Belgrade, 25 th June 2012 Raymond Ellard Director – Consumer Protection Food Safety Authority of Ireland Bottled Water Implementation of Food Controls

Bottled Water Implementation Raymond Ellard Belgrade 25 th June 2012

Annual Consumption- Ireland 183 million litres of bottled water 26 bottled water companies

Most Expensive? Acqua di Cristallo Tributo a Modigliani – $60,000 for a 1.25 ml bottle

Fame & Fortune

Bottled Water Regulation Department? Labels Recognition Trade Description Micro Criteria Treatment Hygiene/Safety Testing

The Rules Key Components Activated Alumina 115/2010 Revised Drinking Water Directive Ozone 2003/40/EC 2009/54/EC Bottled Water 852/2004/EC

NSAI HSE/FSAI Controls in Ireland: Responsible Authority Recognition Competent Authority Inspections Working together

NSAI HSE/FSAI

Natural Mineral Water Spring Water Any Other Water

Natural Mineral Water Authorisation –Within EU –Outside EU List Published in Europa Website

Spring Water intended for consumption in its natural state, underground source, protected from pollution bottled at source. limited treatments

Any Other Water Complies with the same rules are tap water –98/83/EC Table Water

USA Bottled Water Identity Labelling 21 C.F.R § (a)

Natural Mineral Water

Man made or God Made?

Natural Mineral Water Microbiologically wholesome Underground source Protected from pollution Distinguished by –Nature – mineral content, trace elements –Original State Stable Bottled at source Limited treatment Recognised

Consumers in Ireland

Approval & recognition Assessment –Geological –Hydrogeological –Physical, Chemical and physicochemical properties –Microbiological –Pharmacological –Physiological –Clinical Stability –Rate of flow –Temperature –Terrain properties Protection from Pollution Equipment Treatments Periodic Checks Irish Standard IS432: 2010

Page 22 Permitted Treatments 1)the separation of its unstable elements, such as iron and sulphur compounds, by filtration or decanting, possibly preceded by oxygenation, 2)the separation of iron, manganese and sulphur compounds and arsenic from certain natural mineral waters by treatment with ozone-enriched air - NOTIFIED 3)the separation of undesirable constituents other than those specified NOTIFIED 4)the total or partial elimination of free carbon dioxide by exclusively physical methods 5)Activated alumina to remove fluoride NOTIFIED Microbiological treatments are prohibited

Disinfection Not Permitted –UK says UV OK???

Sales Description NATURAL MINERAL WATER Naturally carbonated mineral water Natural mineral water fortified with gas from the spring, or Carbonated natural mineral water –Fully decarbonated –Partially decarbonated

Micro Criteria TCC –Evidence of pollution Free from –Parasites and pathogens –E Coli 0/250ml –Sulphite reducing in 50ml –Pseudomonas in 250ml Organoleptic defects AFTER BOTTLING TCC 0 in 72hrs 37 0 in 24hrs Measure with 12hrs AT SOURCE TCC 0 in 72hrs 37 0 in 24hrs

Micro Criteria E.Coli Enterococci Coliforms Pseudomonas TVC Recall Investigate Investigate &HPSC notice Establish norm

Labels Place in the Trade Description Nor more than One Trade Description per source! Trade Description - name of spring or place 1.5 times Prohibited –Characters the water does not possess

Label Analytical Composition Place where spring is exploited Permitted Treatment Trade Description –Place name if not misleading –Only 1 Trade Description

Fluoride >1,5 mg/l ‘contains more than 1,5 mg/l of fluoride: not suitable for regular consumption by infants and children under 7 years of age’. CODEX USA has a maximum level in drinking water is 4mg/l. Codex now same as EU, but now maximum system

Authorised CLAIMS- Annex III Low Mineral content Very Low Mineral Content Rich in Minerals Contains calcium.. Suitable for a low sodium Diet

Prohibitions on Labels Medicinal Claims Will Cure Heart disease, Cancer, weak bones, and it also Whitens your teeth. HONEST!!! Currently Not Allowed in Europe

Other Prohibited Claims May be laxative May be diuretic No criteria in Ireland

Directive 2000/13/EC TOP 10 Compulsory labelling 1.Name under which product is sold* 2.List of ingredients 3.Quantity of certain ingredients (QUID) 4.Net quantity* 5.Date of minimum durability* 6.Actual alcoholic strength of beverages >1.2% alcohol by volume* *Must appear in the same field of vision

Compulsory Labelling 7.Special storage instructions/conditions of use 8.Name or Business name and address of manufacturer or packager, or of seller in the EU 9.Origin – if absence misleads the consumer 10.Instructions for use where necessary

Authorised Claims? ‘stimulates digestion', ‘may facilitate the hepato-biliary functions' or similar indications.

INFANTS Member States may adopt special provisions regarding information — both on packaging or labels and in advertising — concerning the suitability of a natural mineral water for the feeding of infants. Such provisions may also concern the properties of the water which determine the use of the said information.

Babies and NMW Mineral waters may have a high solute content, may contain inadequate fluoride, and should not be used either to reconstitute formula or as an infant drink.

Main Issue Recognition of NMW is complex Specialist Work Guidance required for Inspectors Market Surveillance - Labelling

You need a good guide

Irish Standard IS432 –Revision 2010 –Includes general hygiene requirements –Recognised Guide to Good Practice

Thank You