Mineral water is water from a mineral spring that contains various minerals, such as salts and sulphur compounds. Mineral water may usually be still or sparkling (carbonated/effervescent) according to the presence or absence of added gases. Much like spring water, it comes directly from protected underground sources. And the minerals are produced organically by the water itself, rather than added later. Just a few of these natural minerals include magnesium, sodium and potassium.
Traditionally, mineral waters were used or consumed at their spring sources, often referred to as “taking the waters” or “taking the cure”, at places such as spas, baths, or wells. The term spa was used for a place where the water was consumed and bathed in; bath where the water was used primarily for bathing, therapeutics, or recreation; and well where the water was to be consumed. Today, it is far more common for mineral water to be bottled at the source for distributed consumption. Travelling to the mineral water site for direct access to the water is now uncommon, and in many cases not possible because of exclusive commercial ownership rights. There are more than 4,000 brands of mineral water commercially available worldwide.
You can only describe a product as natural mineral water if:
- it comes from an underground water source that’s tapped at a natural or drilled exit
- it’s free of parasites and bacteria that cause disease
- the source has been protected from pollution
Bottling must take place at the site of the spring, to avoid contamination.
The water’s composition must:
- have kept its ‘original purity’ – this means its properties have stayed the same from source to bottling, and have not been contaminated
- must be stable (remain consistent) over a period of time when tested
You may want to use treatments to make your water taste better or to make your water comply with the rules to gain recognition.
There are only 5 permitted treatments you can use to improve the water:
- filtration or decanting
- removal of free carbon dioxide
- adding carbon dioxide to produce carbonated or sparkling natural mineral water
- ozone-enriched air oxidation technique
- activated alumina
You need authorisation from the local authority to use ozone-enriched air oxidation technique or activated alumina. When you use any of the 5 treatments, make sure you do not accidentally disinfect the water, as a side effect of the treatment nor add biostatic elements, such as benzyl alcohol, which inhibit the growth of micro-organisms, which alter the total viable colony count.
You can use filtration or decanting to separate unstable elements, like iron, manganese and sulphur in the water. You may want to do this to either reduce the levels of iron, manganese and sulphur in the water or prevent unsightly sediments forming in the bottles during storage. You can use oxygenation before you start filtration, if you wish, to help unstable elements to form into flakes.
When you carry out these methods, you must not alter the mineral, chemical or microbial composition of the water (with the exception of iron, manganese or sulphur). You also must not change the total viable colony count of your water. You can check if this is likely to happen by comparing the total viable colony count before filtration and after, to decide if filtration has had a disinfectant effect on the water.
Getting Recognized
It can take up to 2 years to get a natural mineral water recognised. You should only produce your natural mineral water in bottles or containers after you’ve been granted recognition.
Follow these steps to get recognition.
- Contact the Environment Agency to apply for a water abstraction licence. You’ll need this before you can take water from the spring.
- Get in touch with the local authority in the area the water is extracted from. Ask for an environmental health officer (EHO) within the hygiene team and explain what you want to do. They’ll help you follow the rules to get your water recognised.
- Find out what evidence you need to gather. You may need to use a hydro-geological consultant to gather this evidence.
- Understand how you’ll be allowed to exploit the spring. You need to know this to make sure your natural mineral water is viable to produce.
- Find out what treatments you can use. You need to know this to make sure your natural mineral water is viable to produce.
- Check the rules to follow when labelling. If you want to claim your water has therapeutic qualities, you’ll need to follow extra rules.
- When you’ve produced all the evidence to show that your water meets the conditions for recognition, send your application to your EHO in the local authority.
- If the local authority grants recognition, they’ll put this in writing to you. If your business is not yet registered as a food business with the local authority, you must do this now.
If the local authority refuses to grant recognition, you can appeal to Defra.
You’ll usually need to produce the following documents, gathering data over 2 years:
- geological and hydrological surveys
- physical, chemical and physio-chemical surveys
- a report on what chemicals are naturally present in the water at source
- a report on what chemicals are artificially present in the water at source
- a report to show the water is free of parasites and bacteria
- a list of any treatments you plan to use
You may need to use a hydrogeological consultant to produce these documents. You need to produce surveys to show the type of land that the spring sits in and the rock structure.
These surveys should show:
- the exact site of the catchment (the area that captures the water) with an indication of its altitude on a map with a scale of not more than 1:1000
- the boundaries of the area surrounding the spring
- a detailed geological report on the origin and nature of the land
- the stratigraphy of the hydrogeological layer (a study of the different layers of rock to understand the geological history)
Testing
Test the water at source every 6 months to prove that your water is free of parasites. Every 3 months, you must test and show an absence of the following bacteria in certain testing conditions. You’ll also need to ask your laboratory to test the total viable colony counts every 3 months, both at source and after bottling.
The total viable colony counts are the total number of bacteria picked up by the test. The results, after bottling, should not exceed:
- 100 per millilitre when tested at 20 to 22°C in 72 hours on agar-agar or agar-gelatine mixture
- 20 per millilitre when tested at 37°C in 24 hours on agar-agar
Use this table to see how often you should carry out testing during the 2-year sampling period to get recognition.
Physio-chemical tests                                                                    How often
Rate of flow and water temperature at source                   Every month
Ambient temperature                                                                  Every month
Dry residues at 180°C and 260°C                                               Every month
Electrical conductivity                                                                   Every month
Anions, cations and non-ionised compounds                      Every 3 months
Natural chemicals and minerals                                                Every month
Artificial chemicals                                                                          Once
Pesticides                                                                                           Every 3 months
Microbiological tests                                                                     How often
Absence of all parasites                                                                Every 6 months
Absence of specific bacteria, such as E coli                            Every 3 months
Total viable colony count                                                             Every 3 months
Once proven, include your laboratory reports in your application for recognition to the local authority.
Bottling and Transporting
Your bottling plant must be based at the spring. You must meet hygiene requirements when you bottle and produce the water, bottle in containers with caps or lids, to avoid tampering or contamination, use containers that are made to food-grade standards to avoid adverse effects on the microbiological and chemical characteristics of the water. If you find that your natural mineral water has become polluted at any stage, you must stop bottling from the spring until the cause of the pollution is removed.
You must transport your natural mineral water from your plant in bottles or containers that the final customer will use. The only exception to this is if, on or before 17 July 1980, you were transporting water from the spring to a bottling plant further away, in containers not intended for the final customer. If this applies to you, you can continue transporting using the same containers.
Water Labelling
You must put the following on your labelling:
- type of product
- name of spring and place where the water is exploited
- composition
- details of treatments you’ve used
- fluoride content, if there’s more than 1.5 milligrams per litre in the water
You can put the following if you want to:
- trade description
- health claims
- mineral claims
You must put ‘natural mineral water’ on your labelling. This describes the product and is known as the ‘sales description’. You cannot sell it as any other type of water, such as spring water. If you’re producing carbonated or sparkling natural mineral waters, you’ll need to use slightly different sales descriptions.
On the label, you must put the name of the:
- spring – if the spring doesn’t have a name, you must give it one
- place where the spring is exploited, for example, you could name the town or village
You must not be misleading when you use a town, village or place name.
You must put the composition on the label, showing the mineral and chemical contents of the water. If you’ve treated your natural mineral water to totally or partially eliminate free carbon dioxide, you must put on the label either fully de-carbonated or partially de-carbonated. If you’ve used an authorised ozone-enriched air oxidation technique, your label must contain the words ‘water subjected to an authorised ozone-enriched air oxidation technique’ close to the composition of minerals and chemicals on the label. For any other treatments, you do not need to list any wording on your bottled water label.
Usually, you must sell all-natural mineral water from the same spring or borehole using only one trade description. You cannot sell it under a second name. For example, if you already sell ‘ABC Natural Mineral Water’ you’re not allowed to sell a new batch from the same spring using the name ‘DEF Natural Mineral Water’.
The only exception is if you want to sell your water to a retailer, such as a supermarket, hotel, stadium, museum, venues or cafe, and include their logo. The best practice way to do this is to sell your water with both your trade description and the retailer’s own logo. For example, add the retailer’s logo to your label provided it’s still clear that the water comes from your brand. In this scenario, the retailer’s logo does not count as a second trade description.
Alternatively, you can choose to not have a trade description, remove your brand name and sell the water with only the retailer’s logo. You can do this as long as the retailer’s logo is clearly separate from the sales description ‘natural mineral water’.
To maintain recognition you should continue to assess your spring protection and other risks, for example risks posed by operations going on in your catchment area and tell the local authority and Defra if there’s any change which causes a risk to human health. You must also make sure the water is safe and meets the rules by both continually testing the water to show it does not exceed chemical and microbiological limits – the law does not set out how often, so you should agree this with the local authority and designing and implementing Hazard Analysis Critical Control Point (HACCP) based procedures for the safety of the water – talk with the local authority about how to do this
