This Policy Position Statement reviews issues around the use of
bottled water by the public and the use of water packaged in this
way in emergency situations by drinking water suppliers. 'Bottled
water' includes natural mineral water, spring water and bottled
drinking water supplied to customers in bottles. CIWEM supports
action to inform and protect customers and identifies the following
key actions for policy-makers.
CIWEM's Position on Bottled Drinking Water
- Sustainability: branding and bottling of water
where there already exists a wholesome and safe supply of mains
drinking water cannot be seen as a sustainable use of natural
resources, and adds to the overall levels of waste and pollution to
be managed in modern society.
- Health: there is no general health advantage
in replacing tap water with bottled water, and people should be
protected from false claims in this regard.
- Quality: as a minimum, bottled waters should
meet the requirements of the appropriate Codex
Standard 1 of the Food and Agriculture Organization
of the United Nations World Health Organization.
- Labelling: the labels on bottles in which any
treated or untreated water offered for sale to the public should
include a chemical and bacteriological analysis of the water and
the dates of bottling and analysis. An EU-defined standard for the
labelling of bottled waters would be helpful.
- Infant nutrition: except where it can be
demonstrated that a bottled water is suitable for the purpose, it
should be made clear to health officials and parents preparing
infant formula or follow-on formula milk that tap water rather than
bottled water should be used in its preparation 2
. Bottles of water which have not demonstrated suitability
should be required to carry a warning to this effect.
- Emergencies: drinking water suppliers should
have available to them sufficient bottled water or other means of
providing their customers who are likely to be left without mains
water in an emergency with 7 litres per person per day of
- Energy: use of energy should be minimised in
the production, packaging, transportation and sale of bottled
water, and in the transport of packaging for disposal.
- Disposal/refilling/recycling of empty water
bottles: should be undertaken at the least cost to the
environment. The responsibility for this should lie with the
bottled water producer.
The Chartered Institution of Water and Environmental
Management (CIWEM) is the leading professional body for the people
who plan, protect and care for the environment and its resources,
providing educational opportunities, independent information to the
public and advice to government. Members in 98 countries include
scientists, engineers, ecologists and students.
Bottled drinking water is now a multi-billion pound
international industry. In the UK alone the market grew from
several hundred litres a year to 1,692 million between 1993 and
Potable water from the tap is subjected to stringent quality
controls, and the public is able to easily access information about
its bacteriological and chemical content, for example via the Drinking Water
Inspectorate website. Its price is subject to rigorous control
and is, on average, 500 times lower than that of bottled
Bottled water is being consumed in huge amounts by the public,
yet its labelling is not required to reflect its chemical and
bacteriological content and, while some companies choose to
disclose this information, others do not and it is not mandatory
that they should make such information publicly available. While
the 2003 EU Regulations10 now set quality standards for
all bottled water, there are still no labelling requirements to
enable people to judge for themselves from a standardised set of
information whether the beverage is suitable for their nutritional
needs, nor how it compares in various respects to similar products
and to tap water.
Bottled water marketing has driven a public perception of
bottled waters as purer or healthier than water from the tap. Such
perceptions are unfounded and can lead to undesirable consequences:
tor example, the high mineral content of some bottled waters makes
them unsuitable for feeding babies and young children. This is
recognised in the UK in statutory Regulations11, which
set specific standards for waters that wish to be labelled as
suitable for use in making up infant formula. However, those waters
which have not demonstrated their suitability are not required to
display this fact, so parents might use such water to make up
infant formula feed in the mistaken belief that they are doing
their best for their offspring. CIWEM considers that water
which has not specifically demonstrated its suitability for making
up infant formula feed should be required to carry a warning to
There is a range of environmental costs associated with bottled
waters, which relate to the impacts of abstraction on the local
environment, packaging of the product, resource-use and pollution
resulting from transportation of the product and disposal of the
waste packaging once the water has been consumed.
There are a proliferation of definitions of bottled waters, some
of which are contradictory or vague. CIWEM recommends that the
following definitions should be adopted worldwide in order to avoid
"Natural mineral water" means5
microbiologically wholesome water originating in an underground
water table or deposit and emerging from a spring tapped at one or
more natural or bore exits. Natural mineral water can be clearly
distinguished from ordinary drinking water:
(a) by its nature, which is characterised by
its mineral content, trace elements or other constituents and,
where appropriate, by certain effects;
(b) by its original state,
both characteristics having been preserved intact because of the
underground origin of such water, which has been protected from all
risk of pollution.
"Spring water" means6 water that has been
extracted from a spring.
"Bottled drinking water" means6 water
intended for sale for drinking by humans which is not natural
mineral water or spring water. In practice this
means that bottled water may simply be filtered tap water.
Bottles can be containers of any size and of any food grade
material. These will include plastic and glass bottles and carboys.
Plastic bags are also used for emergency water supply.
Consumers need to be protected from false claims regarding the
effects of tap water vis-à-vis bottled water on their health.
Particular regard should be made to implications that tap water
damages human or animal health, and that bottled water is healthier
CIWEM supports the following WHO position on the health benefits
of drinking bottled water7:
"In European and certain other countries, many consumers believe
that natural mineral waters have medicinal properties or
offer other health benefits. Such waters are typically of high
mineral content and, in some cases, significantly above the
concentrations normally accepted in drinking water. Such waters
have a long tradition of use and are often accepted on the basis
that they are considered foods rather than drinking water per
se. Although certain mineral waters may be useful in providing
essential micro-nutrients, such as calcium, WHO is unaware of any
convincing evidence to support the beneficial effects of consuming
such mineral waters. As a consequence, WHO Guidelines for
Drinking Water Quality do not make recommendations regarding
minimum concentrations of essential compounds.
"On the other hand, in some countries, bottled waters with very
low mineral content, such as distilled or demineralised waters, may
be offered for sale. While a large number of people have
traditionally consumed rainwater which is similarly low in minerals
without apparent adverse health effects, WHO has no scientific
information on the benefits or hazards of regularly consuming these
types of bottled waters."
Under European regulations, all bottled water both produced and
imported within the EU is required to meet certain standards with
regard to mineral composition, microbiological content
etc10. Where national regulations are not in place to
control the quality of bottled water it is appropriate to use for
such control International standards of purity, such as those set
out in the EU Regulations10 the Codex
Standards1 published by the Food and Agriculture
Organization of the United Nations World Health Organization.
In Europe, practices and regulations for the labelling of
bottled waters vary from country to country with some requiring an
analysis of the contained water to be shown on the label and some
not. CIWEM suggests that a uniform, EU-defined, standard would be
helpful to customers.
When formula or follow-on formula milk is prepared correctly in
accordance with the instructions of the manufacturer CIWEM
considers that there should be no bacteriological danger when
bottled or tap water is used in their preparation. Where water
quality equivalent to that of tap water cannot be guaranteed in
bottled water, then using the bottled water to make up formula or
follow on formula milk for feeding to infants or young children is
inappropriate. CIWEM also considers that advice should be available
to health professionals and parents that the high mineral contents
of some bottled waters should preclude them from being used for
preparing formula or forward formula milk. They should be aware
that there are certain bottled waters that have applied for a
designation to indicate their suitability, and that where the water
has been proven to meet strict standards, this is shown on the
At least one major bottled water trade association contends that
bottled water stored correctly will have an indefinite shelf
life8. While this may or may not be true, CIWEM
considers that customers need to be informed of the date when the
water was bottled especially since another
sources9 puts a viable shelf life for
bottled water at one or two years.
Emergency drinking water supplies
CIWEM considers that the stockpiling of bottled water is
necessary, in order for public and private water suppliers to meet
the requirement to provide an adequate emergency supply of water
for drinking. How they will provide these emergency supplies needs
to be planned and organised. In many countries water suppliers are
required by regulation to do this and many use bottled water for
this purpose. Other vehicles such as water bowsers and flexible
plastics containers are used for the stockpiling of emergency
drinking water and CIWEM considers these to be valid
The abstraction, processing, packaging, transportation and sale
of bottled water, and disposal of associated waste, involves a
significant amount of energy use and pollution. When placed in the
context of consumption of safe and wholesome tapwater, it is hard
to view this as anything other than unsustainable.
Nevertheless, in a free market economy consumers have the right to
purchase bottled water and companies to serve this demand. CIWEM
therefore considers that there is a need to ensure that the
environmental impacts of bottled water production are minimised and
made clear to consumers in labelling.
A major contribution to the cost of bottled water is likely to
be transport, certainly where transport is international. The World
Wide Fund for Nature argues that the distribution of bottled water
requires substantially more fuel than delivering tap
water4. This is especially true since over 22 million
tonnes of the bottled liquid is transferred each year from country
to country. Instead of relying on a mostly pre-existing
infrastructure of underground pipes and plumbing, transporting
bottled water burns fossil fuels and results in the release of
thousands of tonnes of harmful emissions. This situation
could be ameliorated somewhat if international brands were to
licence local supplies to be bottled under their names.
Since some bottled water is also shipped or stored cold,
electricity is expended for refrigeration. Energy is likewise used
in bottled water processing. In filtration, an estimated two
gallons of water are wasted for every gallon
Most containers for bottled water are made from non-degradable
plastics and are not reused or recycled: amounts of plastic waste
generated every year are estimated at half a million tonnes. With
both landfill and incineration becoming the options of last choice,
reusing and recycling containers would benefit the environment and,
increasingly, are likely to be cost-effective options.
A WWF Discussion Paper4 points out that PET is
increasingly chosen for bottles instead of PVC because of its
properties: it is light, easy to work on and very transparent. It
can be re-manufactured into many different products, such as fibres
for the clothing industry. When incinerated, it does not release
chlorine into the atmosphere, unlike PVC.
Negative environmental impacts, in particular energy
consumption, are reduced if PET, aluminium and glass packages are
washed and re-filled rather than re-manufactured, and strict
hygiene criteria must obviously be applied in such situations.
Regardless of the material of manufacture, CIWEM considers that
bottles should as far as possible be reused and recycled locally.
However, it is important that if bottles are to be washed and
re-filled, this is only undertaken where water is bottled and
distributed to a local market, otherwise the benefits of re-using
bottles will be negated by transportation of empty bottles.
- Codex Alimentarius Commission: Codex Stan. 108
- 2001 "Codex Standard for Natural Mineral Waters and Codex Stan.
227 - 2001 "General Standards for Bottled/Packaged Drinking Waters
(Other than Natural Mineral Waters).
- Department of Health: Bottle feeding. Leaflet
No. 31640 2p 500k February 04.
- World Health Organisation: Technical Notes for
Emergencies No. 9 - Minimum water quality needed for domestic use
in emergencies. Author: Brian Reed.
- World Wide Fund for Nature: Discussion Paper -
"Bottled Water: Understanding a Social Phenomenon". Author:
Catherine Ferrier April 2001.
- European Commission: Council
Directive 80/777/EEC - "COUNCIL DIRECTIVE of 15 July 1980 on the
approximation of the laws of the Member States relating to the
exploitation and marketing of natural mineral waters"
- Her Majesty's Stationary Office: Statutory
Instrument 1999 No. 1540 - Natural Mineral Water, Spring Water and
Bottled Drinking Water Regulations 1999 and Irish Regulation:
European Communities (Natural Mineral Waters, Spring Waters And
Other Waters In Bottles Or Containers) Regulations 2005
- World Health Organisation: Fact Sheet No.256 - Bottled drinking
water. October 2000.
- International Bottled Water Association:
Answer to a question on their Website FAQs http://www.bottledwater.org/content/faqs#9)
- Health Canada: One year (
- EU COUNCIL DIRECTIVE of 15 July
1980 on the approximation of the laws of the Member States relating
to the exploitation and marketing of natural mineral waters
(80/777/EEC)(OJL229,30.8.1980,p.1) as amended
- Food Safety Act 1990 Practice Guidance CHAPTER
3.9: BOTTLED WATERS (
Note: CIWEM Policy Position
Statements (PPS) represents the Institution's views on issues at a
particular point in time. It is accepted that situations change as
research provides new evidence. It should be understood, therefore,
that CIWEM PPS's are under constant review, that previously held
views may alter and lead to revised PPS's. PPSs are produced
as a consensus report and do not necessarily represent the view of
individual members of CIWEM.