1. Is it possible to declare the exact composition of natural mineral water or spring water on the label?
Directive 2009/54/EC of the European Parliament and of the Council on natural mineral waters and spring waters stipulates that the labels on natural mineral waters must detail the analytical composition of the water's characteristic constituents. This obligation of detailed analytical composition does not apply to spring waters.
Since the mineral content of many spring waters remains constant, labelling may indicate the exact composition of the constituents characteristic to the water, provided that the information does not mislead the consumer. Possible variations in concentrations must be taken into account in the information provided to consumers and the concentrations must be based on sufficiently recent laboratory analyses. If composition data is provided, the Finnish Food Authority recommends that the data given covers the constituents characteristic to spring water (e.g. minerals, fluoride).
The nutrition labelling requirements set out in Regulation No 1169/2011 of the European Parliament and of the Council do not apply to foodstuffs controlled under Directive 2009/54/EC. These include also natural mineral waters and spring waters.
2. Can spring water or natural mineral water be sold under a so-called private label, for example as a chain store's own spring water?
Pursuant to Directive 2009/54/EC, natural mineral water or spring water may only be marketed under one trade name. In this context, the restriction against multiple trade names is interpreted to apply, in particular, to situations where an operator/packager wishes to sell same water under several trade names. However, cases where the same spring water is sold simultaneously under a chain store's trade name and the packager's own trade name are not considered to be in breach of the stipulation on multiple trade names provided for in the Directive. The labelling of such 'private label' waters must indicate the place where the spring is exploited and the name of the spring, and it must not be misleading to consumers.
3. Is it possible to market water from a recognised natural mineral water source both as natural mineral water and spring water?
According to EU legislation, natural mineral water and spring water are two different foodstuffs. Thus, marketing water simultaneously as natural mineral water and spring water would be misleading to consumers.
4. Can spring water be marketed as natural mineral water?
Only waters recognised as natural mineral waters may be marketed as such. In Finland, natural mineral waters are recognised by the Finnish Food Authority. The marketing of water from the same source as both products would mislead the consumer.
5. Does the recognition of water as natural mineral water depend on its mineral concentration?
The conditions for the recognition of water as natural mineral water are laid down in Directive 2009/54/EC. The Directive does not provide requirements for minimum mineral content. The recognition is, however, conditional on the stability of this content.
6. How may spring waters or natural mineral waters be treated before packaging?
The “naturalness” of spring waters and natural mineral waters differentiates them from ordinary drinking water. For this naturalness to be retained also in packaged spring waters and natural mineral waters, the waters may only be treated prior to packaging in the ways laid down in EU directives 2009/54/EC (Article 4) and 2003/40/EU (Article 5) as well as in Commission Regulation EU 115/2010.
The water may not be disinfected, nor may any bacteriostatic elements be added to it or may it be the subject of any other treatment liable to change the viable colony count of the water. Only carbon dioxide in accordance with Annex I of Directive 2009/54/EC may be added to spring waters or to natural mineral waters.
7.What has been laid down about filter size for spring waters or natural mineral waters?
Under EU directive 2009/54/EC, spring waters and natural mineral waters may not be the subject of any treatment that would change the viable colony count of the water. If the spring water is filtrated prior to packaging, the filter must not be so fine so as to filter out the microbes occurring naturally in the water. Spring waters or natural mineral waters must not be treated to disguise poor hygienic quality.
8.What other constituents may be added to water sold as spring water or natural mineral water?
Under EU directive 2009/54/EC, no other elements than carbon dioxide may be added to spring waters or to natural mineral waters.
These answers are the Finnish Food Authority's own interpretations based on existing legislation.