Bottled Water: Federal Labeling Requirements

Americans drink more than 20 million gal of bottled water per day, according to the Beverage Marketing Corp. With the growth of the bottled water industry, consumers are now faced with a wide variety of choices in the bottled water marketplace. Dealers may be able to distinguish their product from all the others out there on the shelf by how they classify it on the label.

An accrediting agency can help you understand the labeling rules and assist in the selection of the best option for your bottled water product. The Code of Federal Regulations states that “Bottled water is water that is intended for human consumption and that is sealed in bottles or other containers with no added ingredients.”

Exceptions are made for the addition of antimicrobial agents and fluoride. The rule goes on to further refine how the product can be labeled, which is largely related to the source of the bottled water.

Well & Spring Water

Well water, for example, is simply defined as bottled water that is tapped from an underground aquifer. In contrast, spring water must come from an underground aquifer from which water flows naturally to the surface and the location of the spring must be identified. Bottled water production facilities are allowed to use external force (i.e., pumping) to bring the water to the surface for bottling. However, the bottling facility must be able to demonstrate by means of hydraulic comparison between the bore hole and the natural spring that the pumped water comes from the same underground stratum as the water that flows naturally from the spring. The spring must continue to flow naturally to the surface in spite of any external force or pump in use. And finally, the pumped water must have the same physical properties, composition and quality as the natural spring water.

Artesian Water

Artesian water or artesian well water is water from a well tapping a confined aquifer in which the water level in the well rises above the water level in the aquifer. As with spring water, pumps can be used to bring artesian water to the surface for bottling. Upon request, plants must demonstrate to the appropriate regulatory official a natural rise in the water level above the top of the aquifer.

Mineral Water

Mineral water must naturally contain at least 250 parts per million (ppm) of total dissolved solids. The concentration of minerals and trace elements in mineral water might vary due to natural cycles of fluctuation, but it should remain relatively constant over time. The total dissolved solids content of mineral water cannot be enhanced by mineral additives. Mineral water classification must be further refined on the label as “low mineral content,” which is less than 500 ppm total dissolved solids, or “high mineral content,” which is greater than 1,500 ppm total dissolved solids. Mineral water between 500 ppm total dissolved solids and 1,500 ppm total dissolved solids does not require further classification on the label.

Sparkling Water

Some groundwater is naturally carbonated due to the high pressures that exist in the aquifer. Sparkling bottled water is carbonated bottled water that contains the same amount of carbonation as it did when it emerged from the source. Typically the carbonation is lost when the water emerges from the source and must be re-added so that the concentration in the final product matches the original source water. This is different than water with added carbonation, such as tonic water, seltzer and club soda, which are considered soft drinks and regulated separately.

Purified Water

Purified water must be tested to meet special requirements contained in the United States Pharmacopeia (USP). The USP test protocols were developed for pharmaceutical and medical applications where it is sometimes necessary to have high-purity water. Purified water can be further classified by how it is produced, such as “deionized water,” “distilled water,” “reverse osmosis water” or “RO water.” The term “drinking water” can also be added to purified water. For example, water processed through a distiller could be labeled as “purified drinking water” or alternatively as “distilled drinking water.”

Sterilized Water

Sterile or sterilized water also must meet special USP testing requirements. If it is stated or implied that bottled water is intended to be used for feeding infants, it must either meet the federal requirements for commercially sterile products, or prominently display the statement “Not sterile. Use as directed by physician or by labeling directions for use of infant formula” on the label.

Bottled water from a community water source must state on the label that it is “from a community water system” or “from a municipal source,” unless it has been further treated by deionization, distillation, RO or sterilization. An accrediting agency can help with the labeling options available to market your bottled water product.

Eric Yeggy is a product certification supervisor for the Water Quality Assn.’s Gold Seal Certification Program. Yeggy can be reached at or 630.505.0160.

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