Guidance

Natural mineral water: how to produce and label in England

How bottled water producers can get a natural mineral water recognised in England, and rules you need to follow to produce and label it.

From:
Department for Environment, Food & Rural Affairs
Published
28 May 2020
Last updated
13 November 2020 — See all updates

Applies to England

This guide is for people or businesses who want to:

  • use a spring in England to produce natural mineral water
  • sell the natural mineral water in the UK

You must get official recognition for your natural mineral water before you can market and sell it.

To use a spring in:

What counts as natural mineral water

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

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

There are only 5 permitted treatments you can use to improve the water.

Bottling must take place at the site of the spring, to avoid contamination.

Composition must be stated on the label.

Check the different types of bottled water if you’re not sure which type you have.

You can also check if your water is exempt from the rules.

How to get recognition for a natural mineral water from a spring in England

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.

  1. Contact the Environment Agency to apply for a water abstraction licence. You’ll need this before you can take water from the spring.

  2. 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.

  3. Find out what evidence you need to gather. You may need to use a hydro-geological consultant to gather this evidence.

  4. 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.

  5. Find out what treatments you can use. You need to know this to make sure your natural mineral water is viable to produce.

  6. Check the rules to follow when labelling. If you want to claim your water has therapeutic qualities, you’ll need to follow extra rules.

  7. 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.

Evidence you need to gather for recognition

Check with the local authority:

  • what evidence they need from you
  • in what format you should provide the evidence

You’ll usually need to produce the following documents, gathering data over 2 years:

You may need to use a hydrogeological consultant to produce these documents.

You should check that the laboratory testing your water has received third party accreditation for carrying out the method of testing that you have requested.

When you’ve got all this data, you should be able to prove that the mineral, chemical and microbial levels in your water remain stable. This means these levels do not change more than 20% from when the water was first tested.

Geological and hydrological surveys

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)

You should also give a description of all industry or other activities in the catchment area that could affect the water source. For example:

  • permitted sites (active and closed), for example, a chemical plant
  • storage and disposal of waste
  • general land uses
  • nitrate vulnerable zones
  • details of any measures to protect the spring against pollution

Physical, chemical and physio-chemical surveys

Record the following monthly:

  • rate of the spring’s flow
  • temperature of the water at source
  • ambient temperature
  • dry residues at 180°C and 260°C to show the total mineral content in the water
  • electrical conductivity or resistivity (the water’s capacity to transfer electricity) - these should show the temperature of water when tested

Also record these factors once during the period of gathering evidence for recognition:

  • relationship between the nature of the land and the nature and type of minerals in the water
  • hydrogen ion concentration (pH)
  • radio-actinological properties at source (a study of the effect of light on chemicals)
  • relative isotope levels of the constituent elements of water, oxygen (0-01816) and hydrogen (protium, deuterium, tritium) if needed

You need to test for anions, cations, non-ionised compounds or trace elements to show what levels are in the water. Test these every 3 months. Show your results in milligrams per litre.

Type What you need to test
Anions Borate BO3-
Carbonate CO32
Chloride Cl-
Fluoride F-
Hydrogen Carbonate HCO3-
Nitrate NO3-
Nitrite NO2-
Phosphate PO BO43-
Silicate SiO2
Sulphate SO42-
Sulphide S2-
Cations Aluminium A1
Ammonium NH4+
Calcium Ca
Magnesium Mg
Potassium K
Sodium NA
Non-ionised compounds Total organic carbon C
Free carbon dioxide CO2
Silica SiO2
Trace elements Barium Ba
Bromine (total) Br
Cobalt Co
Copper Cu
Iodine (total) I
Iron Fe
Lithium Li
Manganese Mn
Molybdenum Mo
Strontium Sr
Zinc Zn

Chemicals naturally present in the water at source

On a monthly basis, check for chemicals that are naturally present in the water, and not as a result of contamination or human intervention.

They should not exceed the following maximum limits.

Chemical Maximum limit (milligrams per litre)
Antimony 0.0050
Arsenic (as total) 0.010
Barium 1.0
Cadmium 0.003
Chromium 0.050
Copper 1.0
Cyanide 0.070
Fluoride 5.0
Lead 0.010
Manganese 0.50
Mercury 0.0010
Nickel 0.020
Nitrate 50
Nitrite 0.1
Selenium 0.010

Chemicals artificially present in the water at source, as a result of human intervention

Your water should not exceed maximum limits for the following.

Substance Maximum limits that Defra advises
Polynuclear aromatic hydrocarbons (PAHs) 0.01 micrograms per litre for individual substances
Volatile organic compounds 1.0 micrograms per litre for individual substances
Trihalomethanes (THMs) 1 micrograms per litre for individual substances
Pesticides 0.1 micrograms per litre for the total of all individual pesticides and their metabolites

0.03 micrograms per litre for aldrin, dieldrin, hepatchlor and heptachlore epoxide

You only need to test your water once at source. Do this at any point during the time you’re gathering evidence for recognition.

If your water exceeds any of the maximum limits, you usually must investigate the cause of the pollution and take measures to remove it, if you want to get recognition.

Talk with the local authority before you take any measures to remove the pollution.

Parasites and bacteria

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.

Show absence of these bacteria Conditions of testing
Escherichia coli 0 in 250 ml at 37°C and 44.5°C
Other coliforms 0 in 250 ml at 37°C and 44.5°C
Faecal streptococci 0 in 250 ml at any temperature
Pseudomonas aeruginosa 0 in 250 ml at any temperature
Sporulated sulphite-reducing anaerobes 0 in 50ml in any temperature

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

Collect samples within the first 12 hours after bottling.

Keep the water between -1°C and 4°C before sending it to the laboratory.

Summary of all tests and how often to carry them out

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 (this indicates the total mineral content) Every month
Electrical conductivity (the water’s capacity to transfer electricity) 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 in certain testing conditions 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.

Rules for exploiting the spring

You must make sure that:

  • any equipment you use to collect the water, such as pumps, preserves the properties of the water and avoids all risk of contamination
  • the source or borehole is protected against pollution
  • pipes and reservoirs are made to food-grade standards, suitable for water, and are built to prevent any chemical, physio-chemical or microbiological change to the water

Bottling or using containers

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.

How you’re allowed to transport the water

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.

Treatments you can use

You may want to use treatments to make your water taste better or to make your water comply with the rules to gain recognition.

You can only use the following 5 treatments:

Write about any treatments you intend to use in your application.

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
  • add biostatic elements, such as benzyl alcohol, which inhibit the growth of micro-organisms, which alter the total viable colony count

Filtration or decanting

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
  • 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 (known as flocculation).

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.

If it has, then you cannot use the treatment in the way you’ve approached it. Try again in a different way.

Removal of free carbon dioxide

You must only use physical methods to remove free carbon dioxide. You must not use chemical methods.

Adding carbon dioxide

You can only produce carbonated or sparkling spring water by introducing or re-introducing carbon dioxide. You must not use any other type of gas.

Ozone-enriched air oxidation

You can use ozone-enriched air oxidation to separate compounds of iron, manganese, sulphur and arsenic from water when they occur naturally at source.

You can only use this treatment if all the following apply:

  • before you start, you’ve met the conditions for exploiting the spring
  • the treatment does not have an accidental disinfectant effect
  • the treatment does not alter the composition of the water in terms of its minerals, chemicals and microbes (other than iron, sulphur and manganese)
  • it does not leave residues in the water that could pose a risk to public health

Any residues caused by treatment must not exceed the following levels.

Treatment residue Maximum limit (milligrams per litre)
Dissolved ozone 50
Bromate 3
Bromoform 1

You must get authorisation to use this treatment. You need to:

  • write to the local authority in the area where the water is extracted
  • allow them to examine your proposed method of treatment, place of treatment and take samples for analysis
  • provide any information the local authority asks for

Authorised activated alumina treatment

You can only treat your water with activated alumina if:

  • you’re aiming to remove fluoride
  • you remove fluoride following technical rules

Any residues released into the water as a result of removing fluoride must be as low as technically possible and should not pose a risk to public health.

You’ll need to make sure:

  • the treatment does not have an accidental disinfectant effect
  • you get permission from the local authority at least 3 months before you start this treatment
  • you allow the local authority to examine your proposed method of treatment, place of treatment, and take samples for analysis
  • you provide any information the local authority asks for

Getting authorisation for ozone-enriched air treatments or activated alumina

A local authority can authorise activated alumina or ozone-rich air oxidation treatments if they’re satisfied that:

  • the treatment is justified due to the composition of the water at source
  • you’ve taken any measures needed to make the treatment safe and effective
  • you’ve complied with the treatment rules

They must tell you in writing the date the authorisation for the treatment starts.

If they refuse to authorise a treatment, they must tell you in writing, stating their reasons.

When a local authority can withdraw authorisation for a treatment

If you’ve already got an authorisation but the local authority believes that you’re no longer meeting conditions for authorisation, they can withdraw it by sending you a written notice stating their reasons.

How to appeal on treatments

If the local authority has refused to authorise or withdraws authorisation of a treatment, you can ask Defra for a review of the decision by emailing bottled.water@defra.gov.uk.

Defra will consider your case and will either:

  • confirm the decision the local authority took is correct
  • tell the local authority to grant or restore authorisation

Labelling rules

You must put the following on your labelling:

You can put the following if you want to:

Type of product (sales description)

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 set out in this table.

Sales description to use Criteria
‘naturally carbonated natural mineral water’ Water with a carbon dioxide content that is the same after bottling as it was at source.

You can only reintroduce carbon dioxide from the same spring, and only to the same level as it occurs naturally at source. You can’t add any more.
‘natural mineral water fortified with gas from the spring’ Water with a carbon dioxide content that is greater after bottling than it was at source after bottling.

You can only reintroduce carbon dioxide from the same spring but you can add more than occured naturally at source.
‘carbonated natural mineral water’ Water which contains added carbon dioxide from somewhere else and not from the original source.

You can also add the word ‘sparkling’ for any of these 3 products on your label, if you wish. This is in addition to (not instead of) ‘carbonated’.

Name of spring and place where spring is exploited

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.

Composition

You must put the composition on the label, showing the mineral and chemical contents of the water.

If you’ve used treatments

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
  • 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 the label.

Fluoride

If fluoride in your water is measured at more than 1.5 milligrams per litre, you must state on the label:

‘contains more than 1.5 mg/l of fluoride: not suitable for regular consumption by infants and children under 7 years of age’.

You must put this close to the trade description, if you have one, and in clearly visible characters.

You should also put the fluoride content in the composition box.

Trade description (optional)

The ‘trade description’ is also known as the brand name. For example, Buxton, Celtic Vale or Hildon.

You do not have to have a trade description for your natural mineral water. You can market it without.

If you choose to have a trade description, you must follow the rules set out in this section.

Trade description: using the place where it’s exploited

You may want to use the place of exploitation as a trade description. You can do this as long as your spring is located there.

You cannot be misleading. For example, you cannot name your water after a town in Somerset if your spring is in Devon.

If you choose to use as your trade description the:

  • place it’s exploited, then you must put the name of the spring elsewhere on the label
  • name of the spring, then you must put the place where it’s exploited elsewhere on the label

Trade description: using a trade description that’s different from the name of the spring and place of exploitation

If you want to do this, then you must put the letters of the name of the spring and place of exploitation in a font at least one and a half times the height and width of the largest of the letters used for your trade description.

Trade description: you cannot have more than one

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
  • 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’.

If you have questions about this, speak with your local authority contact.

If you want to make health claims (optional)

You’re allowed to use certain health claims on the label if you carry out studies and comply with the rules in this section.

Health claims could be one or more of the following:

  • ‘may be diuretic’
  • ‘may be laxative’
  • ‘stimulates digestion’
  • ‘may facilitate the hepato-biliary functions’

You must carry out medical studies to show your claims are true.

To do this, you must:

  • use scientifically recognised methods
  • prove a substantial number of clinical observations demonstrate the same results

You cannot make any other human health claims.

Mineral claims (optional)

If your water meets any of the following mineral criteria, you can use the relevant wording on your labels.

Criteria Wording you can use on label
Mineral salt content, calculated as a fixed residue, not greater than 500 mg/l Low mineral content
Mineral salt content, calculated as a fixed residue, not greater than 50 mg/l Very low mineral content
Mineral salt content, calculated as a fixed residue, greater than 1500 mg/l Rich in mineral salts
Bicarbonate content greater than 600 mg/l Contains bicarbonate
Sulphate content greater than 200 mg/l Contains sulphate
Chloride content greater than 200 mg/l Contains chloride
Calcium content greater than 150 mg/l Contains calcium
Calcium content greater than 150 mg/l Contains calcium
Magnesium content greater than 50 mg/l Contains magnesium
Fluoride content greater than 1 mg/l Contains fluoride
Bivalent iron content greater than 1 mg/l Contains iron
Free carbon dioxide content greater than 250 mg/l Acidic
Sodium content greater than 200 mg/l Contains sodium
Sodium content less than 20 mg/l Suitable for a low-sodium diet

If you use natural mineral water as an ingredient in soft drinks

You can list the term ‘natural mineral water’ as an ingredient in soft drinks. You’re allowed to do this as long as the water meets the natural mineral water rules in this guide, at the point you add the first extra ingredient, such as syrup.

After you’ve submitted your application for recognition

The local authority must:

  • decide whether your water meets the conditions to be recognised as a natural mineral water
  • grant or refuse recognition

If recognition is granted

The local authority must notify you and Defra as soon as your recognition is granted.

It also needs to publish in the London Gazette:

  • an announcement of the recognition
  • the grounds on which it has been granted

If recognition is refused

You can appeal to Defra by emailing bottled.water@defra.gov.uk.

Defra will review your case and either:

  • confirm the local authority’s decision was correct
  • tell the local authority to grant or restore recognition
  • grant or restore the recognition itself

How 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
  • 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
  • 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

The local authority should visit you at your bottling plant at least once a year to check:

  • the hygiene of your bottling operations
  • you’re testing the water correctly
  • you’re still meeting the rules

How your recognition can be withdrawn

If the local authority decides that your natural mineral water no longer meets the rules, they can withdraw recognition until you meet the requirements again.

The local authority may decide to withdraw recognition if:

  • you stop bottling (cease trading)
  • you stop monitoring the water
  • there’s any other incident that could affect assurance that the water still complies with the rules

If you’re not producing bottled natural mineral water but are continuing to monitor physio-chemicals levels to maintain recognition

The local authority may decide to keep your recognition active but should tell Defra.

This is so that Defra can update the list of recognised sources and allow for your listing to be displayed as ‘No production at present’ in the trade description column.

Your monitoring must show that your water continues to meet the conditions set out for recognition, before you start to bottle your natural mineral water again.

You also need to inform the local authority who granted recognition if:

  • you’re aware of any significant changes to the composition of the water
  • you make any change to the trade description of the water

If your water has changed, the local authority must decide on timescales for whether your spring:

  • could be exploited immediately
  • is derecognised, with the aim of granting recognition again after a further period of assessment

How to appeal a withdrawal of your recognition

You can apply to Defra by emailing bottled.water@defra.gov.uk for a review of a decision to refuse or withdraw recognition.

When it receives your appeal, Defra will review your case and will either:

  • confirm the local authority’s decision was correct
  • tell the local authority to grant or restore recognition

How to ask for your recognition to be withdrawn

You can ask for your recognition to be withdrawn by contacting the local authority who granted recognition.

They’ll confirm in writing that your source is no longer recognised.

If you want to use a source for spring water or bottled drinking water instead

If your water has been previously recognised as a natural mineral water, this does not mean you can go on immediately to trade it as spring or bottled drinking water instead.

There are different rules you’d need to follow before you can start to produce:

Published 28 May 2020
Last updated 13 November 2020 + show all updates

  1. New guidance on testing water for parasites and bacteria.

  2. First published.

Contents

Related content