Bottled water means natural mineral water, spring water or domestic water intended to be supplied to consumers or mass caterers in bottles or containers. The characteristics, treatment and labelling of bottled waters is governed by the Decree of the Ministry of Agriculture and Forestry on packaged water 166/2010, which governs the entry into force of directives 2009/54/EC and 2003/40/EC.
The spaces used for the packaging and storage of bottled water are considered food premises subject to authorisation under the Food Act, which also governs food premises’ operations.
Bottled domestic waters and spring waters are further controlled by the Health Protection Act 763/1994 and the quality requirements and recommendations laid down in the Decree of the Ministry of Social Affairs and Health 1352/2015. Health protection legislation does not apply to natural mineral waters.
Recognition of natural mineral water
Natural mineral water may only be placed on the market if the competent authority of the Member State from whose ground the water has been extracted recognises it as natural mineral water. Application for the recognition of natural mineral waters originating in third countries may be made in the EU country where the water is first placed on the market. In Finland, natural mineral waters are recognised by the Finnish Food Authority.
The requirements for natural mineral water and its source are based on directives 2009/54/EC and 2003/40/EC as well as on Regulation 115/2010 (EU). Recognition is applied for by free-form application. The application must include all information on the water, the spring and on the site of the spring as stated in Directive 2009/54/EC and its annexes.
The operator must demonstrate that the natural mineral water and its spring satisfy the requirements of the aforementioned directives. Before making an application, the water must be examined in an accredited laboratory to ensure that the microbiological quality and composition of the water satisfy the requirements of the aforementioned directives.
An operator must also submit a notification of a food business establishment in accordance with section 13 of the Food Act (23/2006) on the bottling of the water to the local food control authority. The certificate obtained of submitting the application shall be appended to the application for recognition.
Where there is certainty that the water and spring satisfy the legislative requirements and the notification about the packaging of the water has been made to the local food control authority, the free-form application, including the appendixes required, may be sent to the registry of the Finnish Food Authority at P.O. Box 100, FI-00027, Finnish Food Authority, Finland or electronically to kirjaamo@ruokavirasto.fi. A handling charge is made based on the Food Authority’s pricelist.
The information required in Annexes I and II of Directive 2009/54/EC is appended to the application including:
- Surveys of the water (microbiological, physico-chemical and chemical surveys)
- Information on the mineral composition of the natural mineral water. The composition, temperature and other essential characteristics of the mineral water shall remain stable within the limits of natural fluctuation.
- Information on the site of the spring and on geological and hydrological surveys.
- Information on the treatments to the natural mineral water in accordance with the aforementioned directives.
- Information on the planned labelling (e.g. an image of the package label). You can find more information on labelling requirements in the Guide for control of packaged waters, for example.
The Finnish Food Authority informs the EU Commission of the information of the recognized source and the operator applying for recognition. The European Commission maintains a list of recognized natural mineral waters, which can be found here: (https://ec.europa.eu/food/sites/food/files/safety/docs/labelling-nutrition_mineral-waters_list_eu-recognised.pdf)
Guide for control of packaged waters
The Finnish Food Authority has prepared a guide (Finnish Food Authority Guideline No 5813/04.02.00.01/2021) for the control of bottled waters. This guide applies to bottled domestic water, spring water and natural mineral water. Water bottling is considered a food premises operation and is controlled by the provisions of different laws. The guide reviews the requirements and recommendations of the various regulations regarding the quality of water before and after bottling, and provides guidelines for the operations and the control of operators in compliance with the Food Act.