‘Packaged Waters’ Offered By Restaurants, Retailers Muddy Legislation, Environmental Concerns

The packaged water bottled on site by restaurants and other hospitality outlets, often as an alternative to bottled waters or tap water, is muddying the water when it comes to legislation and standards, and environmental concerns.

These waters are bottled and packaged on site using bench-top treatment systems utilising filtration, reverse osmosis, carbonation, refrigeration or chilling – as well as combinations of these – to bottle water on demand in re-usable glass bottles, typically closed with a Grolsch-type lid.


The water source can be municipal water (tap water), or spring or borehole water should the business have access to this water.


Concerns have been raised about this practice, specifically whether or not it conforms to South African packaged water legislation and food safety standards, and whether it offers true environmental benefits as manufacturers of these systems claim.


Asked for comment, chairman of the South African National Bottled Water Association (SANBWA), John Weaver, said the association had been in discussion with the Department of Health with respect to how these waters should be regarded under South African legislation.


“SANBWA interprets these waters as being ‘packaged water’ due to the fact that it is marketed and presented as “bottled water”.  Therefore the businesses offering water treated and packed in this way will need to conform to the same packaged water, labelling and food safety legislation as other packaged waters bottled in this country do, including:

·         Microbiological legislation: Regulations Governing Microbiological Standards for Foodstuffs and related matters, R.692

  • Treatment and chemical regulations as per R.718
  • Labelling legislation as detailed in R.718 and Regulations Relating to Labelling and Advertising of Foodstuffs, R.146


“This means they must add best before dates and correct product information on their product bottles and labels. If they don’t, according to South African law, they must cease to offer this product or offer it in jugs.”


Weaver said the Department of Health is in the process of ensuring the necessary packaged water legislation is correctly interpreted so that the consumer is not misled when it comes to these new products.


The department will also review and suggest guidelines in terms of seals, circumstance of sales, use and marketing of these products.


Until this happens, it is vitally important that the hospitality industry and those charged with ensuring its compliance with legislation are familiar with the Department of Health’s interpretation of R.718: Regulations Relating to Packaged Waters (as amended 26 May 2010) because of the confusion these new products are currently creating for the consumer of bottled waters.


He also suggested potential users of these systems carefully investigate any ‘green’ claims.


“Laudably, restuarants and other businesses in the hospitality industry are, like many others, trying to be more responsible corporate citizens when it comes to environmental matters,” he said.


“They’re changing to energy saving light bulbs, they’re encouraging guests not to expect towels to be changed on a daily basis, and they’re electing to replace the bottled water they serve with that packaged on site using one of these systems.


“Unfortunately, given the amount of water these systems could use to properly clean and sterilise the re-usable bottles, it is unlikely that they’ll achieve a reduction in their water footprint, and they’d therefore do well to consider this before banning bottled waters.”


Bottled water production in South Africa is a very water efficient business in that it has an extremely low ‘water usage’ factor, a factor that Weaver believes the bench-top systems will struggle to attain.  


“The term ‘water usage’ refers to how much water is used (volume) to make a finished product.  This measure – sometimes called ‘water footprint’- includes both direct and indirect water usage (in the bottled water industry, that would be water for rinsing and sanitising bottles, plant and general cleaning and sanitation, vehicle washing, floor washing, toilets etc.) and includes water from boreholes and municipal source,” he said.


“The total South African bottled water industry benchmark is 1.8:1, and there are plants that achieve ratios of as low as 1.3:1 – 1.4:1 by recycling their bottle rinse water. This 1.8:1 usage of water by the bottled water industry equates to 22.7 litres/second. 


“To put this into perspective, just one golf course uses 1 litre/second per hole or 18 litres/second for an 18 hole golf course. This means that the total amount of water used by the bottled water industry just slightly more than the equivalent used by one golf course. Similarly, the fruit export industry uses 0.5 litres/second/hectare, making the bottled water industry’s use equivalent to that of just one 45 hectare farm.”


Weaver concluded by asking potential users to not fall victims to urban myth when making their purchasing decision.


“One of the arguments against bottled waters is that carcinogenic substances leach into the water from the plastic. This is incorrect, and stems from a concern about phthalates and BPA, which do not exist in PET (polyethylene terephthalate).


“PET is used for numerous types of packaging for many foods, including everything from ketchup, peanut butter, soft drinks, and juices to beer, wine and spirits, yet no-one discourages people from consuming of any of these products.


“PET is approved as safe for food and beverage contact by the FDA and similar regulatory agencies throughout the world, and has been for over 30 years. PET itself is biologically inert if ingested, is safe during handling, and is not a hazard if inhaled, according to the International Life Sciences Institute Report (ILSI) ‘Packaging Materials 1. Polyethylene Terephthalate PET for Food Packaging Applications’ (2000).”


Box 1:


SANBWA adheres to the following interpretations:

·         Bulk water: tanker – distributed to rural areas = public water supply and not within the scope of packaged water legislation

  • Bulk Water: office coolers = packaged water (and, as per Europe, hermetically sealed, just a bigger bottle) when seal broken and on cooler = drinking water
  • Re-filling into consumer’s containers = drinking water not within the scope of packaged water legislation
  • Benchtop treated waters and shop-floor treated waters bottled on site = packaged water that should be hermetically sealed with a tamper evident component


Box 2:


The following definitions are adhered to by the Department of Health:

·         Packaged Water – R.718: ‘Packaged water’ means water that is packed in hermetically sealed containers of various forms, capacities and approved safe and suitable materials and which is indented as a foodstuff for human consumption.

  • Milk and Milk Products – R.1555: ‘Hermetically sealed container’ means an unopened container which cannot be opened without breaking or damaging such container or seal, adhesive label or other part of or attachment to such container and which is intended to protect its contents against the entry of micro-organisms.

 You can also get in touch with Prime Packaging for customized packing solutions.

 Web site:www.sanbwa.co.za


For further information contact: 

Petra Peacock

+27 11 7944665; +27 83 3031778


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