Labelling Requirements for Prepackaged Water and Ice
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Table of Contents
- Common Name - Water and Ice
- Legibility - Water and Ice
- List of Ingredients - Water and Ice
- Nutrition Labelling - Water and Ice
- Fortification - Water and Ice
- Product Specific Labelling Requirements
- Variations in Mandatory Labelling
- Voluntary Claims & Statements
- Additional Information
This section provides information on the labelling requirements for water and ice which has been prepackaged in sealed containers for use by consumers subject to the Food and Drugs Act (FDA), the Food and Drug Regulations(FDR), the Consumer Packaging and Labelling Act (CPLA) and Consumer Packaging and Labelling Regulations (CPLR). In addition, provincial regulations may also have requirements for prepackaged water and ice that apply to products sold in that province. Note that this information does not apply to drinking water that is not prepackaged, such as municipal water supplies. Health Canada's webpage on Drinking Water provides information on non-prepackaged drinking water.
The requirements detailed in the following sections are specific to prepackaged water and ice. They are in addition to the core labelling and claims and statements pages of the Industry Labelling Tool that apply to all prepackaged foods.
Prepackaged water can come from a variety of sources including springs, aquifers, or municipal supplies and may be treated to make it fit for people to drink. Water represented as mineral or spring water has a prescribed standard in Part B, Division 12 of the FDR, B.12.001. Part B, Division 12 of the FDR also includes specific microbiological standards, acceptable treatments and specific labelling requirements.
Prepackaged spring or mineral water may not be subjected to any treatment that would modify the original composition of the water. It may be treated by the addition of carbon dioxide for carbonation, ozone for disinfection during the bottling process and fluoride for the prevention of dental caries.
Common Name - Water and Ice
Mineral or Spring Water
Prepackaged potable water obtained from an underground source other than a public community water supply and that meets the prescribed standard for water represented as spring or mineral water may be labelled with the common name "Mineral Water" or "Spring Water" [B.12.001, FDR]. While mineral water generally contains a larger amount of dissolved minerals than spring water, these two terms can be used interchangeably.
Carbonated Mineral or Spring Water
Mineral or Spring Water containing added carbon dioxide is required to be labelled with the term "Carbonated" as part of the common name on the principal display panel (definition) when the added carbon dioxide [B.12.003, FDR]:
- did not originate from the decarbonation of the water upon its emergence from the underground source (definition); or
- is at a level greater than the naturally occurring level, prior to the water emergence from the underground source.
For information on spring or mineral water containing carbon dioxide that originated from and is present in the same amount as in the underground source, refer to Naturally Carbonated, Sparkling.
Acceptable common names for water not meeting the standard for Mineral Water or Spring Water are "Water", "Bottled Water", "Table Water" or other similar terms.
Prepackaged water is required to be labelled as [B.12.006 (a), FDR]:
- "Distilled Water" when it has been treated with vaporization and condensation;
- "Demineralized Water" when it has had its mineral content reduced to less than 10 parts per million by means other than distillation; and
- "Carbonated Water" when it contains added carbon dioxide.
Water, Mineral Water or Spring Water with Added Ingredients
Water, Mineral Water or Spring Water to which other ingredients such as flavours have been added are considered unstandardized foods and must be labelled with an appropriate common name to describe how the food is different from the prepackaged waters described in the FDR. Examples: "Berry Flavoured Spring Water", "Carbonated Water with Cherry Flavour", and "Water with added Lemon Juice". Water with added mineral salts may be labelled as "Water Flavoured with Mineral Salts" or "Mineralized Water".
Refer to Common Name for more information.
Water, mineral water and spring water from different sources are permitted to be blended. "Mineral Water / Eau minérale" and "Spring Water / Eau de source" may be used as part of the common name provided that:
- The common name indicates the product is a blend; and
- The mineral water or spring water meet the standard as prescribed in B.12.001 of the FDR prior to blending and the water product has not subsequently been subjected to modifications or treatments not permitted by the standard; and
- The quantity of mineral water and spring water are presented in a way that would not mislead the consumer about the composition, for example, by using an accompanying statement declaring the amount of mineral or spring water in the product.
Legibility - Water and Ice
Where mandatory information such as the net quantity has been blown or cast on the surface of a container, such as a glass bottle, it is not generally considered legible unless a colour contrast has been applied.
Refer to Legibility and Location for more information.
List of Ingredients - Water and Ice
Prepackaged water, ice, spring water and mineral water to which other ingredients such as fluoride, ozone, flavours or mineral salts have been added must carry a complete list of ingredients. If the common name includes all ingredients, it is considered to satisfy the list of ingredients requirement. For example, bottled water to which only fluoride has been added and is labelled with the common name "Water with added Fluoride" is considered to have a complete list of ingredients.
Chlorine or compounds of chlorine that have been used in the treatment of prepackaged water (other than mineral or spring water) and subsequently removed from the water are not required to be shown in the list of ingredients [B.12.007, FDR].
Refer to List of Ingredients for more information.
Nutrition Labelling - Water and Ice
Mineral water, spring water, water and prepackaged ice are exempt from Nutrition Facts tables when all of the required core nutritional information would be declared as zero [B.01.401 (2)(a), FDR]. Note that this exemption may not apply in all cases due to sodium or mineral content of some waters. Nutrition labelling exemptions may be lost in certain situations, such as when a voluntary claim (e.g. "sodium-free") is made on the label. Refer to Reasons for Losing the Exemption for more information.
Common names such as "Demineralized Water", "Mineral Water" or the presence of other information required by Division 12 of the FDR (such as the declaration of fluoride content) do not cause a loss of exemption from nutrition labelling [B.01.401 (3)(e)(i), FDR].
Additionally, the presence of added fluoride to prepackaged water or ice is not required to be declared in the Nutrition Facts table [B.01.402 (6), FDR]. (See Mineral Ion Concentration below).
Refer to Nutrition Labelling for more information.
Fortification - Water and Ice
Water to which vitamins and minerals have been added was previously regulated as a Natural Health Product under the jurisdiction of Health Canada. These products are currently being transitioned from Natural Health Products to foods. During the transition period, all such products require Temporary Marketing Authorization Letters from Health Canada, prior to marketing, to permit the vitamin and mineral addition.
Product Specific Labelling Requirements
Mineral or Spring Water
Prepackaged water that is represented as mineral water or spring water must be labelled with the following information on the principal display panel [B.12.002, FDR]:
- the geographical location (definition) of the underground source of the water;
- the total dissolved mineral salt content in parts per million;
- the total fluoride ion content in parts per million; and
- the declaration of any addition of fluoride or ozone, e.g. "ozonated", "with added fluoride".
Prepackaged water must be labelled with a description of any treatment it has undergone on the principal display panel. However, the following treatments are not required to be indicated [B.12.009, FDR]:
- the addition of an ingredient declared in the list of ingredients;
- chlorination followed by the removal of the agent used for the chlorination; together with any chlorine and compounds of chlorine produced in the water;
- decantation; and
- filtration (including microfiltration).
For example, an appropriate description for a product that has under gone electrolysis may be "electrolyzed" or "treated by electrolysis". Other examples of treatments that must be declared include reverse osmosis, deionization, and mineralization.
The total fluoride ion content in parts per million is also required to be declared on the principal display panel [B.12.008, FDR].
The total fluoride ion content in parts per million is required to be declared on the principal display panel [B.12.008, FDR].
Variations in Mandatory Labelling
Principal Display Panel
It is acceptable for the cap/ lid to be used as the principal display panel for large bottles of water, such as 20 L bottles, that are displayed on their side.
Voluntary Claims & Statements
Alkaline and pH claims
General claims such as alkaline and pH content may be declared provided they are factual and not misleading. The use of additional terms such as "super" or "organized" in conjunction with a claim, e.g. "Super Alkaline Organized" does not provide a clear meaning and is considered to be misleading in this context.
Glacier water is not defined in Canadian regulations. However, the CFIA will not object to claims and statements about glacier water origin when it meets the basic criteria as developed by the state of Alaska:
- glacier drinking water, or words of similar meaning, must be water from a stream that flows directly from a glacier and that has not been diluted or influenced by a non-glacial stream; and
- glacier-blend, glacially-influenced, or words of similar meaning, must be either water taken from a glacial stream that is influenced by a stream whose headwaters are not from a glacier; or water taken from a lake that is fed by a glacial stream.
Additionally, glacier waters are characterized by low dissolved solid levels and there should not be a significant change in dissolved solids between the glacier and the collection point. This would be assessed based on a maximum 50% increase in dissolved solids, or a maximum of 50 mg/L, whichever is greater.
Mineral Ion Concentration
With the exception of fluoride, declaring the amount of individual mineral ions present in prepackaged waters is optional. When mineral ion content is provided, it must be declared in parts per million outside of the Nutrition Facts table [B.01.301(1)(d), FDR]. Refer to Quantitative Declarations Outside the Nutrition Facts Table for more information.
Mineral or spring water which does not have its composition modified through the use of chemicals and meets the Natural – Method of Production Claim criteria in all other ways, such as how it is processed, may be described as "Natural Mineral Water" or "Natural Spring Water".
As ozone is classified as a food additive, prepackaged waters with added ozone may not make the claim "natural mineral water" or "natural spring water". However, claims such as "natural mineral water with added ozone" or "ozonated natural spring water" are acceptable.
Naturally Carbonated, Sparkling
A mineral or spring water containing carbon dioxide which originated underground may be described as "naturally carbonated", "naturally sparkling", or "sparkling" when:
- the added carbon dioxide originates from the decarbonation of the water upon its emergence from the underground source; and
- the carbon dioxide is not added to a level greater than the naturally occurring level, prior to the water emergence from the underground source.
Nutrient Content Claims
Products represented as containing mineral nutrients for use in human nutrition must meet the requirements of Part D of the FDR.
Claims such as "sodium-free" are permitted provided that the product meets the compositional and labelling requirements set out in Sodium (Salt) Claims [table following B.01.513, FDR]. Note that such a claim will trigger the Nutrition Facts table requirement on bottled water that might otherwise be exempt.
Therapeutic or prophylactic claims are not permitted on mineral water or mineralized water [Section 3, FDA].
Vignettes / Pictorial Representations
Vignettes and pictorial representations may not misrepresent the source of mineral water or spring water. It is misleading, for example, to depict a mountain scene on the label of a product whose source is located on the prairies [5.(1), FDA].
Refer to Pictures, Vignettes, Logos and Trade-marks for more information.
- Frequently Asked Questions about Bottled Water (Health Canada)
The name of the closest commonly recognized locality near or in which the source is located.
For the purpose of the FDR, an "underground source" means deeper waters of a water-bearing formation in the zone of saturated earth below the upper part of the ground-water zone.
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