Bottled Water Reporter

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


IN THIS ISSUE Advocacy Has Never Been So Easy (or Competitive)

Keeping Water Tips for Answering Coolers in the Consumers' PFAS Workplace During Questions COVID-19



Also Inside:

Is the Available Supply of rPET and rHDPE Enough to Meet Demand? Americans' Favorite Packaged Beverage Continues to Be Bottled Water A PUBLICATION OF THE INTERNATIONAL BOTTLED WATER ASSOCIATION

VOL. 60 • NO. 6


24 | Politics and Advocacy in the Post-Pandemic World Getting involved in the political arena has never been easier—or more competitive. COMMUNICATIONS

26 | Tips for Answering Consumers' PFAS Questions PFAS is a complex topic. IBWA insights will help prepare you for any consumer questions on these emerging contaminants. TECHNICAL UPDATE

28 | IBWA Ensures Bottled Water Remains Healthy Hydration Option During COVID-19 Learn the actions IBWA took to help ensure water coolers remained in the workplace during the health crisis. BY THE NUMBERS

32 | Bottled Water Volume to Increase in 2020 Despite the challenges industry encountered due to the COVID-19 health crisis in 2020, bottled water will continue to be America's favorite packaged beverage.

TABLE OF CONTENTS 10 | Realities of Recycled Content

CHAIRMAN'S COMMENTARY ...............................2 PRESIDENT’S MESSAGE ......................................4

California has set a recycled content mandate, and other states may soon follow suit. But will there be enough postconsumer recycled plastic available to meet current and future demands for this valuable resource? This article investigates the complexities of the issue. By Christine Umbrell

WATER NOTES ....................................................6

17 | Learning During the Pandemic


What consumers should know about bottled water packaging In response to COVID-19, more people are working from home, and more food and beverages are being consumed at home. That means more recyclable "waste" is also being produced at home—which presents a great opportunity for IBWA members to educate consumers about the fact that bottled water containers are made to be recycled. By Chris Torres

CPO QUIZ .........................................................30 ADVERTISERS ...................................................31 CALENDAR .......................................................31

BOTTLED WATER REPORTER, Volume 60, 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, 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.


When I joined IBWA more than 25 years ago, I had no idea I would one day serve as chairman of the board. I originally joined IBWA because I wanted to grow my business—and, to do that, I needed a thorough bottled water education. After attending a couple of meetings, I began to feel comfortable around the other members, so I started getting involved, first by joining a few committees and then later participating in advocacy events at home and on Capitol Hill. It recently dawned on me that I am now one of the “elders in the industry,” in both age and years of service. For the past quarter of a century, I have been an active IBWA bottler member, helping the association in any way I can to promote the industry. I’ve observed the growth in bottled water consumption firsthand: watching it evolve from a product enjoyed by a few Americas to its current status as the No.1 packaged beverage in the United States. IBWA has played a crucial role in creating that bottled water success story. Through its dedicated members, highly qualified staff, and constructive partnerships, IBWA has helped to guide discussions on regulatory and legislative issues at both the state and federal levels. Without a doubt, IBWA’s efforts have helped to maintain a favorable business, regulatory, and public affairs climate for all IBWA members and the bottled water industry. As a child growing up in the rural south, I frequently heard my elders say, “I don’t know where this year went!” Indeed, 2020 has been an extremely busy year for the bottled water industry. In addition to the usual issues of taxes, sales bans, resource management, and recycled content mandates (just to name a few), we overcame new hurdles that the COVID-19 pandemic introduced and yet still remained a viable business. Being chairman of the International Bottled Water Association has been one of the highlights of my career. I want to take this opportunity to thank the members for electing me to this prestigious position and applaud Joe Doss for his excellent leadership of IBWA. It has been an absolute pleasure to work with Joe and every member of the Board of Directors and Executive Committee. I also want to thank the IBWA staff. In all my years in this industry, I have never worked with a group of individuals who are more dedicated and qualified than the staff we have at IBWA. As I prepare to pass the gavel to the incoming chair, I do hope we have many more years to work together, and I hope those years fly by as well. I know we will enjoy what we accomplish together. Until then!

Robert Smith IBWA Chairman 2 • BWR • WWW.BOTTLEDWATER.ORG


International Bottled Water Association OFFICERS Chairman Robert Smith, Grand Springs Distribution Vice Chair Tara Carraro, Nestlé Waters North America Treasurer Brian Hess, Niagara Bottling LLC Immediate Past Chairman Lynn Wachtmann, Maumee Valley Bottlers, Inc..

BOARD OF DIRECTORS Shayron Barnes-Selby, DS Services of America, Inc. Joe Bell, Aqua Filter Fresh, Inc. Philippe Caradec, Danone Waters of America Tara Carraro, Nestlé Waters North America C.R. Hall, Hall's Culligan Brian Hess, Niagara Bottling LLC Doug Hidding, Blackhawk Molding Co. Dan Kelly, Polymer Solutions International Kari Mondt, Allied Purchasing Greg Nemec, Premium Waters, Inc. Robert Smith, Grand Springs Distribution Lynn Wachtmann, Maumee Valley Bottlers, Inc. William Patrick Young, Absopure Water Co., Inc.

IBWA EXECUTIVE COMMITTEE Chairman Robert Smith, Grand Springs Distribution Shayron Barnes-Selby, DS Services of America, Inc. Joe Bell, Aqua Filter Fresh, Inc. Philippe Caradec, Danone Waters of America Tara Carraro, Nestlé Waters North America C.R. Hall, Hall’s Culligan Brian Hess, Niagara Bottling LLC Henry R. Hidell, III, Hidell International Dan Kelly, Polymer Solutions International Dave Muscato, DS Services of America, Inc. William Patrick Young, Absopure Water Co., Inc. Lynn Wachtmann, Maumee Valley Bottlers, Inc.

COMMITTEE CHAIRS Communications Committee Julia Buchanan, Niagara Bottling, LLC Maureen Hendrix, DS Services of America, Inc. Education Committee Glen Davis, Absopure Water Co., Inc. Douglas R. Hupe, Aqua Filter Fresh Environmental Sustainability Committee John Cook, Niagara Bottling LLC Government Relations Committee Viola Johnson Jacobs, DS Services of America, Inc. Derieth Sutton, Niagara Bottling LLC. Membership Committee Marge Eggie, Polymer Solutions International Kelley Goshay, DS Services of America, Inc. State and Regional Associations Committee Jillian Olsen, Cherry Ridge Consulting LLC Supplier and Convention Committee Joe Bell, Aqua Filter Fresh, Inc. Dan Kelly, Polymer Solutions International Technical Committee Glen Davis, Absopure Water Co., Inc. Ryan Schwaner, Niagara Bottling, LLC

Taking the industry from the modern world to the future


1 (800) 781-1680


Bottled water containers are made to be recycled. But the current recycling rate for PET bottled water containers hovers around 33 percent—and the overall recycling rate for every beverage container made from PET is even less: 29 percent. In this issue of Bottled Water Reporter, our cover story, “Realities of Recycled Content” (p.10), reviews some of the hurdles water bottlers encounter when trying to use recycled content. IBWA member bottlers are always on the lookout for ways to increase the use of recycled PET (rPET) and recycled HDPE (rHDPE) in their plastic containers, but those efforts are often thwarted due to a lack of available food-grade recycled content material. Because California recently became the first U.S. state to set a recycled content mandate—and we expect other states to follow suit—now is the time to make sure you understand the complexities of the issue. IBWA’s position has always been that we support reasonable recycled content mandates—but the task of getting government and industry to agree on a definition of "reasonable" might be a heavy lift. Bottled water drinkers are among the best recyclers—but to encourage our consumers to have even better recycling habits, our second feature “Learning During the Pandemic” (p.17), provides a few teaching aids. These days, COVID-19 is keeping us all closer to home—and our recycling bins—which provides a great opportunity for consumers to put any newly learned recycling knowledge to work. One way to help increase the supply of rPET and rHDPE is to ensure that every plastic bottle used is recycled. Like our consumers, elected officials also need to be kept up to date about recycling issues, and our Government Relations column (p.24) discusses how virtual meetings have made it easier than ever before to become an industry advocate. Legislators also have an interest in learning more about the effects of PFAS, a group of emerging contaminants. To help ensure accurate information is part of your PFAS messaging, our Communications column (p.26) provides a primer that members can use that states IBWA’s position. Finally, our Technical Update column (p.28) communicates to the membership the actions IBWA recently undertook to ensure the guidance recently published by the Centers for Disease Control and Prevention (CDC) on reopening businesses did not prevent water coolers from remaining in the workplace. This year has been challenging and unprecedented. I’m proud of how IBWA members and staff have been able to persevere and work to ensure that bottled water continues to be the healthy hydration option that consumers can depend on.


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

IBWA STAFF President Joe Doss Senior Vice President of Education, Science, and Technical Relations Robert R. Hirst Vice President of Communications Jill Culora Vice President of Government Relations Cory Martin Director of Conventions, Trade Shows, and Meetings Michele Campbell Director of Government Relations J.P. Toner Director of Science and Research Al Lear Director of Communications Sabrina E. Hicks Manager of Member Services Cheryl Bass Communications Coordinator Chris Torres Education and Technical Programs Coordinator Linda Alfakir Executive Assistant Vacant Bottled Water Reporter Layout and Design Rose McLeod Tel: 315.447.4385 Editor Sabrina E. Hicks

Joe Doss IBWA President


Advertising Sales Stephanie Schaefer






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2024. Penalties shall be assessed using the following formula: Total penalty = $0.20 x total postconsumer plastic* *Total postconsumer plastic = [(total amount of plastic used in pounds) x (compliance date %)] (amount of postconsumer plastic used in pounds)


California Establishes Recycled Content Mandate for Plastic Beverage Containers With the signature of Governor Gavin Newsom (D), AB 793 (Chapter 115) has become the first law in the United States to implement a state mandate on recycled content use for plastic beverage containers. After several years of work and a promising bill that was ultimately vetoed in 2019, this latest legislation garnered wide support and moved swiftly through the legislature, even with the difficulty of operating a legislative session amidst COVID-19. The new act, sponsored by Assemblymembers 6 • BWR • WWW.BOTTLEDWATER.ORG

Phil Ting (D) and Jacqui Irwin (D), not only makes California the first state to establish minimum recycled content requirements for plastic beverage containers but also makes California’s standards the strongest in the world. Beginning January 2022, manufacturers of plastic beverage containers that are part of the California Redemption Value (CRV), the state’s bottle deposit program, will be required to contain a minimum of 15% postconsumer recycled plastic. That amount

increases to 25% in 2025 and 50% in 2030. The adopted language does allow for the director of CalRecycle to adjust the 25% and 50% requirements if they are not achievable given the state of recycled material markets and the availability of postconsumer plastics and then adjust targets if necessary. Failure to meet those standards, which are measured in the aggregate, will trigger penalties that go into effect in 2023 and will be collected annually beginning on March 1,

Other important components of the law include annual reporting by plastic reclaimers in the state the amount in pounds and by resin type of empty plastic beverage containers subject to the CRV that the reclaimer has collected and sold in the previous calendar year. It also requires manufacturers of postconsumer recycled plastic to annually report to CalRecycle the amount of food-grade flake, pellet, sheet, fines, or other forms sold in the previous calendar year and their capacity to produce food-grade material. CalRecycle will also contract with a research university to study the PET and HDPE markets; that study is to be completed by May 1, 2028, based upon fund approval by the legislature. To review this legislation, visit Chap115. If IBWA members have any question, they can contact J.P. Toner, IBWA’s director of Government Relations:



IBWA Corrects Consumer Reports’ PFAS Article


principle, several state agencies have adopted tap water standards that range from 10 to 14 ppt for individual PFAS compounds. Some of those standards also apply to bottled water. Those state standards were based on recommendations from scientists and toxicologists. In the absence of federal requirements for PFAS, IBWA set stringent standards for PFAS, which all IBWA bottler members must meet. While not mandated by law, IBWA requires its members to test their bottled water products annually for PFAS, using the Environmental Protection Agency Method 537.1. IBWA has adopted a PFAS standard of 5 ppt for one PFAS compound and 10 ppt for more than one compound. IBWA’s requirement for member bottlers is more stringent than any current state or federal requirement. For tap water, EPA has set a “health advisory” limit for PFAS of 70 ppt [but that agency has not established a maximum contaminant level (MCL)].

Political Expert Charlie Cook Shares Election Intel With IBWA PAC

IBWA continues to encourage FDA to issue an SOQ for PFAS in bottled water. In late 2019, IBWA sent a letter to FDA with that request, and the agency responded, stating it would not issue a PFAS regulation at this time. FDA also said it believes that “establishing SOQs for PFAS in bottled water at this time would not significantly enhance FDA’s mission of public health protection.” However, FDA noted that it would continue to monitor any action by EPA on establishing PFAS MCLs for public drinking water. Under federal law, bottled water regulations must be as protective of the public health as tap water regulations. If EPA issues a PFAS regulation for tap water, FDA is required to review the EPA rule and determine its applicability to bottled water. For more information on FDA’s research and investigation of PFAS in foods and beverages, visit PFAS2020statement.

Charlie Cook

IBWA has had to once again call Consumer Reports (CR) to task for irresponsible journalism. In a recent article, “What’s Really in Your Bottled Water,” CR suggests that bottled water products with PFAS levels of greater than 1 part per trillion (ppt) pose a health risk. That recommendation is neither based on sound science nor supported by the U.S. Food and Drug Administration (FDA), which regulates bottled water as a food product and has not, as yet, issued a standard of quality (SOQ) regulation for PFAS. In addition, CR’s testing method can neither accurately nor reliably detect the amount of PFAS in bottled water. As a result, IBWA had to call out CR on this misleading reporting that only intends to frighten consumers unnecessarily. In our response to CR, IBWA noted that PFAS standards must be set at levels at which the substance can be reliably detected and the amount can be reported with a reasonable degree of accuracy and precision. Based on that

Charlie Cook, political pundit and founder, editor, and publisher of the non-partisan Cook Political Report, shared his insights on the 2020 election with IBWA members who participated in a recent IBWA PAC event. For almost 90 minutes, Cook detailed the information gathering process that forms his opinion on what to expect from the election process. Cook reviewed his thoughts on what polls are most accurate (those done by live interview telephone calls) and suggested that it is best to remove the highest and lowest outlier polls for any race to get the best snapshot of an election. He also noted that for Democrats to win a national election, they need to be polling at least 3 to 4 percent higher than the Republican candidate, as Republican votes are more efficiently spread across the country. Of note, Cook mentioned that the days of predicting election outcomes based on how well the economy is doing are over. Instead, he suggested that, in recent elections, people have put their support behind a candidate earlier and stayed with that candidate no matter what variables may come into play during the course of an election. Cook also noted that early voting has changed how candidates campaign. In the past, you could always expect an “October surprise,” or an issue that would arise late in the campaign that could be a boon for one candidate and potentially influence the outcome of the election. With early voting, anything announced in October may now be too late to dramatically influence the outcome. For more information about the IBWA PAC, visit or contact IBWA Vice President of Government Relations Cory Martin: NOV/DEC 2020 • BWR • 7



CDC Releases Data Brief on Nonalcoholic Beverage Consumption Among Adults

In September, the Centers for Disease Control and Prevention’s (CDC) National Center for Health Statistics (NCHS) issued a data brief, titled “Nonalcoholic Beverage Consumption Among Adults: United States, 2015– 2018,” which discusses the major role of beverages, including water, in meeting total water intake needs and their overall nutrient and caloric intake for the U.S. population. The 2015–2020 Dietary Guidelines for Americans recommend that water, fatfree and low-fat milk, and 100 percent juice be the primary beverages consumed. CDC’s report provides estimates of the contribution of beverage types to total nonalcoholic beverage consumption, by grams, for U.S. adults. Below are the data brief's key findings: • In 2015-2018, water accounted for more than one-half of total nonalcoholic beverage consumption (51.2 percent) among U.S. adults. • Compared with women, men consumed more coffee, sweetened beverages, and fruit beverages as a percentage of total beverage consumption, and less water and tea. • The contribution of water and sweetened beverages to total beverage consumption decreased with age, while the contribution of coffee, tea, milk, and diet beverages increased with age. • Water and tea consumption (60.7 and 13.6 percent, respectively) was highest among non-Hispanic Asian

adults, while coffee (17.3 percent) had its highest consumption percentage among non-Hispanic white adults. The NCHS report concludes that, “Beverages vary in their nutrient and calorie contents, and some beverages can contribute excess calories while supplying few or no key nutrients. The 2015–2020 Dietary Guidelines for Americans recommend consuming primarily beverages that are calorie-free or that contribute beneficial nutrients.” For a copy of this NCHS brief, go to products/databriefs/db376.htm. If you have any questions, please contact IBWA Director of Research Al Lear: alear@

Water, fat-free and low-fat milk, and 100 percent juice are the primary beverages recommended for consumption.



Beverage Industry Magazine Podcast Interviews IBWA President Joe Doss IBWA President and CEO Joe Doss was recently a featured guest on the “Sip & Learn” podcast series produced by Beverage Industry Magazine. During the "Bottled Water's Future" episode, Doss discusses what the bottled water industry is doing concerning the COVID-19 pandemic and its environmental sustainability efforts. To listen to the episode, visit




retain oversight of water sources. Currently, PA DEP regulates bottled water products in half-gallon or larger containers, while the PA DOA oversees products smaller than half-gallon. The bottled water industry supports these measures because PA DEP does not administer food safety standards and inspections in accordance with U.S. Food and Drug Administration (FDA) or DOA requirements. Instead, DEP has promulgated its own water quality standards, which differ from FDA standards. These bills

would remove duplicative oversight of facilities that are all food manufacturers and not public water systems, while helping ensure the safety and quality of bottled water. IBWA members and staff met with several sponsors of the measures to push for a floor vote this fall. This included meeting with state Representative Gary Day (R), who is the prime sponsor of the legislation,

DWRF Presents 2020 Kristin Safran College Scholarship to Lizzie Murphy

and Minority Chair of the House Agriculture Committee Eddie Pashinsky (D), who is a co-sponsor and was instrumental in leading a unanimous vote in support of the two bills out of the House Agriculture Committee last December. For more information on this issue, please contact IBWA Vice President of Government Relations Cory Martin: cmartin@

Lizzie Murphy

IBWA held several virtual meetings with members of the Pennsylvania legislature in September to promote passage of HB 1971 and 1972, bills that would move regulatory oversight of bottled water products to the state’s Department of Agriculture (PA DOA), the agency with regulatory oversight of food products, from the Department of Environmental Protection (PA DEP), which monitors public water systems. Under these bills, product oversight would shift from the PA DEP to the PA DOA; however, PA DEP would

Pennsylvania State Capitol

IBWA Continues Efforts in Pennsylvania to Move Bottled Water Industry Regulation to the Department of Agriculture

The Drinking Water Research Foundation (DWRF) is pleased to announce that Lizzie Murphy is the recipient of the 2020 Kristin Safran College Scholarship. Lizzie, who is the daughter of Christopher Murphy of IBWA bottler member Premium Waters, Inc. in Milwaukee, Wisconsin, is a freshman at Drake University, where she is studying public relations. She has also joined the Public Relations Student Society of America and is participating in Drake’s music program as a non-major. In high school, Lizzie excelled academically as well as in her extracurriculars. She was president of her Tri-M Music Honor Society, captain of the forensics team, and a student leader in the Spanish Honor Society. When she’s not studying, Lizzie likes to bake, bike, and play the flute. She also continues to work at a Hallmark store, where she has been employed for the past two years. Congratulations to Lizzie on this stellar achievement of receiving DWRF’s 2020 Kristin Safran College Scholarship. During the judging process, the Kristin Safran College Scholarship Selection Committee blindly reviewed applications from children or grandchildren of IBWA members. Judges did not know the names of the children, parents, or the company the parents worked for when reviewing the applications. Members of the committee include DWRF trustees Jack West and Stew Allen, and Kristin’s widower, Russ Safran. The Kristin Safran College Scholarship Fund was created by DWRF in February 2010, in honor of former IBWA Board 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 information about DWRF, visit NOV/DEC 2020 • BWR • 9


REALITIES OF RECYCLED CONTENT More and more states are looking to set recycled content mandates—but is the available supply of rPET and rHDPE enough to meet demand? By Christine Umbrell

Offering beverages packaged in containers made partially of recycled PET (rPET) and recycled HDPE (rHDPE) is swiftly moving from a “nice-to-have” product option to a "must meet" requirement for today’s bottled water companies. More and more, bottlers are leveraging recycled content—or making plans to add recycled content—in their containers. This trend is gaining speed as companies seek to contribute to the circular economy and prepare for legislation at the state and federal levels that would require specified amounts of recycled content in beverage containers. However, as states like California and Washington begin to set mandates, bottlers may be challenged to comply with proposed legislation’s unrealistic postconsumer recycled plastic percentages and unrealistic deadlines. Even as well-meaning companies seek to do their part and adjust their operations to include more recycled content in their containers, access to adequate supplies of postconsumer recycled plastic is in question. Those complications, combined with continuing COVID-19-related setbacks, set the stage for a difficult transition.

Legislation Looms On September 24, California became the first U.S. state to mandate recycled content in plastic bottles when Governor Gavin Newsom (D) signed the Energy Efficiency bill (AB 793). The new law phases in recycled plastic mandates, requiring the total number of plastic beverage containers filled with a beverage sold by a beverage manufacturer to contain no less than 15 percent postconsumer recycled plastic per year, beginning January 1, 2022; no less than 25 percent beginning January 1, 2025; and no less than 50 percent beginning January 1, 2030.

NOV/DEC 2020 • BWR • 11

A closer look at demand and supply issues across the country demonstrates how difficult it may be for bottlers to access enough recycled content to adhere to mandates. This landmark legislation is a game-changer for many bottlers. Some companies that do business in California are already exceeding the 15 percent recycled content requirements, but that's not the case for most companies, says IBWA Vice President of Government Relations Cory Martin. “There’s definitely going to be a ramp-up,” Martin explains, as companies try to adjust their operations to meet the 15 percent requirement in California. Martin says that Washington state considered legislation that is similar to California’s AB 793, except it would have mandated 10 percent recycled content by January 1, 2022. Although the bill passed the legislature last February, Governor Jay Inslee (D) declined to sign the bill due to the negative impact COVID-19 has had on the state's finances. Washington legislators are expected to re-introduce this legislation next year, says Martin, but it may be different than the 2020 version. He expects the 2021 Washington bill to include Extended Producer Responsibility (EPR) verbiage, which would introduce new challenges for beverage manufacturers. EPR is a policy approach under which producers are given a significant responsibility, financial or physical, for the treatment or disposal of postconsumer products. Martin predicts a domino effect regarding this type of legislation: “Once one state moves forward—especially California, which tends to lead on a lot of policy issues— other states will have a roadmap of what to include in their bills.” But unlike California, many states do not have the data to support recycled content availability within their borders. “In California, we have a good idea of the data, and what the state can and cannot support in terms of recycling, because the state has done a good job in collecting that type of data,” says Martin. “Other states—including Washington—aren’t there yet.” While California might be able to justify phasing in the new requirements, “other states would have to greatly increase their infrastructure to help the industry come close to meeting proposed mandates.” 12 • BWR • WWW.BOTTLEDWATER.ORG

“Anytime you’re looking at legislation for recycled content and water bottles or other containers, you have to think about supply,” says Laura Stewart, communications director at the National Association for PET Container Resources (NAPCOR). “We know that there simply is not enough supply of recycled PET being generated and collected today to meet all of the requirements.” A closer look at demand and supply issues across the country demonstrates how difficult it may be for bottlers to access enough recycled PET and HDPE to adhere to mandates.

COVID-19 Complicates Supply Last spring, when the COVID-19 coronavirus first appeared in the United States, rPET became a more sought-after commodity. “The demand for PET in the container business, both virgin and rPET, is quite strong, and we owe a lot of that to the bottled water business, which is booming—in part, because more people are staying at home,” says Darrel Collier, executive director of NAPCOR. Although no authority directed consumers to stock up on bottled water in connection with the COVID-19 outbreak, consumers still turned to bottled water amid concerns about sanitation during the public health emergency, plus “there’s more use of plastics in the delivery of food and beverages in plastic containers than before COVID,” Collier explains. “Almost all of our recyclers still report good sales of rPET into beverage containers.” However, over the past several months, fewer plastic bottles have been making their way to materials recovery facilities (MRFs) to be recycled. Both bottle deposit programs and curbside recycling programs have experienced setbacks. Given fears of contamination and statewide shutdowns, many of the bottle deposit programs stopped accepting recyclables. “Consumers have had concerns about returning empty containers, and operators of redemption centers have had concerns about COVID or their workforce has been affected by COVID,” explains Kate Krebs, director of industry affairs at Closed Loop Partners.


Both bottle deposit programs and curbside recycling programs have experienced setbacks due to the COVID-19 pandemic. Of particular note, in California, Newsom signed Executive Order N-54-20 on March 4, 2020, which stated that recycling centers did not have to accept plastic bottles and cans due to the COVID-19 pandemic. “So, the opportunity to get more recycled content into the market was greatly diminished” until August 21 when the order expired, says Martin. Data from the state of California indicated a 30 percent drop in the volume of beverage containers reclaimed through its deposit program from March 14, 2020, to May 22, 2020, compared with 2019. According to information released by the California legislature, that decline in recycling activity is “believed to be caused by a combination of temporary redemption center closures and consumers voluntarily avoiding venturing into public spaces.” In some states where curbside recycling is the norm, COVID-related labor shortages have had an impact— starting in the spring of 2020 and continuing today. In late August, for example, the Baltimore Department of Public Works announced that it was suspending recycling pickup throughout the city until at least November 1 to focus on trash routes, citing shortages of workers caused by an overwhelming demand for service due to the coronavirus pandemic and heat-related issues. Instead, the city has set up recycling drop-off centers, open for limited hours on workdays. “Stoppages such as this will affect the flow of PET from households to reclaimers to bottle manufacturers,” says Krebs. “The disruption affects citizens that like to recycle, but it also affects material flow. Recycling collection and MRFs are the real behind-the-scenes infrastructure that process PET and other plastics after their use and feeds them back into the manufacturing supply chain, which is what beverage companies are dependent upon.”

Competing for Recycled Content Eventually, many of the bottles that sat in people’s homes during the early days of the pandemic will make their way to recycling facilities. And COVID-related employment shortages may dissipate as collection companies staff back

A CLOSER LOOK AT FEDERAL RECYCLED CONTENT LEGISLATION Beyond state mandates, it is expected that national legislation regarding recycled content may eventually become law. The Break Free From Plastic Pollution Act was introduced in early 2020 in the U.S. House of Representatives by Rep. Alan Lowenthal (D-CA) and in the Senate by Sen. Tom Udall (D-NM). “Federal legislation often can take years, so they have included a very aggressive Extended Producer Responsibility (EPR) program,” explains Cory Martin, IBWA’s vice president of government relations. As currently written, the proposed legislation would require producers of covered products, including water bottles, to “design, manage, and finance programs to collect and process product waste that would normally burden state and local governments,” according to the Plastic Pollution Coalition. It would institute a 10-cent national refund requirement for all beverage containers and require that plastic beverage containers include an increasing percentage of recycled content in their manufacture before entering the market, among several other provisions. The legislation is in its early stages, explains Martin. This year, the bills’ sponsors are “laying the groundwork, building a foundation to get more support to get some hearings on the bill next year,” he says. While only Democrats have signed onto the bill so far, the bills’ champions “have done a good job of continually pushing it,” so Martin believes it will be reintroduced in future years, and the speed with which it accelerates may depend on the November elections.

up. But coronavirus-related complications are just one of the supply challenges for bottlers in search of rPET and rHDPE for their containers, as bottlers are already competing with other industries to acquire the commodity. “What many people don’t realize is that it’s not totally a circular economy, from the perspective that many of those molecules that come back from the recovered postconsumer bottles are going into other applications, such as fibers, carpet, strapping,” and even thermoform packaging for produce, explains Collier. And those nonbottle applications comprise approximately half of all the molecules that come back. “So, if you said you had a flat market, and you wanted a minimum content [of recycled material] of 25 percent, you literally need to have 50 percent, because half of the molecules that come back are going into applications that are nonbottle.” And those noncontainer applications of rPET “are worthwhile as well.” NOV/DEC 2020 • BWR • 13

CHALLENGES FOR BOTTLERS USING HDPE CONTAINERS Those bottled water companies that rely on HDPE for larger containers also face some unique circumstances. Recycling for HDPE is much less mature than it is for PET, says Cory Martin, IBWA’s vice president of government relations. "So, when you start applying mandates across the board for all types of plastics that are used in bottles, HDPE users are facing a different type of challenge,” he notes. For example, some data has indicated that when containers are made of more than 30 percent rHDPE, “it starts to impact the look of the plastic, so that means it may impact the customer experience, and the consumer may reject that,” says Martin. He suggests that bottlers that use HDPE pay close attention to the verbiage in upcoming legislation.

Competition for the appropriate type of recycled content can be fierce, agrees Martin. “Whether it’s PET or HDPE, we need food-grade, FDA-approved plastic” for bottled water, he says. “We want bottle to bottle. But for reclaimers, it’s harder to produce a food-grade recycled pellet; it’s easier to produce recycled PET or recycled HDPE that doesn’t have to go into food-grade products.” Some reclaimers will choose to sell recycled content to clothing manufacturers, or film or strapping companies, because they don’t require food-grade technical specification. This problem is evident even in states like California, where recycling is common, says Martin. “California shows 62 or 63 percent recovery” of bottles back into the recycling system, but many of those containers don’t make it back into bottles, he says. “Eighty percent of those are being sold off to another industry—or lost in the process somewhere.” In fact, there’s “shrinkage” in each step of the recycling process, with some loss occurring at MRFs and reclaimers. “If there are 100 bottles that go in [to be recycled], the bottled water industry typically only gets 20 bottles back, because the other 80 are lost or contaminated or sold off to other sources,” Martin says. “Once those bottles have been made into a carpet or into many types of clothing, you can’t recapture that plastic—it’s been downcycled, and it’s very difficult to recycle again—whereas a bottle can be recycled again and again.”

Seeking Sources of Recycled Content For some companies that already use rPET in their bottles, the proposed state mandates on recycled content use are not as problematic. “A lot of larger beverage companies 14 • BWR • WWW.BOTTLEDWATER.ORG

Competition between industries for recycled content can be fierce. had already made recycled content commitments, so a mandate was not a surprise for them—their procurement teams had already been working on what they would need to do,” says Krebs. Most early adopters already have a dedicated source for accessing rPET materials, and they have worked out agreements with suppliers to meet their internal goals, according to Martin. Smaller bottlers may not have the purchasing power to achieve the same goals. “For the smaller companies, it’s hard to get your foot in the door and find, at a price that they can afford, that recycled content,” Krebs says, particularly given the price differential between virgin and rPET materials. “When a virgin bottle comes into the marketplace, there are very few steps to go from raw material input into a polymerization process into a bottle, whereas recycled PET has to travel from the consumer, to the MRF, to the reclaimer, to the converter, to the bottling plant,” says Krebs. “The competition between rPET cost and virgin cost when we’re talking about mandates for recycled content—it’s a very big reality. If rPET is going to compete with virgin at scale, we have to find every single way to make improvements across the system so that the price point is not such a factor.” Fortunately, some small steps are being taken to move bottlers closer to integrating more recycled content into their bottles. First, some MRFs are beginning to automate their processes to capture more of the recycled PET as it passes through their facilities. Several MRFs affiliated with Closed Loop Partners integrated new robotic sorting systems into their operations over the past 12 to 18 months— just in time for the pandemic. Once social distancing measures were put into place, MRFs were forced to rely on fewer employees and had to slow down their sort lines. But those MRFs with robotic sorting systems leveraged artificial intelligence to pick the more valuable PET and HDPE items out—and did so faster than is possible using humans, says Krebs. “The value of robotics, because of COVID, has definitely been proven out.” And second, bottlers themselves can take a proactive approach. Krebs suggests that bottlers adhere to design


Bottlers can be proactive in helping increase the amount of recycled content that is available by adhering to APR’s design recommendations for plastic bottles. recommendations to ensure their bottles are easily recyclable. The Association of Plastic Recyclers (APR) has published “ The APR Design Guide for Plastics Recyclability,” which can help companies in designing packaging so “there is nothing that will contaminate that package when it hits the recycling process,” says Krebs. The APR guidelines address color, labeling, and other design aspects to “improve the feedstock going into the system . . . and remove ‘disruptors’—things that will disrupt a cleaning system at a reclaimer,” she says. “I think that will help accelerate the transition we need to make sure we have a system that works.”

Beyond bottle design, companies that have not already incorporated recycled content into their packaging “are going to have to identify a source” of rPET or a blend of rPET and virgin, then “start doing the technical work around how a blend of virgin and rPET works in their facilities and in all their bottles,” says Collier. “And think about the distribution and marketing.” white/blue fill/blue drop shadow

For more favorable pricing of rPET materials, Krebs encourages bottlers to identify reclaimers with whom they can sign offtake agreements—long-term purchase agreements. For these types of contracts, bottlers agree to



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RECYCLED CONTENT purchase either a specified volume or a specified percentage of the volume produced by the reclaimer, providing stability for both parties. Partnerships will be key, agrees, Nina Bellucci Butler, a principal at More Recycling. “The new era will be less about straight traditional competition and more about collaboration,” she says. “So, what is your value chain doing? How are you partnering with those companies that have a value chain that is really moving toward circularity? It’s making those iterative changes and adjustments” to move toward circularity.

Embracing the Future

As states look to implement mandates, it will be important that each state examine the availability of recycled content within its borders, says Martin. “Remember that in California, reclaimers are already shipping in plastic content from other states, just to meet current demand,” he says. As more states consider mandates, “they need to be data-driven so we can meet demand,” says Martin. “If every state is facing supply problems, where will that recycled content come from?” IBWA’s position has always been that “we support reasonable recycled content mandates,” concludes Martin. “How we define 'reasonable' means having the data to back up our ability to meet any percent mandates.” BWR

California is the first, but certainly not the last, state to adopt recycled content mandates. And there may come a day soon when national legislation regarding recycled content becomes law (see sidebar on p.13), so it’s important for bottlers to start preparing now. “Once we get past the COVID problems [like stoppages and holds on materials], I think we really need to be ready,” says Krebs. “Mandates are coming; we have to prepare.”

Christine Umbrell is a freelance writer based in Herndon, Virginia. Email her at

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LEARNING DURING THE PANDEMIC What consumers should know about bottled water packaging By Chris Torres

Since the COVID-19 pandemic began, everyday life for consumers has changed, and some of those changes may evolve into permanent lifestyle choices. Here’s one example: More people are working from home. Recent surveys have found that some employees may continue to work from home after the end of the COVID-19 era. More time at home means more food and beverages are being consumed at home. Ultimately, that equates to more recyclable “waste” being produced at home.

NOV/DEC 2020 • BWR • 17

THE PET CONTAINER: A CLEAR CONSUMER FAVORITE Recyclable—PET containers are 100% recyclable and can be recycled again and again.*

Lightweight—Bottled water bottles use 59% less PET than other packaged beverages, like carbonated soft drinks.


Better for the environment—PET bottles have the smallest environmental footprint of any packaged beverage container and have up to 60% less greenhouse gas emissions than other packaging types.**

Recognizable—PET containers use the #1 recycling code, along with the chasing arrows, usually on the bottom of the bottle.

Consumer friendly— PET containers are lightweight, clear, and shatterproof.


Modern recycling can repair any PET mechanical properties. **

That’s why the current environment provides a great opportunity for IBWA members to communicate bottled water packaging facts to their consumers. It’s important for consumers to know that plastic beverage containers are made to be recycled—and, with their help, that valuable recycled content can have a chance to be used again and again.

Still No.1 Since 2016, bottled water has been the No.1 packaged beverage product (by volume) in America. Most Americans (94 percent) have purchased bottled water, according to a Harris Poll survey conducted on behalf of IBWA. And we know that Americans like the fact that it can be consumed both on the go and at home because, according to 18 • BWR • WWW.BOTTLEDWATER.ORG

the survey, people drink bottled water while traveling (86 percent) and shopping (72 percent)—and when at home (76 percent). We don’t yet know the final numbers on bottled water sales for 2020, but preliminary data shows bottled water will continue to be on top at the end of the year, as more and more people continue to chose bottled water. And their preferred packaging material for that water? Plastic. The Harris Poll survey said of the 86 percent of people who have a packaging preference, 79 percent prefer their bottled water in plastic, compared with 15 percent who prefer glass, 4 percent for metal cans, and 2 percent prefer paper cartons or a box. In addition, Beverage Marketing Corporation reports that plastic packaging is preferred over glass in almost every

Versus aluminum cans, glass, and paperboard containers.

country. Even in countries where glass has a strong presence, such as the United Kingdom and Germany, polyethylene terephthalate (PET) is the most dynamic and rapidly growing segment. With what we know about bottled water’s popularity and the consumer’s preference for plastic packaging, it’s important to talk about recycling. We need consumers to be educated about the recyclable plastic materials commonly used in food packaging— whether it’s PET, high density polyethylene (HDPE), or polycarbonate (PC). Bottled water is just one of many food items that are packaged in plastic, so it’s crucial that the public understands the important role they play as recyclers.

Most bottled water customers are likely familiar with PET bottles, but what details do we want to ensure they know about this form of plastic? For starters, PET is recycled more than any other plastic in the world. Bottled water is typically produced and sold in small, portable 16.9- and 24-ounce sizes. It’s 100 percent recyclable and is used to package a variety of food and beverage products, as it is approved as safe for such uses by the U.S. Food and Drug Administration (FDA), along with similar regulatory agencies around the world. “PET is a wonderful material and serves a purpose,” says Laura Stewart, communications director for the National Association for PET Container Resources (NAPCOR). “Whether for on-the-go convenience or peace of mind related to health and safety—consumers rely on PET. The other fact is that there is a large percentage of consumers who choose PET because of its clarity, shatterproof, lightweight and recyclability attributes.” Another point worth noting is that PET bottled water containers use much less plastic than other packaged beverages. Compared with soft drinks, bottled water uses 59 percent less PET on average (9.89 grams vs. 23.9 grams for 16.9-ounce containers). Consumers are probably aware that soft drink bottles use thicker PET plastic, but they may not be cognizant of why, which is due to carbonation and other bottling processes. When trying to identify PET, customers should look for the #1 code, along with the chasing arrows logo, which is typically found at the bottom of the bottle. Most PET is recycled through curbside pickup programs, but some states also have bottle deposit programs in which consumers receive a refund after returning

their empty PET bottles to a store or other redemption center. Of the PET that is collected from bottle deposit and curbside recycling programs in the United States and turned into recycled PET (rPET), 47 percent is used for fiber, 21 percent for food and beverage containers, 19 percent for sheet and film, 8 percent for strapping, 4 percent for non-food bottles, and 1 percent for other uses, according to Waste Management’s September 2020 Report on Recycling ( WM_Report_on_Recycling.pdf ).


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PET Prevails During the Pandemic

THE HDPE CONTAINER: A HANDY PACKAGE Safe—HDPE has been used since the 1930s.

Recyclable—HDPE containers and caps are 100% recyclable and can be recycled multiple times.

Lightweight and shatterproof—HDPE bottles are easy to carry due to their sturdy handles and won’t break, making them ideal for use at home or outdoors.

When the COVID-19 pandemic began, many deposit programs became unstable, according to Stewart. Redemption centers in states with bottle deposit legislation were shut down, which forced consumers to either hoard their PET bottles, or, in some cases, send them to landfill, she says. Those issues have since been resolved and returns have recovered strongly.


single-serving beverages (for example, soft drinks), you’ll want to ensure your consumers are familiar with the bottled water industry's other packaging options.

HDPE: Common in Every Home

Some curbside programs have been impacted as well in recent months, Stewart explains, primarily due to labor shortages related to COVID-19. Despite those impacts, she states that demand for rPET has remained high. Buyers of rPET, according to the Waste Management report, are typically larger companies that are capable of more consistent purchasing habits.

HDPE is likely in the homes of most consumers in some form, whether it’s a jug of bottled water, milk, or juice. HDPE is also 100 percent recyclable and is most commonly used in 1 gallon jugs. Recycled HDPE (rHDPE) can be used to make new bottles and jugs— and also it is used in the manufacture of hard hats, plastic wraps, plastic lumber, as well as other products. Like PET, HDPE is safe for bottled water, and it doesn’t add a taste or odor to the water.

While PET is the most common packaging for bottled water and other

Consumers can identify HDPE bottles by noting the #2 code along with the


Recognizable—HDPE containers use the #2 recycling code, along with the chasing arrows, either on the bottom or side of the container.

chasing arrows logo, either on the bottom or side of the container. There are other details you may want to teach your customers about HDPE recyclables in their homes. HDPE is also used to make liner-less caps, and they use less plastic than a non-liner-less cap, according to AJ Miller, director of marketing with Silgan Closures. “The key,” he says, “is to get the bottles with caps on into the recycling bin, so [the cap also] gets recycled. Most recycling is single stream. You can put it all in one container and it will get sorted at the MRF [material recovery facility]. It is also very important to place the cap back on the empty water bottle before you place the bottle in the recycle bin. Having the cap on the bottle ensures that it will get to the proper recycling stream.”

Like PET, HDPE can be recycled multiple times. In 2018, a European company demonstrated that HDPE can be recycled at least 10 times (www.ese. com/home/ese-aktuell/aktuell-detailseite/ article/hdpe-multiple-recycling-proven-inan-experiment/). While PET and HDPE are the most popular plastics used to make bottled water packaging, consumers should

be educated about the other, very dependable, materials used to produce beverage containers.

PC: Transparent Strength These days, consumers are spending a lot more time around their home, rather than the office, water coolers. Like the other plastics mentioned, polycarbonate (PC) is 100 percent recyclable, and it is used to make many 3- and 5-gallon home and office delivery (HOD) bottled water containers. (Note: Some HOD bottles are made from PET.) PC plastic has been a popular material for many food and beverage product containers for over 50 years because it is very strong, lightweight, shatter-resistant, and transparent. What also makes it


THE PC CONTAINER: A WATER COOLER'S FRIEND Durable—PC containers are ideal for 3- and 5-gallon containers because they are strong, lightweight, shatter-resistant, and transparent.

Recyclable—PC containers are 100% recyclable. They are cleaned, sanitized, and reused between 30-50 times before being recycled.

Safe—PC plastic has been used in food and beverage containers for more than 50 years.


Recognizable—PC containers use the #7 recycling code, along with the chasing arrows, either on the bottom or side of the container.

NOV/DEC 2020 • BWR • 21


Demand for rHDPE has been strong in recent months, as brands have since figured out how to continue forward with recycled content commitments after an initial pause to deal with COVID-19 efforts, according to Recycling Today (


To help consumers learn what should and shouldn’t be placed in their recycling bins, IBWA created a “Can You Recycle This?” social media campaign as part of its broader “Put It In The Bin” initiative. These posts feature graphics that help clarify what items are considered recyclable at material recovery facilities.

Bottled water containers are, of course, 100 percent recyclable— including the caps. Among the non-recyclable items identified are plastic bags, plastic utensils and straws, shredded paper, paper plates, single-use coffee and drink cups, and greasy pizza boxes. You can locate these social media posts and images at Recycling can be a complex issue for consumers to understand, as different municipalities accept different recyclables. To find out what is or isn't recyclable at your community facility, contact your local recycling program. For more information about bottled water packaging and recycling, visit IBWA’s website,, and follow IBWA on social media: FACEBOOK Bottled Water Matters

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ideal is that it’s hygienic and provides protection from food contamination and spoilage. Once consumers return their 3- and 5-gallon HOD bottled water containers, they’re cleaned and sanitized between uses and can be reused 30 to 50 times before they’re recycled. PC doesn’t have its own distinct identifying number for recycling, but it is usually marked with the #7 code, which is classified as “other” along with other plastics.

Glass: Still Dependable As widespread as the use of plastics is in the production of bottled water containers, glass is still a viable option for bottled water packaging. Since the beginning of the industry in North America, bottled water has been packaged in glass. Nowadays, glass is most often used as packaging for larger bottles of water (e.g., 750 ml). Glass can be more of a challenge to recycle for a few reasons, including contamination. There’s a lack of end markets, higher transportation costs because it weighs much more than plastic or aluminum, and it has potential to break easily. This also makes it hard on equipment and increases maintenance costs. Bottled water producers that market their product as premium water tend to gravitate toward glass packaging.

Continuing to Spread the Good News About Bottled Water Packaging The American Chemistry Council (ACC) has published a report, conducted by Franklin Associates, that compares the overall impact of plastics on the environment with other packaging materials. The “Life Cycle Impacts of Plastic Packaging Compared to Substitutes in the United States and Canada” (plastics. uses a

By looking at the entire life cycle of the plastic packaging versus alternatives—cans, glass bottles, and paperboard containers—the ACC report concluded that, when you compare materials throughout the entire life cycle of a package, plastics leave a much smaller environmental footprint than the alternatives. Perhaps the most significant finding was that using those alternatives to plastic beverage containers would produce about 60 percent more greenhouse gas emissions—a major contributor to global warming.

When surveyed, consumers choose plastic as their preferred packaging material for beverages. In addition, results from IBWA’s Harris Poll show that 75 percent of Americans agree that plastic is a valuable resource because of its ability to be recycled over and over—and 91 percent state that it’s important to recycle all recyclable consumer packaging. NAPCOR’s Stewart agrees: “If every PET bottle used was recycled like it should be, the use and reuse of PET would be maximized and PET product would not be available to be released into the environment because it would be captured in a locked circular economy. For those consumers spending more time at home—it’s a perfect time to think about your own recycling habits and work to reduce the amount of materials that are landfilled.” BWR


Chris Torres is IBWA’s communications coordinator. Contact him at ctorres@

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“theoretical substitution analysis” to assess the environmental impacts of plastics packaging relative to alternative packaging in North America—taking into account energy demand, water consumption, solid waste, global warming potential, eutrophication potential, smog formation potentials, and ozone depletion potential.

Politics and Advocacy in the Post-Pandemic World By J.P. Toner, IBWA Director of Government Relations

By the time you are reading this article, the dust has (hopefully) settled from the 2020 election. There will be new members of Congress in the U.S. Senate and House, and new legislators in State Houses across the United States—and perhaps a new leader in the White House. Even with all that has occurred in the last year or so that impacted the election (e.g., the MeToo movement, Black Lives Matter, social justice protests, 24 • BWR • WWW.BOTTLEDWATER.ORG

police reform, and COVID-19, just to name a few), the daily routine of politics and advocacy marches on. Getting involved in the political arena has actually become easier—and more competitive.

Remote Congress As the expression goes, “Time waits for no one,” and that applies to the work of the country’s lawmakers: budgets still need to be approved, regulations need

to be established, and laws need to be enacted. Frankly, the everyday responsibilities of elected officials are pretty much the same as they have always been. However, the COVID-19 pandemic has impacted how advocacy works. If you’ve advocated on behalf of your company and the bottled water industry in the past—building relationships with state legislators and members of Congress by spending time and money

GOVERNMENT RELATIONS to travel to state capitals and Washington, DC, and inviting elected officials to tour your bottling plants and meet your employees—then you can consider yourself at an advantage. Those established relationships can help you play an important role in the legislative process. However, if the role of advocate is new to you, it’s a brave new world. Remote working has become the modus operandi for most executives— and that extends to our elected officials. Now, you only need a smartphone and a Wi-Fi connection to meet with legislators. That’s a great convenience that levels the playing field, but it also brings with it increased competition for legislators’ time. Every citizen advocate is working to gain access to legislators to promote their agendas, so getting your voice heard above the din is more problematic than ever. Responding to the realities of COVID-19 has meant that access to lawmakers and participating in the legislative process has changed in such a way that everyone can more easily be part of policy-making conversations and activities. States that put their sessions on hold when the pandemic first hit have implemented changes that enable remote access for events like committee meetings and hearings, floor sessions, and other daily legislative actions. Anyone with a phone or a webcam can now be included in the process without having to leave their home. While there are still slight glitches that need to be worked out, today the citizen advocate has access to a whole new level of participation.

New Age Advocacy For the immediate future, gone are the days of direct lobbying, meet and greets, and plant visits. But, with a little imagination and some general tech tools, you can repackage those activities in a way that the access remains useful and personal. IBWA has already successfully

GETTING INVOLVED IN THE POLITICAL ARENA HAS BECOME EASIER—AND MORE COMPETITIVE. scheduled virtual meetings for members with lawmakers—both state and federal. We can use the same technology to enable elected officials to “visit” your facilities. Simply by using a smartphone, you can give legislators a guided tour of your operations and include opportunities for them to meet your employees. Although these meetings are virtual rather than “IRL” (in real life), they still provide a great opportunity to educate legislators on the many issues involved in producing the No.1 packaged beverage in the United States. If you are looking to do multiple meetings with legislators, consider recording a tour and uploading it to use during any presentation via a web conference tool (e.g. Zoom, Webex, GoToMeeting, etc.).

Getting Your Message Across When it comes to presenting information that you believe is important for elected officials to know, you need to do two things: narrow your focus and broaden your allies. Legislators cannot be expected to be subject matter experts on all issues. For them, you are the bottled water expert. Consider presenting specific details on your topic, identifying for the official the key points you want them to walk away from your virtual event knowing. Make sure those vital messages are repeated often by anyone who has a speaking role during your event. Another way to ensure legislatives hear your message multiple times is by casting a broader net on the players that repeat your key points. Work with existing and potential allies to build

a coalition. More than ever before, establishing a coalition is an advocacy best practice that presents arguments from a group mentality. Bottled water has some unique issues as an industry; however, many of our issues are shared with numerous other businesses and industries (e.g., recycled content and taxes). The more a lawmaker hears the same message from numerous unique sources, the more it resonates. Using partnerships to hone a message and voice it in unison can have an influential impact. Even though we are practicing our advocacy skills in a new reality, it’s important to remember this: don’t give up. Everyone has had to pivot and approach business in a new way due to COVID-19. We are sure to experience new hurdles we could not have anticipated, but the best strategy is to approach those growing pains with patience and understanding. Our elected officials have a job to do—and IBWA’s advocacy work never ends. We will continue to innovate during this time of crisis to help ensure no legislation that is harmful to the industry is enacted. BWR

NOV/DEC 2020 • BWR • 25

Tips for Answering Consumers’ PFAS Questions By Sabrina E. Hicks, IBWA Director of Communications

The issue of emerging contaminants has received a lot of attention from the media lately, particularly a group of manmade chemicals called per- and polyfluoroalkyl substances (PFAS). These chemicals are very persistent in the environment and in the human body, which means they don’t break down and can accumulate over time. There is concern that exposure can lead to adverse health effects; however, there is no scientific consensus about what the negligible risk level is. Due to the interest in PFAS, your consumers may reach out to you for information on this complex issue. Use this article as a primer to help form company messaging on the topic.

What are PFAS? PFAS are a group of manmade chemicals that include PFOA, PFOS, 26 • BWR • WWW.BOTTLEDWATER.ORG

GenX, and many other chemicals. As described on the U.S. Environmental Protection Agency’s (EPA) website, “PFAS have been manufactured and used in a variety of industries around the globe, including the United States, since the 1940s.” EPA notes that PFAS can sometimes be found in the following: • Food packaged in PFAS-containing materials, processed with equipment that used PFAS, or grown in PFAScontaminated soil or water. • Commercial household products, including stain- and water-repellent fabrics, nonstick products (e.g., Teflon), polishes, waxes, paints, cleaning products, and firefighting foams (a major source of groundwater contamination at airports and military bases where firefighting training occurs). • Workplaces that use PFAS, including production facilities or industries

(e.g., chrome plating, electronics manufacturing, or oil recovery). • Tap water, typically localized and associated with a specific facility (e.g., manufacturer, landfill, wastewater treatment plant, firefighter training facility). • Living organisms, including fish, animals, and humans, where PFAS can build up and persist over time. For surface and ground waters, the highest levels of PFAS compounds may be found near airports and military bases with firefighting schools, where large quantities of firefighting foams were applied during training sessions, and facilities that formerly manufactured non-stick coatings. The highest concentrations of such facilities, known to date, are in the northeastern United States, Michigan, and California. Other more localized areas have also been identified.

COMMUNICATIONS Are PFAS in bottled water? PFAS are not used in the manufacturing of bottled water bottles; however, some food packaging does contain PFAS (e.g., burger wrappers and pizza delivery boxes use PFAS to help keep food warm). In addition, results of product testing conducted by the U.S. Food and Drug Administration (FDA) have shown that bottled water, to date, is free of PFAS levels found in some foods and packaging materials. FDA conducted a bottled water shelf study in 2016 and published those test results ( PFAS2016). The study yielded no detections of PFAS for all samples collected. Similar results were found in 2019 when IBWA conducted a testing program of member bottlers: 100 percent of the samples tested were below the EPA’s health advisory limit of 70 parts per trillion (ppt). Detectable levels of PFAS compounds were found in 1.7 percent of the samples tested, but the levels were below IBWA’s standards of quality (SOQs) of 5 ppt for one PFAS and 10 ppt for more than one. To help consumers imagine what that amount looks like, Suez North America, an American water service company, provides the following analogy on its website: “One part per trillion is the equivalent of one grain of sand in an Olympic-size swimming pool” (www.

Are PFAS in tap water? In late 2016, EPA published a health advisory level of 70 ppt for all PFAS in drinking water. The Environmental Working Group (EWG) tested tap water samples from 44 places in 31 states and the District of Columbia and published its research in 2020. EWG detected PFAS in all water samples from those 31 states and DC, but only two public water systems had levels exceeding EPA’s 70 ppt limit. Because PFAS are not federally regulated, other

IF EPA ISSUES A PFAS REGULATION FOR TAP WATER, FDA IS REQUIRED TO REVIEW EPA’S RULE AND DETERMINE ITS APPLICABILITY TO BOTTLED WATER. locations that had detectable levels of PFAS were not required to make those results public ( national-pfas-testing).

Will PFAS be federally regulated? According to EPA’s website, “In February 2020, EPA proposed to regulate [PFOS and PFOA] in drinking water. The comment period on these preliminary determinations closed on June 10, 2020 and the agency received more than 11,000 comments. The agency will review and consider comments received on this action then take the next appropriate steps” ( EPA is evaluating PFOA and PFOS as drinking water contaminants in accordance with the process required by the Safe Drinking Water Act (SDWA). To regulate a contaminant under SDWA, EPA must find that it: (1) may have adverse health effects; (2) occurs frequently (or there is a substantial likelihood that it occurs frequently) at levels of public health concern; and (3) there is a meaningful opportunity for health risk reduction for people served by public water systems. As the focus on PFAS became more intense, several states began to propose new regulations of specific PFAS compounds. They generally focused on regulating PFAS compounds found in their states during initial rounds of testing of drinking water supplies, and PFOS and PFOA were the most common. IBWA foresaw the inevitable

“patchwork” of PFAS regulations by the states. Some states established maximum contaminant levels (MCLs) for specific PFAS compounds, while other states follow the EPA health advisory level of 70 ppt for PFAS compounds as a group. At 5 ppt for one PFAS and 10 ppt for more than one, IBWA’s SOQs for PFAS are substantially below the EPA’s health advisory level of 70 ppt. Because bottled water is a food product, IBWA member bottlers would follow the SOQs set by FDA for PFAS in bottled water; however, FDA has not yet issued a regulation for PFAS. IBWA takes consumer health and safety very seriously, which is why, IBWA continues to encourage FDA to issue an SOQ regulation for PFAS in bottled water. IBWA has written to FDA with this request, and FDA responded to IBWA stating that the agency would not issue a PFAS regulation "at this time." FDA also said it believes that “establishing SOQs for PFAS in bottled water at this time would not significantly enhance FDA’s mission of public health protection.” However, FDA noted that it would continue to monitor any action by EPA on establishing PFAS MCLs for public drinking water. Under federal law, bottled water regulations must be as protective of the public health as tap water regulations. If EPA issues a PFAS regulation for tap water, FDA is required to review the EPA rule and determine its applicability to bottled water. BWR NOV/DEC 2020 • BWR • 27

IBWA Ensures Bottled Water Remains Healthy Hydration Option During COVID-19 By Bob Hirst, IBWA Vice President of Education, Science, and Technical Relations

Much of the nation struggled in the early days of the COVID-19 pandemic, and some small businesses either struggled to remain open or shuttered. Purchases of bottled water surged at the beginning of the pandemic due to panic buying by consumers who feared shortages on essentials. Retailers found it difficult to keep up with demand for supplies of bottled water, along with paper products, hand soaps, sanitizers, and disinfecting cleaners and wipes, and many stores found it necessary to ration those products. 28 • BWR • WWW.BOTTLEDWATER.ORG

As the nation settled into new stayat-home routines, consumer hoarding of bottled water and other products eased, allowing manufacturers to restock supplies. Some IBWA bottler members reported that sales had slowed to the point of reduced sales for the year, possibly as a result of consumers working through their excess stock at home. But marketplace issues weren’t the only COVID-induced challenges bottled water companies faced.

Aiding the Infrastructure Because bottled water is an essential part of the nation’s critical infrastructure, the industry was expected to maintain adequate stocks for other national emergencies, such as hurricanes. The industry met that challenge recently when Hurricane Laura slammed into Louisiana and southeast Texas, and later when Hurricane Sally caused damage and flooding in Florida and Alabama. IBWA works with the American Logistics Aid Network (ALAN) during

TECHNICAL UPDATE hurricanes and other emergencies to coordinate relief supplies. ALAN also coordinates with the trucking industry to help direct logistics capabilities to where they are needed. The response after Laura and Sally showed that the industries that work with ALAN, including bottled water, were successful in meeting demands despite COVID-19 restrictions.

Advising CDC COVID-19 restrictions have had several impacts on the way bottled water companies operate. The federal government’s science and regulatory agencies have published guidance documents for businesses that are reopening or have continued to operate during the pandemic. For the most part, bottled water facilities have adapted to the guidance, including social distancing and use of personal protective equipment, such as face masks, gloves, and enhanced sanitization procedures. When the Centers for Disease Control and Prevention (CDC) released guidance for reopening businesses that included a suggestion to avoid use of bottled water coolers in favor of sanitizing water fountains frequently, IBWA acted quickly. We contacted CDC and submitted written comments to challenge the guidance document's suggestion to avoid using water coolers. In the letter, IBWA stated the following: The CDC’s May 2020 guidance includes a section titled “Engineering controls: Isolate workers from the hazard.” Language in that section recommends not using “communal items,” such as water coolers. However, another section of the guidance titled “Administrative controls: Change the way people work,” lists drinking fountains among other “high-touch surfaces” in the workplace that should be routinely cleaned and disinfected to reduce the risk of

QUICK ACTION BY IBWA HELPED TO ENSURE WATER COOLERS REMAINED A HYDRATION OPTION IN THE WORKPLACE. people’s exposure to the COVID-19 virus. It is inconsistent to allow the use of water fountains in the workplace but not water coolers. IBWA believes that both water coolers and water fountains can be cleaned and disinfected in the same manner to reduce the risk of exposure to the COVID-19 virus. There is, however, one significant and important difference between water coolers and water fountains. Water coolers can be used more safely because people do not place their mouths and noses near the faucet when drinking the water, which is necessary when using a water fountain. In the same letter to CDC, IBWA cited a similar situation in Kentucky, where IBWA commented on a proposal to discontinue use of water coolers: The Commonwealth of Kentucky recently considered this issue and made it clear that water coolers should be allowed in the workplace during the COVID-19 pandemic. Kentucky’s “Healthy at Work Phase 1 Reopening Requirements for Manufacturing, Distributing, and Supply Chain Businesses” includes language that prohibits the use of “water fountains.” Because some workplaces were concerned that this provision applied to water coolers, IBWA contacted the Governor’s office for clarification on this issue. The following response from the Governor’s office clearly states that water coolers can be used in the workplace: Under “manufacturing” guidance, water coolers or water fountains for bottles (e.g., anything that doesn’t

require someone putting their mouth on or near the water dispenser and instead things that dispense into a personal container) are all permissible under the requirements. They were what we had in mind when we stated, “alternative water sources,” and are permitted even if they’re outside the “manufacturing” facilities.

Successful Revision As a result of IBWA's efforts, the next version of CDC's guidance did not include the suggestion that water coolers should not be used in offices and other workplaces. This was a win for the home and office delivery members of IBWA. IBWA continues to monitor important developments in the nation’s management of the pandemic and will also continue to issue pertinent COVID-19 Bulletins to members as is warranted. BWR

NOV/DEC 2020 • BWR • 29



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 Linda Amar ( / Fax: 703.683.4074), IBWA Education and Technical Program Coordinator, 1700 Diagonal Road, Suite 650, Alexandria, VA 22134. Look for additional quizzes in future issues and earn additional IBWA CEUs!

Name______________________________________________________ Company__________________________________________________ Address____________________________________________________ City_______________________________________________________ State/Province______________________________________________

ZIP/Postal Code____________________________________________

Check your selection for each question


_____ published reopening guidelines for businesses that included not using bottled water coolers.




“Mineral Water” means water containing not less than _____ total dissolved solids (TDS).


100 ppm 250 mg/l 500 ppm 10 mg/l


The state that ruled specifically that water coolers should be permitted in the workplace was _____.


New York California Kentucky Michigan


According to the IBWA Code of Practice, water intended for bottling must be from a source approved by _____.


the applicable regulatory agency the USEPA FDA US Department of Agriculture


IBWA’s primary means of communicating important information to members regarding COVID-19 is through _____.


IBWA News Splash Bottled Water Reporter IBWA website IBWA COVID-19 Bulletins



Representative samples shall be taken from shipments of bulk water for the analyses of coliform bacteria and Heterotrophic Plate Count (HPC). The minimum frequency of sampling shall be one sample from each tanker on a _____ basis.


weekly daily monthly annually


Nonregulatory testing for coliform and E. coli may be done in the plant by _____.


Qualified plant personnel Certified laboratory technicians Outside certified laboratory Qualified plant personnel or outside certified laboratory


Beginning in 2019, IBWA bottlers will be required to test for 14 PFAS compounds in finished water every 3 years.

O True O False


While IBWA has not to date received a direct response from CDC to our comments and suggestions, the next version of the CDC guidance was revised to remove the suggestion for not using water coolers in offices and other workplaces.

O True O False


The current requirement for PFAS testing is analysis using _____.


USEPA Method 537.1 Any approved method USEPA Method 525 USEPA SW-846



9-12 • NOVEMBER IBWA Annual Business

Allied Purchasing . . . . . . . . . . . . . . . . . . . . . . . 19

Conference and Trade Show Virtual Event Visit convention for more details.

Analytical Technology. . . . . . . Inside Back Cover Blackhawk Molding Co. . . . . Inside Front Cover BMI Korea . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ..22


Brio Water Technology . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

23-25 • FEBRUARY IBWA Board of Directors

Culligan . . . . . . . . . . . . . . 866.408.0380. . . . . . . . . . . . . . . . . . . . . . . . . . 23

and Committee Meetings Video Conference

KHS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 Polymer Solutions Int'l . . . . . . . . . . . . . . . . . . . . . . . . . . . .16

7-9 • MARCH CBWA Convention

Sigma Home Products Co., Ltd. . . . . . . . . . . . . . . . . . . . . . .31

and Trade Show (PCQI class, March 9-11) Paso Robles Inn Paso Robles, CA

Steelhead Inc. . . . . . . . . . . . . . .Outside Back Cover Vertex Water Products . . . . . . . . . . . . . . . . . . . . . . . . . .15

12-15 • MAY NWBWA Convention

and Trade Show Embassy Suites Hotel Portland, OR

7-10 • JUNE IBWA Board of Directors

and Committee Meetings and Capitol Hill Appointments Hilton Old Town Alexandria, Virginia

Support your industry while getting ahead of the competition! Place an ad in IBWA's Bottled Water Reporter magazine. Why We Need a Federal PFAS Standard



IN THIS ISSUE Three Lessons IBWA's Water for Bottlers From Stewardship Best a Wastewater Practices Guide Treatment Facility

Why Water Should Be Added to MyPlate



IN THIS ISSUE States Consider Responding to PFAS Regulation Bottled Water Myths With Facts

IBWA Bottlers Promoting the Granted Recyclability Labeling Exemption of Bottled Water Containers




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

IN THIS ISSUE IBWA Establishes Correcting a Coast-to-Coast Misinformation Advocacy Network With Bottled Water Facts


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

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


THE HEALTHY HYDRATION ISSUE PROVEN STEWARDSHIP How the bottled water industry is a leader in environmental sustainability

DOING OUR PART The positive impact of offering environmentally friendly beverage containers to eco-conscious consumers

Also Inside:

Who Will You Nominate for a 2020 IBWA Award? IBWA Bottlers Earn "Excellence in Manufacturing" Designation A PUBLICATION OF THE INTERNATIONAL BOTTLED WATER ASSOCIATION

Also Inside:

Why Experts Recommend Water The Case for Water's Continued Inclusion in the Dietary Guidelines for Americans A PUBLICATION OF THE INTERNATIONAL BOTTLED WATER ASSOCIATION

Also Inside:

Why Meeting With Legislators Matters FDA Launches Food Safety Dashboard A PUBLICATION OF THE INTERNATIONAL BOTTLED WATER ASSOCIATION

IBWA’s award-winning, bimonthly magazine, Bottled Water Reporter, is the only trade magazine in the United States that exclusively targets the bottled water industry. IBWA has proudly been offering digital editions of its magazine online since 2009. Issues are mailed directly to IBWA members and nonmember subscribers six times a year. Bonus distribution offered during in-person IBWA Annual Business Conference and Trade Shows. Review past issues at bottled-water-reporter. Contact Stephanie: 817.719.6197 /


R f

Although the second quarter of 2020 saw decline in volume and dollars for bottled water due to the COVID-19 pandemic, category growth still occurred thanks to double-digit growth in the first quarter.




2020 Q1

2020 Q2

2020 1H

19/20 Q1

19/20 Q2

19/20 1H







Retail Bulk







Direct Delivery




















Domestic Sparkling








Imported Sparkling














*Includes Domestic and Imported Still Water. Source: BMC Drinktell Database


According to Beverage Marketing Corporation (BMC), bottled water is projected to remain the largest U.S. beverage category in 2020, with volume surpassing 15 billion gallons—a 5 percent increase.

Americans have chosen bottled water as their favorite package beverage, by volume, for five years in a row.







Bottled Water




Carbonated Soft Drinks






















RTD Coffee





Sports Drinks

Fruit Beverages




Energy Drinks




V-A Water




Dairy Alternative








Note: BMC data is total-market, covering all channels. Source: BMC DrinkTell Database


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