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Chapter 5
Misleading Bottled Water Labeling and Marketing

In 1995, FDA issued "standards of identity" -- essentially labeling rules, in response to a petition from the International Bottled Water Association (IBWA). [230] These rules were widely acclaimed as a breakthrough that would prohibit misleading claims by unscrupulous water bottlers. While the rules do prohibit some of the most egregiously deceptive labeling practices by bottlers, they have by no means eliminated the problem.

Some Bottled Water Labels Remain Misleading to Consumers

The Institute of Medicine, an arm of the National Academy of Sciences, found in a 1992 study that deceptive bottled water labeling was a widespread practice, with state authorities exasperated about FDA inaction in the face of frequent statements and vignettes indicating or implying that the bottled water was far purer than tap water or came from specific sources or had purity levels that may not have been justified. [231]

Many of these practices continue. For example, FDA rules allow bottlers to call their product "spring water" -- which seems to carry cachet with consumers as being especially natural and pure -- even though it may be brought to the surface using a pumped well, and even though it may be treated with chemicals. FDA merely requires that the geologic formation that is tapped by the well must come to the surface somewhere, sometimes, to allow the water pumped to the surface in a well to be called spring water. [232] Among the more interesting labels we have run across:

  • "Spring water" (with mountains and a lake on the label) actually from an industrial parking lot next to a hazardous waste site, ruled not misleading. A well located in the middle of an industrial warehouse facility and next to a state-designated industrial waste site in Millis, Massachusetts, produced this water, contaminated with industrial solvents including trichloroethylene at levels above EPA and FDA standards. The label gracing at least one of the many brands that used this water depicted a beautiful mountain in a reflection off a lake and was called "spring water." In response to a request from the state of Massachusetts, FDA opined that this label was acceptable so long as the water does come to the surface sometimes (it sometimes does in an unpaved area near the parking lot), and as long as "there is no claim to the effect that the location pictured in the vignette is the actual spring, we would not consider the label vignette to be in violation of our requirements." [233] Apparently, after public disclosure of the true source of the water and contamination problems, this well is no longer being used for bottled water.
  • "Alasika™ - Alaska Premium Glacier Drinking Water: Pure Glacier Water From The Last Unpolluted Frontier, Bacteria Free" apparently from a public water supply. This water actually came from "Public Water System #111241" (a public water system in Juneau, Alaska), according to documents in Washington State files. The bottler evidently was told that when it reordered its labels, it had to state that the water is "from a municipal source" or "from a community water system," in keeping with FDA rules; the phrase "pure glacier water" was, per documents in state files, "considered false and misleading." The bottler was required to drop the "bacteria free" claim, as this was "considered synonymous with sterile and false." This water no longer claims to be "glacier water" or "bacteria free." However, NRDC has found several other brands sold as "glacier" water even though they apparently come from groundwater nowhere near any current glacier.[234]
  • Vals Water "Known to Generations in France for its Purity and Agreeable Contribution to Health...Reputed to Help Restore Energy, Vitality, and Combat Fatigue." While the IBWA voluntary code prohibits health claims, some bottlers still make such claims.

In addition to these instances of bottled water labels, far more common -- in fact exceptionally widespread -- is the use of descriptive terminology that suggests bottled water is extraordinarily pure and uncontaminated. As an example, our review of the labels and Web site vignettes and advertising of about 50 IBWA members found the following terms used:

  • "Pure" -- eight bottlers.
  • "Purest" or "Purity" -- three bottlers.
  • "Pristine" -- five bottlers.
  • "Glacial" -- two bottlers.
  • "Natural" or "Prepared by Nature" -- eight bottlers.
  • "Naturally Purified" or "Naturally Occurring" -- three bottlers.
  • "Premium" -- five bottlers.
  • "Mountain Water" -- seven bottlers.
  • "Clean" -- two bottlers.
  • "Good Health" or "Healthy" -- two bottlers
  • "For Health Conscious" -- two bottlers

Thus, representations about bottled water purity, premium and natural sources, and healthfulness remain extremely widespread. The FDA rules seem to have little effect on bottlers' claims of water purity and cleanliness.

Bottled Water Marketing is Often False or Misleading

Bottled water marketing seeks to emphasize the supposed purity of bottled water, in many cases contrasting "pure" and "protected" bottled water with "inconsistent" or unpredictable tap water quality. In the words of a leading industry consultant, "Water bottlers are selling a market perception that water is 'pure and good for you'...." [235]

This effort to create a "market perception" of purity is an advertising mandate for the industry, notwithstanding the fact that just because water comes from a bottle does not mean that it is any purer than tap water, as we have seen in previous chapters. Among the common industry claims about bottled water that are of questionable veracity or that are clearly incorrect are:

  • Bottled water contains "no" chlorine or harmful chemicals. This claim is boldly featured on IBWA fact sheets and its Web site. [236] It clearly is false, as previous chapters have shown.
  • Bottled water is always high quality, whereas tap water is of inconsistent quality. IBWA often points out that "unfortunately, tap water can be inconsistent -- sometimes it might be okay and other times it is not." On the other hand, IBWA says, "quality is in every container of bottled water. It's consistent and it is inspected and monitored by governmental and private laboratories." [237] What IBWA neglects to point out, however, is that in many cases bottled water does contain contaminants, that most tap water is required to be monitored more often than bottled water (and testing must be done by government-certified labs, which is not the case for bottled water), and that about one fourth or more of the bottled water sold in the United States is derived from the same tap water IBWA says is of inconsistent quality.
  • No waterborne illness has been traced to bottled water. IBWA claims that "According to the Centers for Disease Control and Prevention (CDC), bottled water has never been responsible for an outbreak of waterborne illness." [238] In fact, as discussed in the Technical Report (print report only) and Appendix B, there have been waterborne-disease outbreaks traced to bottled water. For example, a bottled water-related cholera outbreak in U.S. territory in the Pacific was written up in 1996 in CDC's flagship journal, Morbidity and Mortality Weekly Report, and other outbreaks traced to bottled water in Portugal and elsewhere have been documented. [239]
  • Cryptosporidium cannot get into bottled water. The IBWA's fact sheets and Web site make the repeated claim that FDA rules "ensure that surface water contaminants such as Cryptosporidium and Giardia are not present" in bottled water derived from groundwater, and that all IBWA members using municipal water "reprocess this water [and] employ methods such as reverse osmosis, deionization, distillation, and filtration," implying this eliminates any risk. IBWA also implies that bottled water is safe for the immunocompromised. [240] There is no evidence that bottled water is truly immune from Cryptosporidium or Giardia unless it is fully protected and treated with EPA-CDC recognized best available technologies, and much bottled water does not receive this treatment. Indeed, internal industry communications highlight that IBWA is well aware that some bottlers do not use these treatment technologies. [241]
  • Imported bottled water must meet all U.S. rules. IBWA states that "any bottled water sold in the United States must meet all of the same regulations as domestically produced water." [242] But what is not mentioned is that FDA's Good Manufacturing Practices, source approval, and source-water-testing requirements apply at the source or bottling facility and are impossible for FDA to enforce when such facilities are outside of the United States. FDA does not conduct any foreign inspections of bottlers, so the degree to which foreign bottlers comply with these FDA rules is not known. What is clear, however, is that these FDA rules do not apply equally to foreign bottlers.

Although these claims may not be the most exaggerated of those made by the industry, they are troubling in that all of them are made by the leading industry trade association.

Also of concern is a major IBWA public relations campaign intended to persuade the public to drink more bottled water. The campaign, funded by IBWA members, is aimed to be "a comprehensive campaign to educate third-party groups and the media about the safety and quality of bottled water." The campaign includes slick advertising and fact sheets. Also central are briefings of the media, nonprofit health organizations, and groups representing the immunocompromised and retired persons. The campaign has also taken other steps, such as the sponsorship of an American Dietetic Association meeting. Mailings have been made to thousands of advocacy groups, members of the media, environmental and health groups. Several news stories have been placed, and expanded briefings in more cities were planned.

Thus, in a well-orchestrated effort, the bottled water industry has made major inroads into the public psyche, reinforcing perceptions about the purity of bottled water. While this clearly is within the industry's rights, it is important that bottlers not overstate their case or mislead the public into believing that bottled water is safer or better protected than is the case.

Report Notes

230. Codified at 21 C.F.R. Part 165.

231. IOM, Committee on State Food Labeling, Food and Nutrition Board, National Academy of Sciences, Food Labeling: Toward National Uniformity (1992); 58 Fed. Reg. 389, p. 406 (January 5, 1993).

232. 21 C.F.R. § 165.110(a)(vi).

233. Letter from Shellee Davis, FDA, to Dr. Liz Bourque, MDPH, June 6, 1996.

234. Washington State Department of Agriculture Food Establishment Inspection Report April 17, 1997, and attachments; WSDA Food Establishment Inspection Report October 4, 1996, and attachments; WSDA Food Processor Licensing Worksheet and Attachments, and WSDA Food Establishment Inspection Report and Attachments, March 20, 1996. Personal communication with Shelly Haywood, USDA, Jan. 1999. For other waters claiming to be "glacier" water, see e.g., "Bottled Water/Carbonated Beverage Files: Current Permitholders," MDPH (January 1999).

235. H.R. Hidell, "Water: The Search for a Global Balance," Bottled Water Reporter, p. 53 (June/July 1995), (emphasis added).

236. See, e.g., IBWA's Bottled Water FAQs, "www.bottledwater.org/faq."

237. Ibid.

238. Ibid.

239. CDC, "Surveillance for Waterborne-Disease Outbreaks--United States, 1993-1994, Morbidity and Mortality Weekly Report vol. 45, no. SS-1 (April 12, 1996). See also Appendix B regarding waterborne disease outbreaks.

240. Ibid., and "www.bottledwater.org/facts/immuno.html."

241. As noted in a previous chapter, for example, an article in the IBWA's in-house organ that urged bottlers to upgrade their treatment to be sure it meets CDC guidelines for removing Crypto, pointed out: "How can we expect health groups to endorse our product if we don't ALL meet the [CDC Crypto removal] guidelines!" Sylvia Swanson, "IBWA in the Forefront," Bottled Water Reporter, p. 37 (December/January 1996).

242. See, e.g., IBWA's Bottled Water FAQs, "www.bottledwater.org/faq."

last revised 7/15/2013

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