Spring water: how to produce and label
How to register as a spring water producer, and the rules you must follow to produce and market spring water.
Applies to England
This guide is for people or businesses who want to:
- use a spring in England to bottle spring water
- sell this spring water in the UK and the EU
To use a spring in:
- Wales or Northern Ireland, read Food Standards Agency guidance
- Scotland, contact Food Standards Scotland
What counts as spring water
You can only describe a product as spring water if:
- it comes from an underground water source that’s tapped at a natural or drilled exit
- it’s free of parasites and bacteria that cause disease
- the source is protected from pollution
Bottling must take place at the spring or borehole.
You can sell spring water directly to consumers in, for example:
- bottles
- tetra packs and cartons
- water coolers
- pouches
You do not have to state the composition on the label (although many producers choose to do so).
There are no forbidden treatments, but you must follow rules for certain treatments if you use them.
Check the different types of bottled water if you’re not sure which type you have.
You can also check if your water is exempt from the rules.
Steps to get registered to produce spring water
- Contact the Environment Agency to apply for a water abstraction licence. You’ll need this before you can take water from the spring.
- Apply to the local authority in the area the water is extracted to register as a food business for spring water.
- Carry out initial tests out on your spring water to make sure it complies with chemical, microbiological and radioactive limits. Send the results to the environmental health officer at the local authority who’s registering your business.
- Understand the rules you’ll need to follow when exploiting the spring. You need to know this to make sure your spring water is viable to produce.
- Understand what treatments you can use. You need to know this to make sure your spring water is viable to produce.
- Check the labelling rules you’ll need to follow.
The local authority will register your business and premises when they’ve checked:
- your testing records
- that you’ve understood the rules you must comply with
- your premises meets hygiene conditions
They’ll let you know in writing when you can start producing and marketing your spring water.
Tests you need to carry out on your spring water
You must test your spring water and make sure it complies with:
You should check that the laboratory testing your water has received third party accreditation for carrying out the method of testing that you have requested.
Initial and ongoing tests
Carry out initial testing and keep records of the results - you’ll need to show these to the local authority. Take samples at source and take as many as you need to be sure your water complies with the rules.
After initial testing, you must carry out ongoing testing regularly - discuss how often with the local authority you’re dealing with. This can vary, depending on, for example:
- how much spring water you produce
- the conditions around the spring
For both initial and ongoing testing, you do not need to send samples of the water to the local authority. They will carry out their own tests at your bottling plant.
Chemicals limits
Test your water to make sure it complies with the following limits.
| Chemical | Maximum limit | Details |
|---|---|---|
| Antimony | 5 micrograms per litre | |
| Arsenic | 10 micrograms per litre | |
| Benzene | 1 microgram per litre | |
| Benzo(a)pyrene | 0.01 micrograms per litre | |
| Boron | 1 milligram per litre | |
| Bromate (Br03L) | 10 micrograms per litre | |
| Cadmium | 5 micrograms per litre | |
| Chromium | 50 micrograms per litre | |
| Copper | 2 milligrams per litre | |
| Cyanide (CN) | 50 micrograms per litre | |
| 1,2-dichloroethane | 3 micrograms per litre | |
| Fluoride | 1.5 milligrams per litre | |
| Lead | 10 micrograms per litre | |
| Mercury | 1 microgram per litre | |
| Nickel | 20 micrograms per litre | |
| Nitrate (NO3) | 50 milligrams per litre | You also need to divide concentration of nitrate in milligrams per litre by 50. Add this to the concentration of nitrite in milligrams per litre. Divide it by 3 - it must not be more than 1. |
| Nitrite (NO2) | 0.5 milligrams per litre | You also need to divide concentration of nitrate in milligrams per litre by 50. Add this to the concentration of nitrite in milligrams per litre. Divide it by 3 - it must not be more than 1. |
| Polycyclic aromatic hydrocarbons | 0.1 micrograms per litre | This means the total of all individual polycyclic aromatic hydrocarbons found and measured during your testing should not be more than 0.10 micrograms per litre |
| Selenium | 10 micrograms per litre | |
| Tetrachloroethene and trichloroethene | 10 micrograms per litre | This means the total of tetrachloroethene and trichloroethene combined should not be more than 10 micrograms per litre |
| Trichloromethanes | 100 micrograms per litre | This means the total of all individual trichloromethanes should not be more than 100 micrograms per litre |
Chemical limits: special conditions for acrylamide, epichlorohydrin and vinyl chloride
Your water must not contain more than the maximum limits for these 3 chemicals.
| Chemical | Maximum limit |
|---|---|
| Acrylamide | 0.1 micrograms per litre |
| Epichlorohydrin | 0.1 micrograms per litre |
| Vinyl chloride | 0.5 micrograms per litre |
If there’s any risk of the water exceeding these limits, you must sample and test the water. However, you do not need to test the the water if you and the local authority are satisfied that:
- your spring water has not come into contact with equipment made using acrylamide, epichlorohydrin and vinyl chloride
- you’ve not used any flocculants containing these 3 chemicals
You can demonstrate to the local authority that your water does not contain residues of these chemicals over the limits by providing either a manufacturer’s:
- relevant certificate of conformity
- declaration of conformity
- declaration of performance
Chemical limits: pesticides
Test your water to make sure it complies with the following limits.
| Pesticide | Maximum limit | Details |
|---|---|---|
| Aldrin | 0.03 micrograms per litre | |
| Dieldrin | 0.03 micrograms per litre | |
| Heptachlor | 0.03 micrograms per litre | |
| Heptachlor epoxide | 0.03 micrograms per litre | |
| Other individual pesticides | 0.1 micrograms per litre | You only need to test for pesticides that are likely to be present in the water. The maximum of 0.1 micrograms per litre applies to each individual pesticide you test for. |
| Total pesticides | 0.5 micrograms per litre | Total of all pesticides you find should not equal more than 0.5 micrograms per litre |
Microbiological limits
Your water must be free of parasites and bacteria that cause disease. Test your water to make sure it complies with the following limits.
| Bacteria | Maximum limit |
|---|---|
| Escherichia coli | 0 per 250 ml |
| Pseudomonas aeruginosa | 0 per 250 ml |
| Faecal streptococci | 0 per 250 ml |
| Sporulated sulphite-reducing anaerobes | 0 per 50 ml |
| Total viable colony count (TVC) after 72 hours at 22ºC | 100 per ml |
| TVC after 24 hours at 37ºC | 20 per ml |
For your initial testing, take samples both:
- at source
- within the first 12 hours after bottling - keep the water at between -1°C and 4°C before you send to the laboratory
Radioactive limits
Test your water to make sure it complies with the following limits.
| Test for | Concentration or value |
|---|---|
| Radon | 100 becquerels per litre |
| Tritium | 100 becquerels per litre |
| Indicative dose | 0.1 millisievert (a year) |
Rules for exploiting the spring
You should be aware of rules to follow once your business and premises are registered and you start to exploit the spring.
Rules for protecting the water at source
You must make sure that:
- any equipment you use to collect the water, such as pumps, prevents contamination and does not change the properties of the water
- the source or borehole is protected against pollution
- pipes and reservoirs are made from materials suitable for water, and are built to prevent any chemical, physio-chemical or microbiological change to the water
Bottling or using containers
Your bottling plant must be based at the spring.
You must also:
- meet hygiene requirements when you bottle and produce the water
- bottle the water in containers with caps or lids, to avoid contamination
- use food-grade standard containers to avoid adverse changes to the microbiological and chemical properties of the water
If you find that your spring water has become polluted at any stage, you must stop bottling from the spring until you’ve removed the cause of pollution.
How you’re allowed to transport the water
You must transport your spring water from your plant in bottles or containers that the final customer will use.
The only exception to this is if you were transporting water from the spring to a bottling plant further away on or before 13 December 1996, in containers not intended for the final customer. If this applies to you, you can continue transporting using the same containers.
Check what treatments you can use
You may want to use treatments to make your spring water taste better or to make it comply with the rules.
You may use any treatment for spring water. You must follow certain rules if you use:
Ozone-enriched air oxidation treatment
You can use ozone-enriched air oxidation to separate compounds of iron, manganese, sulphur and arsenic from the water if they occur naturally at source.
You can only use this treatment if all the following apply:
- before you start, you’ve met the conditions for exploiting the spring
- the treatment does not accidentally disinfectant the water, as a side effect
- the treatment does not alter the mineral, chemical and microbial composition of the water (apart from iron, sulphur and manganese)
- it does not leave residues in the water that could be a risk to public health
Any residues caused by this treatment should not exceed the following maximum limits.
| Treatment residue | Maximum limit (milligrams per litre) |
|---|---|
| Dissolved ozone | 50 |
| Bromate | 3 |
| Bromoform | 1 |
You must get authorisation from the local authority to use this treatment. You should:
- allow them to examine your proposed method of treatment, place of treatment and take samples for analysis
- provide any extra information the local authority asks for
Authorised activated alumina treatment
You can only treat your water with activated alumina if:
- you’re aiming to remove fluoride
- you follow the technical rules
Any residues released into the water as a result of removing fluoride must be as low as possible and should not be a risk to public health.
You must make sure:
- the treatment does not accidentally disinfectant the water, as a side effect
- you get permission from the local authority at least 3 months before you start this treatment
Labelling rules
You must follow rules in this section when labelling your spring water.
You need to put the following on your labels:
- type of product (also known as the sales description)
- name of spring and place where the water is exploited
- details of any ozone-enriched air treatments you’ve used
You can also put a trade description (sometimes known as the brand name) if you want to but it’s not legally required.
Type of product (sales description)
You must put ‘spring water’ on your labelling. This describes the type of product and is known as the ‘sales description’. You must not sell it as any other type of water, such as natural mineral water.
Name of spring and place where spring is exploited
On the label, you must put the name of the:
- spring (if the spring does not have a name, you must give it one - discuss with the local authority when you register your food business)
- place where the spring is exploited - for example, you could use the town or village where it’s based, but you must not be misleading when you use a location on your labelling
If you’ve used an ozone-enriched air oxidation treatment
If you’ve used an authorised ozone-enriched air oxidation technique on your spring water, you must put the words ‘water subjected to an authorised ozone-enriched air oxidation technique’ on your labelling.
If you’ve used any other treatments, you do not need to put any wording on the label about them.
Trade description (optional brand name)
The ‘trade description’ is also known as the brand name. For example, Highland Spring, Pure Life or Harrogate.
You do not have to use a trade description for your spring water. If you choose to have one you must follow the trade description rules set out in this section.
Trade description: using the town or place name
You can use the town or place of exploitation as the trade description as long as your spring is located there.
You must not use a misleading place name as your trade description. For example, you cannot name your water after a town in Somerset if your spring is in Wales.
If you use as your trade description the:
- name of the spring, then you must put the place where it’s exploited elsewhere on the label
- place it’s exploited, then you must put the name of the spring elsewhere on the label
Trade description: using a trade description (brand name) that’s different from the name of the spring and place of exploitation
If you do this, you must make the font for the name of the spring and place of exploitation at least one and a half times the height and width of the largest of the letters used for your trade description.
Trade description: you cannot have more than one
Usually, you must sell all spring water from the same spring or borehole using only one trade description. You cannot sell it under a second name.
For example, if you already sell ‘ABC Spring Water’ you’re not allowed to sell a new batch from the same spring using the name ‘DEF Spring Water’.
The only exception is if you want to sell your water to a retailer, such as a supermarket, hotel, stadium, museum, venue or cafe, who will apply their own branding.
The best practice way to do this is to sell your water with both:
- your trade description
- the retailer’s own logo
For example, add a retailer’s logo to your label provided it’s still clear that the water comes from your brand. If you do this, the retailer’s logo does not count as a second brand.
Alternatively, you can choose to not have your own trade description, remove your own logo and sell the water with the retailer’s logo only instead. You can do this as long as the retailer’s logo is clearly separate from the sales description ‘spring water’.
If you have questions about this, speak with your contact in the local authority where the water is extracted.
If you use spring water as an ingredient in soft drinks
You can use the term ‘spring water’ on your labelling as an ingredient in soft drinks.
You’re allowed to do this as long as your spring water complies with the rules in this guide at the point you add the first extra ingredient to the spring water, such as flavouring.
When you’re allowed to start producing and marketing your spring water
The local authority will:
- check your testing records
- make sure you’ve complied with all the rules
When they are satisfied that your spring water meets the rules, they will register your business and confirm it in writing.
Once you’ve received this, you can start to produce and market your spring water.
Updates to this page
Published 28 May 2020Last updated 16 August 2022 + show all updates
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Clarified the permitted treatments for spring water.
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First published.