KNOW YOUR WATER

Q & A


... not just any water in a bottle can be called "bottled water".

What regulations cover the production of packaged water in New Zealand?

Is tap water so bad in New Zealand that we need bottled water?

What is the difference between the different types of water?

How can the consumer tell the difference? Should they expect to pay more for one than the other?

What’s to stop anyone turning on the kitchen tap and filling bottles and then selling the water?

Who is checking to determine if what is being consumed is actually what it says on the label? Does anyone actually go and inspect the "spring" or measure the mineral?

Is fluoride added or deleted from the water being put in the bottles? What about other additives?

Should the consumer detect a different taste in bottled water from tap water?

What is mineral water, what is spring water and how do they differ from tap water?




What regulations cover the production of packaged water in New Zealand?

It should be noted bottled water is one of the most complicated food products to manufacture as you cannot have any microbiological contamination present in a bottle of water.

The New Zealand Drinking Water Standards are most often used as a minimum baseline level to ensure quality but, in most cases, NZ water bottlers design plants and manufacturing etc. around industry best practice using protocols such as Australasian Bottled Water Institute (ABWI) Standards.

These standards are based on the widely accepted and highly stringent International Bottled Water Standards developed in the 1980’s by the International Bottled Water Association.

The ABWI Model Code is the Australasian successor to the International Bottled Water Association’s Model Code. The Model Code Sub-Committee started with the IBWA Code and made amendments based on assessment of local needs and FSANZ regulations.

These standards are not aspirational, they are a requirement to operate in the bottled water space and they are, in general, far higher than local Municipal supply standards.

The standards vary subtly by market depending on the local legislation that exists and requirements peculiar to that market which areoften a reflection on the health of the groundwater systems in each country.




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Is tap water so bad in New Zealand that we need bottled water?

No, not at all. In fact you will find no credible natural bottled water company that is a member of the NZBC saying don’t drink tap.

The availability of bottled water is driven by two factors: convenience and taste.

For those who don’t enjoy the taste of tap water bottled water offers an alternative and for those who do not have access to tap water such as those travelling, tramping, camping or involved in active sports, bottled water is the convenient option.

Having said that, drinking water is naturally aligned with a healthy lifestyle and is good for you. So if having access to bottled water gets you and your family drinking more water than that has to be good for you.

Interesting fact: Most (not all) water bottlers are using natural sources that are untreated by Municipal suppliers.

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What is the difference between the different types of water?

Bottled Water Types

Regulations contained in the Australia New Zealand Joint Food Standards Code (FSC) include specific definitions for ‘spring water’ and ‘mineral water’.

All other definitions, including: ‘well water’, ‘distilled water’, ‘purified water’ and ‘sparkling water’ are regulated by the Australian and New Zealand Competition and Consumer Commissions’ regulations requiring that labelling not be false or misleading.

The Australasian Bottled Water Institute (ABWI) has its own published guidelines for definitions of water types in its Model Bottled Water Regulations, which incorporate relevant legislation.

Relevant definitions applicable to Australia and New Zealand include:

Natural Water
“Bottled spring, mineral or well water which is derived from an underground formation or water from surface water that only requires minimal processing, is not derived from a municipal system or public water supply, and is unmodified except for limited treatment (e.g. filtration, ozonation or other proven disinfection processes).”

Spring Water
“Ground water obtained from a subterranean water-bearing strata that, in its natural state, contains soluble matter. No minerals may be added to such water.”

Mineral Water
“Ground water obtained from a subterranean water-bearing strata that, in its natural state, contains soluble matter. It is a requirement that mineral water have a level of total dissolved solids of greater than 250 ppm. No minerals may be added to such water.” Mineral water (by definition in New Zealand and Australia) is effectively spring water with a mineral content greater than 250mg/L.

Artesian Water
Neither FSANZ nor ABWI offer specific definitions for ‘Artesian water’. However, an accepted meaning of Artesian water is water ‘confined under pressure’ such that if the confined aquifer is ‘tapped’ (i.e. a bore is drilled into it) the water will flow to the surface under pressure. Artesian water may be spring water or mineral water.

A note about bottled water from Municipal sources:
It is important to note that purified bottled water is not "just tap water in a bottle." Once the municipal source water enters the bottled water plant, several processes are employed to ensure that it meets the purified or sterile standard of the U.S. Pharmacopeia 23rd Revision. Those treatments can include ozonation, reverse osmosis, distillation, or de-ionization. The finished water product is then placed in a bottle under sanitary conditions and sold to the consumer.

Some critics of bottled water imply that people may be unaware that they are consuming bottled water that is from a municipal water source and has been placed in a bottle without being purified. As stated above, this is not the case.

Note: If a bottled water product's source is a public water system and the finished bottled water product does not meet the FDA Standard of Identity for purified or sterile water, the product label must disclose the public water system source.

Exporting Bottled Water
Companies considering the export of bottled water from New Zealand should check that they comply with the bottled water definitions of the country they are exporting to. As an example, the United States of America FDA specify Spring Water as:

FDA describes bottled water as water that’s intended for human consumption and sealed in bottles or other containers with no added ingredients, except that it may contain a safe and suitable antimicrobial agent. (Fluoride may also be added within the limits set by FDA.)

The agency classifies some bottled water by its origin. Here are four of those classifications:

· Artesian well water. This water is collected from a well that taps an aquifer—layers of porous rock, sand, and earth that contain water—which is under pressure from surrounding upper layers of rock or clay. When tapped, the pressure in the aquifer, commonly called artesian pressure, pushes the water above the level of the aquifer, sometimes to the surface. Other means may be used to help bring the water to the surface.

· Mineral water. This water comes from an underground source and contains at least 250 parts per million total dissolved solids. Minerals and trace elements must come from the source of the underground water. They cannot be added later.

· Spring water. Derived from an underground formation from which water flows naturally to the surface, this water must be collected only at the spring or through a borehole that taps the underground formation feeding the spring. If some external force is used to collect the water through a borehole, the water must have the same composition and quality as the water that naturally flows to the surface.

· Well water. This is water from a hole bored or drilled into the ground, which taps into an aquifer.

Bottled water may be used as an ingredient in beverages, such as diluted juices or flavored bottled waters. However, beverages labeled as containing “sparkling water,” “seltzer water,” “soda water,” “tonic water,” or “club soda” aren’t included as bottled water under FDA’s regulations. These beverages are instead considered to be soft drinks.

In all export cases the legal definition of the country being exported to will take precedent over the local FSANZ / ABWI definitions.

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How can the consumer tell the difference? Should they expect to pay more for one than the other?

Labelling will tell you if it’s a natural product or not (purified) so read the labels carefully.

Yes you can expect to pay more for a natural bottled product. Bottled water plants are expensive to build and operate and margins on bottled water are diminishing. Pricing reflects consumer demands and brand segmentation, distribution and all the other standard factors. Having said that prices for bottled water are coming down relative to other beverage products.

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What’s to stop anyone turning on the kitchen tap and filling bottles and then selling the water?

Regulation around Drinking Water standards. It’s a highly regulated industry and those flouting the law will soon be caught out.

In addition, the cost of entry and distribution barriers for those looking to produce bottled water is a huge disincentive for those looking to start up their own bottling plant. It’s also a very competitive market with low margins so you have to be well capitalised, be prepared for a long haul and completely familiar with all the regulations in order to stand a chance of succeeding.

Yes there are cowboys in the industry and the NZBC encourages anyone with concerns to contact us via this website.

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Who is checking to determine if what is being consumed is actually what it says on the label? Does anyone actually go and inspect the "spring" or measure the mineral?

Testing on Raw Water and water sources should be undertaken by third parties as per strict ABWI Model Code requirements.

It is essentially the role of the regulatory authorities with in the relevant Government ministries. However consumers in New Zealand can take confidence from knowing that the NZBC carries out regular independent testing on water products from both its members and non-members. If these are found not to comply with either ingredient or labelling regulations then the NZBC takes measures to rectify the situation.

Interesting fact: It costs around $4000 to do a full test of a typical water annually.

The standards require stringent testing of both source water (RAW) yearly and regular testing of finished product in respect of a number of criteria summarised in the Standards.

*The NZ industry has developed strict codes of compliance, which NZBC members must follow.

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Is fluoride added or deleted from the water being put in the bottles? What about other additives?

Fluoride can occur naturally in natural bottled water sources, including those used for town supply. This is at very low levels which are considered safe and meet strict international guidelines.

At this time the NZBC is not aware of anyone deliberately adding Fluoride and cannot see that ever being a worthwhile consideration. Consumers can get Fluoride by drinking ordinary tap water and the issue is too contentious for most water bottlers to get involved with.

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Should the consumer detect a different taste in bottled water from tap water?

Yes. You should be able to pick up the absence of chlorine taste and odours from water treatment. In the case of bottled water it will in most cases be chilled and so may feel “crisper” in the mouth. Some waters will have a stronger taste of the minerals that are in the ground from which it’s taken. These may include silica which is good for skin.

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What is mineral water, what is spring water and how do they differ from tap water?

The critical point is that Mineral Water strictly speaking must be of a sufficient mineral content measured in TDS (total dissolved solids), which varies by country standards. Internationally it must not be less than 250 parts of total dissolved solids and this information must be displayed on the label.

For Spring Water the TDS can be much lower as is the case for the other types of water. Typically mineral water costs more for this reason.

In most cases NZ bottled waters are predominantly sourced from Spring and Artesian Water sources with a typical TDS of between 75-150 TDS – total dissolved solids.

They differ from Tap Water in that they are taken from a protected underground source, either an aquifer or protected water supply, rising to the surface naturally (artesian) or by pump into a bottling water facility and are not treated until the bottling stage, typically with 2 stage filtration and then ozonation which has GRAS status from the FDA for “generally recognised as safe”, for over a decade .

Most natural vs. tap waters from aquifers have been naturally filtered by volcanic rock for as little as 10 years and in many cases significantly greater than several hundred years. This natural filtration process imparts minerals and taste. On average most bottled water sources are bottling water that has been underground for at least 50 years in NZ.

Tap Water often comes from natural sources too, but not always underground or protected sources, often it comes from dams and rainfall via rivers where it is exposed to contamination in the open air, and throughout the piping network to treatment regimes and then onto your home or workplace. Hence the requirement to highly treat it with a number of chemicals including chlorine to ensure that it can be subsequently sent great distances though Municipal pipe systems and arrive in safe potable condition for human consumption.

Yes, there are companies who bottle tap water, albeit they are in the minority, and how they treat Municipal Supply is touched on below. By volume, comparatively, they may be a significant player in the market but in reality they are only a handful of operators and traditionally operate in the Home Office Delivery segment. They typically sell water in 15L containers.

On a supermarket shelf there would be very few “purified waters”, albeit this is far more prevalent in Asian economies.

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