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Bottled Water Code of Practice
Revised January, 2007

International Bottled Water Association 1700 Diagonal Road, Suite 650 Alexandria, VA 22314 (703) 683-5213 http://www.bottledwater.org

(revised January, 2007) Table of Contents
SECTION Foreword General Requirements Rule 1: Definitions Rule 2: Product Quality andSecurity Rule 3: Good Manufacturing Practices and Operational Requirements Rule 4: Source Water Monitoring Rule 5: Finished Product Monitoring Rule 6: Labeling Requirements Appendix A: Monitoring Matrix - IBWA Model Code Monitoring Requirements Appendix B: Purified Water – Official Monograph (USP XXIII) Appendix C: IBWA Total Coliform Standard of Quality and Laboratory Results Response ProcedureAppendix D: List of State Regulatory Contacts PAGE 3 5 6 9 10 14 15 16 18 23 24 25

This Model Code for Bottled Water has been prepared by the International Bottled Water Association, its membership, Board of Directors, Government Relations Committee, and Technical Committee. For questions about the Model Code contact: International Bottled Water Association, 1700 Diagonal Road, Suite 650,Alexandria, VA 22314. (703) 683-5213.

* Denotes FDA Regulation

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IBWA Code of Practice Revised 01/07

The IBWA Model Bottled Water Regulation, known as the “Model Code,” was first published in 1982. At that time, the U.S. Food and Drug Administration’s regulations for bottled water were limited in scope. IBWAdeveloped a set of standards that could be used as minimum standards to which association members would subscribe and to encourage state agencies to adopt it as a model for their own bottled water regulations. IBWA has continued to advance the Model Code in the 1980s, 1990s, and up to the present day. In November 13, 1995, FDA published a standard of identity and quality for bottled water at 21C.F.R. §165.110. The Model Code was revised to adopt the provisions that FDA had promulgated, but it was still considered a document that could be used to raise the standards for bottled water and distinguish IBWA bottlers from others in the industry. This was done partly by adopting industry and regulatory requirements that were sometimes more stringent than FDA, primarily in the area of goodmanufacturing practices (GMPs). In 2000, IBWA adopted the Hazard Analysis of Critical Control Points (HACCP) system into the Model Code. This was a significant advance for the industry since HACCP was not mandated for bottled water at either the federal or state levels of government. The association felt it was important to adopt HACCP. The IBWA Model Code has adopted many of the state requirementsfor bottled water. However, there are some instances where an individual state requirement may not be included in the Model Code, such as source and finished product monitoring requirements for certain substances, and bulk water hauling regulations. If a bottler sells in a particular state, they must ensure they comply with the state bottled water regulations. IBWA bottler members are encouraged touse the contact list of state regulatory agencies, included in this Model Code at Appendix D, for ready access to state bottled water regulations. In recent years, with improved FDA and state regulations in place, IBWA’s focus began to shift from providing a regulatory model to the following set of principles: The IBWA Model Code is a set of self-regulating industry standards. The Model Codeestablishes a comprehensive set of standards for bottler members to ensure product safety and quality. The Model Code provides specific guidance to current IBWA members. The Model Code is a reference document that provides, in one place, information members need regarding government and industry standards. The Model Code provides valuable guidance to “startup” companies, who are prospective members...
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