the ad compared to men at 27 percent. Also, proportionally, older women were more apt to engage; younger women engaged the most, but at a lesser rate. Creative types at bottled water companies may find that images simply don’t exist for the messaging they want to convey; thus, you may need to create your own visuals. We’re experiencing this more and more at IBWA in our efforts to set the record straight on a multitude of issues facing the bottled water industry. Our target audiences are increasingly using social media as a main source for news and information, so IBWA displays our materials alongside other items cluttering up a person’s newsfeed. We’re mindful of that, so for our materials to been seen, we must stand out amongst the other posts.

Sometimes an appropriate image does not exist for the message you want to promote. When that happens, consider hiring an illustrator. IBWA’s illustrator created this image to portray the fact that many industries purchase water from municipal water systems.

We need those likes, comments, and shares to boost our organic reach.

Starting From Scratch IBWA staff tries our best to choose images wisely (and within budget), purchasing from stock image websites. But sometimes an appropriate image doesn’t exist or the message we want to convey is challenging to illustrate. This was the case in pulling together IBWA’s Plant Siting and Permitting Social Media Toolkit. We had a number of issues we needed to address that couldn’t be properly depicted with a single photograph. When that happens, it’s time to consult with a graphic designer or illustrator to discuss ways of visually representing your messaging. In our case, we decided

on illustrations (such as the one above) that can convey a lot of information at a glance. We expect these visuals will have no problem standing out amongst the other posts in peoples’ newsfeeds. As technology continues to rapidly improve, peoples’ attention spans are set to become even shorter and more complex. As communicators, being innovative with our marketing strategies requires continual observation, analysis, and learning—not to mention being nimble enough to make adjustments to the tools, channels, and approaches we use to reach consumers. If we ignore this evolution, our messages will just be digital text clutter lost among the glitzy images grabbing our reader’s attention. NOV/DEC 2017



What FDA’s Revised Labeling Regulations Mean for Bottled Water By Bob Hirst, IBWA Vice President of Education, Science, and Technical Relations

In May 2016, the U.S. Food and Drug Administration (FDA) released sweeping revisions to its regulations for nutrition and supplement facts labels and serving sizes. The proposed revisions included mandatory declaration of sugars, a revised definition of dietary fiber, and new serving size and dual column labeling requirements. In light of revisions to serving sizes and daily values, the changes will make it necessary for some foods to reevaluate whether they still qualify for nutrient content and health claims. The effective date for the revised rules was originally proposed for July 26, 2016. Compliance date for large manufacturers was set at two (2) years after the effective date, or July 16, 2018. For manufacturers with less than $10 million in annual food sales, the compliance date was three (3) years after the effective date, or July 26, 2019. However, FDA proposed an extension on October 2, 2017. Under the proposed rule, the compliance date would be extended by about 18 months– 24



from July 26, 2018 until January 1, 2020 for large manufacturers and from July 26, 2019 until January 1, 2021 for manufacturers with $10 million or less in annual food sales. There are a number of impacts to bottled water that require the bottler’s attention, most specifically sodium claims on the label and how fluoride content is expressed on the label.

RACCs and Sodium Currently, the Reference Amount Customarily Consumed (RACC) is 8 ounces. Based on this 8-ounce serving, bottled waters with less than 5 milligrams (mg) of sodium per 8-ounce serving can be labeled as “sodium-free.” With an increase in the RACC under the revision to 12 ounces, a 50-percent increase in serving size, there may be an impact on the amount of sodium per serving that can be claimed. For example, if a bottled water currently contains 4 mg of sodium for an 8-ounce serving, it can be labeled as

“sodium-free” because it contains less than 5 mg per serving. However, if you increase the amount by the same 50 percent, the new amount per serving size is 6 mg per serving, which now exceeds the limit of 5 mg per serving under the current definition of “sodium-free.” IBWA, as well as many other food manufacturers, submitted comments to FDA on the adverse impacts this will have on nutrient claims. FDA has stated that it will assess whether other changes in its nutrient claim regulations are needed. It will address those issues separately in future rulemakings, as time and resources permit. In the meantime, FDA will exercise enforcement discretion on sodium claims, so bottlers will be permitted to continue current practice until the nutrient claims issues are addressed by FDA.

Fluoride The revised regulations included changes to the way bottlers label fluoride content in their products. The revised

TECHNICAL UPDATE rule allows for fluoride content to be declared on the label voluntarily. However, IBWA submitted comments to FDA after the initial proposed revised rule to suggest changes to the way in which fluoride is claimed on the label. IBWA stated that two refinements of the rule were warranted: 1. The amount of fluoride should be declared in milligrams per liter (mg/L) rather than in mg per serving, consistent with current practice and in accordance with policies for fluoride in drinking water as established by the Centers for Disease Control and Prevention (CDC) and the American Dental Association (ADA). Both the CDC and ADA have established 0.7 mg/L as an optimum level of fluoride in drinking water. However, the FDA revision included a formula for calculating the amount of fluoride in water, which would be required to be included on the label if a fluoride claim is made. The result of the calculation for some fluoridated bottled waters would require that the bottler not make a content claim if the amount is below 2 mg/serving. A 4-ounce bottle of fluoridated water containing 0.7 mg/L of fluoride would contain <2 mg/12-ounce serving, and the result would be a declaration of 0 mg/serving. 2. The inclusion of a statement about fluoride content in the statement of identity (e.g., “purified water with fluoride added”) under the bottled water standard should not be treated as a fluoride “claim” that triggers mandatory nutrition labeling, so long as the amount of fluoride is otherwise declared on the label. Moreover, when fluoride is added to bottled water, standard practice within the industry is that fluoride content is generally declared on the label in mg/L; although not as part of the Nutrition Facts Panel (NFP). Many bottled waters are exempt from the nutrition labeling requirements under

21 C.F.R. § 101.9(j)(4) because they contain insignificant amounts of all of the nutrients and food components required to be declared in the nutrition label. If the statement “with added fluoride” as part of the common or usual name triggered mandatory nutrition labeling, this would mean that bottled water labels that are currently exempt from nutrition labeling would now be required to include an NFP simply to provide the information on fluoride content, which is currently being declared elsewhere on the label. To avoid these potential inconsistencies in the units, IBWA plans to submit a letter to FDA requesting an exemption from the need to provide an NFP in this situation. FDA staff have indicated a willingness to grant IBWA’s request if the fluoride level meets federal recommendations of 0.7 mg/L and the label claim states that fact. The following two FDA policies will need to be addressed: • FDA recommends bottled water manufacturers do not exceed 0.7 mg/L fluoride. • The compliance standard for added nutrients requires at least 100 percent of the declared value. In the case of bottled water, that means the product would need to contain the full 0.7 mg/l of fluoride. To be in compliance with both, companies would need to have exactly 0.7 mg/L, which is not practical. Therefore, IBWA has proposed the following next steps: • Ask FDA to allow products with between 0.6 and 0.8 mg/L to qualify for the requested NFP exemption. • Ask FDA to agree that “up to 0.7 mg/L” claims are allowed if the levels are at least 0.6 mg/L.

Calorie Labeling Currently, bottled water products with a zero-calorie declaration on the front label are required to have a full NFP that would contain all zeros.

IBWA petitioned FDA to allow the following abbreviated label statement instead of an NFP under 101.9(g)(9): “For nutrition information, call [insert phone number].” FDA has issued a letter to IBWA recognizing this alternate means of compliance, provided the following specific criteria are met: • The label bears the statement “For nutrition information, call [insert phone number].” • The product is subject to the FDA Standard of Identity (SOI) for bottled water. • The product is otherwise exempt from nutrition labeling. • The product bears no other nutrient claims or information. • The company and brand name were submitted to FDA as part of the IBWA list. Companies not on the IBWA list will need to submit their own requests. (For more information on this, IBWA members can refer to the April 27, 2017 Splash e-newsletter.)

“Healthy” Claims FDA opened a docket for comments on “healthy” claims. IBWA submitted oral and written comments supporting FDA steps to revisit the “healthy” definition to include bottled water. IBWA’s justification to FDA included a claim that bottled water helps consumers maintain healthy dietary practices: • IBWA cited dietary guidelines and other government statements. • Water is also a healthy alternative to sugar sweetened beverages. • IBWA asked FDA to create an exemption from beneficial nutrients criteria. IBWA recently submitted a letter to FDA seeking enforcement discretion in the interim, and we are in process of scheduling a meeting with FDA to discuss that request. NOV/DEC 2017





certified plant operators (CPOs) are encouraged to complete the following quiz for ½ IBWA continuing education unit (CEU). The questions are derived from material presented in this issue of the Bottled Water Reporter, the IBWA Plant Technical Reference Manual, and the IBWA Bottled Water Code of Practice. Submit this quiz to Claire Crane (ccrane@bottledwater.org / Fax: 703.683.4074), IBWA Education and Technical Program Coordinator, 1700 Diagonal Road, Suite 650, Alexandria, VA 22314. Look for additional quizzes in future issues and earn additional IBWA CEUs!


Company_ _________________________________________________



State/Province_ _____________________________________________

ZIP/Postal Code_ ___________________________________________

Check your selection for each question


Under FDA’s revised nutrition labeling regulations, the RACC for bottled water will be _____.


8 ounces 16.9 ounces 12 ounces 500 ml


A common nutrition statement currently included on many bottled water labels will be affected by a change in the RACC. That nutrient is _____.


Sodium Potassium Calories Vitamin C


FDA’s current final nutrition labeling rule will require that fluoride content be expressed in _____.


mg/L ppm mg/100 mL mg per serving


Currently, a “0 Calorie” statement on the label of a bottled water will require a _____.


Nutrition Facts Panel Results of analysis for calorie content Warning statement List of ingredients


IBWA has petitioned FDA to allow an abbreviated label statement instead of an NFP under 101.9(g) (9): “For nutrition information, call [insert phone number].”

OO True OO False


In lieu of labeling a product as containing EXACTLY 0.7 mg/L, IBWA has proposed to FDA that _____ be permitted.

OO Label the product as “containing approximately 0.7 mg/L of fluoride.” OO The product will contain between 0.6 and 0.8 mg/L of fluoride. OO A label stating that the product contains 0.7 mg/ serving. OO None of the above.


The current best estimate of a compliance date extension for FDA’s revised nutrition labeling regulations is _____.



For bottled water, will the label be able to claim “sodium free” after the compliance date for new RACCs?

OO Yes OO No


If the RACC for a bottled water is increased by 50 percent, the sodium content in mg per serving will _____.




Not change Increase by 100 percent Decrease by 50 percent Increase by 50 percent


The following organizations have recommended 0.7 mg/L as an optimum level of fluoride in drinking water (pick all that apply):


July 26, 2018 January 1, 2020 July 26, 2019 January 1, 2018



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WE'RE NO.1 IN 2017, BOTTLED WATER WILL SOFT DRINKS OUTPACE AS THE NO. BEVERAGE 1 IN THE UNITED PACKAGED STATES. Now is the time to ensure your is a part of that success—no business to plan your w is the time advertising campaign with International the Bottled Water Association, authoritative the voice on all issues concerning the bottled water industry.



Annual Business IBWA Conference and Trade Show Gaylord Texan Resort Grapevine, TX CALENDAR 2018

JUNE 4-7

IBWA June Board of Directors and Committee Meetings Hilton Old Town Alexandria, VA


IBWA Annual Business Conference and Trade Show Hyatt Regency New Orleans, Louisiana


JUNE 3-6

IBWA June Board of Directors and Committee Meetings Hilton Old Town Alexandria, VA


NOV/DEC 2017



VALUE OF IBWA MEMBERSHIP JEAN VALVIS OWNER AND FOUNDER AQUA CARPATICA ROMANIA ALL ABOUT JEAN Jean earned an architect-engineer degree from the National Technical University of Athens and an Advanced Graduate Diploma in Architectural Aesthetics from the University of Paris, Pantheon Sorbonne. He has lived in Greece, Switzerland, and Romania. Jean also heads the Valvis Foundation, which supports many charitable organizations and community programs for disadvantaged children.

While an engineering consultant in Romania in 1992, Jean Valvis stopped at a restaurant where he enjoyed what he later realized was a life-changing drink of bottled water. He was always a bottled water enthusiast—but he didn’t expect what was coming that day. Jean had a bottle of natural sparkling mineral water, and that moment led him down the path to entrepreneurship and starting his own bottled water business. Today, Jean is the owner and founder of AQUA Carpatica, an independent, Romanian-based bottled water company whose source is located in the Carpathian Mountains. Founded in 2011, AQUA Carpatica joined IBWA last year. Jean said his organization has benefited greatly from its membership. “This association represents a lot for us,” says Jean about IBWA. “We receive a huge amount of information about [industry] issues. We know what the issues are in the United States, the strategies of the industry . . . I’m happy that we can receive all the campaigns that are done by IBWA, and I’m happy to be a member of this association.” Jean adds he appreciates that IBWA, while U.S.-based, also delivers bottled water information on global issues and perspectives, which helps other countries understand that the perception of bottled water varies around the world. IBWA’s offerings also help Jean and his company connect with other IBWA members and strengthen their relationships with each other. AQUA Carpatica’s slogan is “experience waterlove,” which Jean characterizes as “the condition when you love the clean taste of refreshing water, but the water also takes care of you. It’s water that loves you back. “Our efforts are to prospect the best natural springs, and to provide to people and the consumers nature’s best mineral and spring water,” says Jean. “This is where we focus— to find what is already provided by nature, which has natural electrolytes, alkaline, and doesn’t have nitrates, sodium, and has an excellent taste.” In addition to AQUA Carpatica, Jean also owns a wine company, Domeniile Samburesti. He first ventured into bottled water in 1994 with a mineral water company called Dorma, which he sold to Coca Cola in 2002. He also once owned a dairy company called LaDorna, which he sold to Lactalis in 2008. To learn more about AQUA Carpatica and its products, visit www.aquacarpatica.com.




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