Labelling requirements for prepackaged water and ice

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Overview

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.

Prepackaged water and ice sold in Canada are subject to the provisions of the :

When sold intraprovincially, prepackaged water and ice are subject to the labelling requirements under the FDA and FDR, as well as specific requirements of the SFCA and the SFCR that apply to prepackaged foods sold in Canada, regardless of the level of trade. Provincial regulations may also have labelling requirements that apply when these products are sold within that province.

Water represented as mineral or spring water has a prescribed standard in volume 11 of the Canadian Food Compositional Standards (CFCS) document. Part B, Division 12 of the FDR, also includes specific labelling requirements. Prepackaged mineral or spring 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 [11.1.1, CFCS], and fluoride [B.12.001, FDR] for the prevention of dental caries.

The labelling requirements detailed in the following section are specific to water and ice. Refer to the Industry Labelling Tool for additional core labelling and voluntary claims and statements requirements that apply to all prepackaged foods.

Note: The information in this section 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.

Common name

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 mineral or spring water may be labelled with the common name "mineral water" or "spring water" [11.1.1, CFCS, B.12.001, FDR]. While mineral water generally contains a larger amount of dissolved minerals than spring water, these 2 terms can be used interchangeably.

Carbonated mineral or spring water

Mineral or spring water containing added carbon dioxide is required to be labelled with a descriptive term that indicates this addition, such as "carbonated" or "sparkling", as part of the common name on the principal display panel when the added carbon dioxide [B.01.006.1(c), FDR]:

  • did not originate from the decarbonation of the water upon its emergence from the underground source, 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.

Water

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 could undergo various treatments which could affect its true nature. Examples of such treatments include distillation, demineralization and carbonation. In these cases, a descriptive term that indicates the condition of the water resulting from the treatment must be included in its common name, for example "distilled water", "demineralized water" and "carbonated water", in order to distinguish it from other prepackaged water for which it could be mistaken [B.01.006.1(c), FDR].

Water, mineral water or spring water with added ingredients

Water, mineral water or spring water that deviates from the standard specified in volume 11 of the Canadian Food Compositional Standards, such as water with added flavours, must be labelled with an appropriate common name to reflect these modifications. Examples include "berry-flavoured spring water", "carbonated water with cherry flavour", and "water with lemon juice". For more information, consult Modified standardized common name.

Water to which vitamins and minerals (except fluoride) have been added are Supplemented foods. Refer to item 1 "carbonated or non-carbonated water-based beverages" in the List of permitted supplemented food categories for more information.

Water blends

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
  • the mineral water or spring water meets the standard as prescribed in section 11.1.1 of the Canadian Food Compositional Standards document and meets the other labelling requirements set out in section 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

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

Prepackaged water, ice, spring water and mineral water to which permitted ingredients such as fluoride and ozone 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

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

Mineral water, spring water, water and prepackaged ice are exempt from a Nutrition facts table (NFt) when all of the required core nutritional information would be declared as zero [B.01.401(2)(a), FDR]. This exemption may not apply in all cases due to sodium or mineral content of some waters. The exemption from the NFt may be lost in certain situations, such as when a voluntary claim (for example, "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 section 11.1.1 of the CFCS document and Division 12 of the FDR (such as the declaration of fluoride content) do not cause a loss of exemption from the NFt [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 NFt [B.01.402(6), FDR]. See Mineral ion concentration below.

Refer to Nutrition labelling for more information.

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 [B.12.002, FDR]:

  • the geographical location of the underground source of the water
  • the total dissolved mineral salt content in parts per million, and
  • the total fluoride ion content in parts per million

Prepackaged water and ice

The total fluoride ion content in parts per million is required to be declared on the principal display panel of prepackaged water (other than water represented as mineral water or spring water) and ice [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 and 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, such as "super alkaline organized" does not provide a clear meaning and is considered to be misleading in this context.

Glacier water

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.

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 section D. Sodium/Salt Related Statements and Claims of the Table of Permitted Nutrient Content Statements and Claims. Note that such a claim will trigger the Nutrition Facts table requirement on bottled water that might otherwise be exempt.

Therapeutic claims

Therapeutic or prophylactic claims are not permitted on mineral water or mineralized water [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; 6(1), SFCA].

Refer to Pictures, vignettes, logos and trade-marks for more information.

Additional information

Resources (FAQ)

Definitions

Geographical location
The name of the closest commonly recognized locality near or in which the source is located.
Underground source
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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