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I just saw a post talking about how various brands of spring water in the UK are not meeting regulations because they are bottled at a different location to the spring.

Looking online, most sites (including https://www.gov.uk/guidance/spring-water-how-to-produce-and-label) specify that "bottling must take place at the spring or borehole", with some linking to the legislation for England:

The Natural Mineral Water, Spring Water and Bottled Drinking Water (England) Regulations 2007

However, while I know my legal speak isn't very good, I just can't find where in that document it explicitly says that spring water must be bottled at source?

Schedule 10 (the most obvious place) just seems to say it must be extracted from spring, not altered, and meet Schedule 2&4. Those two schedules seems to mainly just cover the requirements for the water to be legally considered mineral/spring, but don't cover bottling.

Is someone able to point out where in the regulations it states that the water must be bottled at source?

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Admittedly it's not very clear, but paragraph 5 of Schedule 4 restricts the use of anything else apart from the resulting consumers' bottles, ergo bottling has to take place at the point of extraction (Subject to sub-para 3):

5.—(1) Subject to sub-paragraphs (2) and (3), water must not be transported in containers other than those authorised for distribution to the ultimate consumer.

(2) [omitted]

(3) Water distributed to the ultimate consumer in a bottle marked or labelled with the description “spring water” may be transported from the spring to the bottling plant in a container which is not for distribution to the ultimate consumer if, on or before 13th December 1996, water from that spring was so transported.

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  • Ah thanks, so (ignoring the 1996 clause) it can't be contained in anything other than the final bottle. Although it does seem paragraph 3 opens the door to catching/piping then storing in open reservoir if it doesn't alter the water...
    – USD Matt
    Jan 19, 2023 at 13:37
  • @USDMatt para 3 is presumably to allow for bottling plants' infrastructure. Otherwise it would be a slow process filling one bottle at a time direct from the spring (not to mention getting wet feet!)
    – user35069
    Jan 19, 2023 at 14:41

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