BOTTLED WATER SURVEY

A report on a sampling survey examining the
composition and labelling of the varied range of
bottled water available locally.
The following varieties of bottled water :
Natural Mineral Water
Spring Water
Table Water
are compared with tap water locally supplied.
March 2005

SUMMARY
The following samples were taken :31 Natural Mineral Waters
20 Spring Waters
8
Bottled Drinking Waters
9
Local Tap Water
The samples were all analysed for :Chemical Analysis - pH value
- Nitrate
- Chloride
- Calcium
- Magnesium
- Fluoride
- Sodium
- Potassium

( NO3 mg/Litre)
( Cl mg/Litre )
( Ca mg/Litre )
( Mg mg/Litre )
( Fl mg/Litre )
( Na mg/Litre )
( K mg/Litre )

Microbiological Examination
- Colony count per ml at 22C after 72 hours
- Colony count per ml at 37C after 24 hours
- Total coliforms numbers per 250 ml
- Escherichia Coli ( E. coli ) number per 25 ml
Issues were identified with :- pH
- Nitrates
- Chloride
- Sodium / Salt
- Total Viable Count
A short word on Tap Water -v- Bottled Water
Problems identified with manufacturers guidelines
And
Recommendations given for new guidelines

RECOMMENDATIONS
In the main the recommendations apply to the updating / re-writing of the
Guidelines in line with current good manufacturing practice and the issues
observed as a result of this survey.
Clearly manufacturers need clear and modern guidelines to set industry standards,
so consumers can obtain appropriate information.
It is therefore vital that new guidelines are produced.
It is also recommended that they include the following :-

Set Standard levels of testing for specified parameters in line with good
manufacturing practice. Daily and Weekly analysis rather then monthly.

Set a specified review period for the typical analysis perhaps annually, with
a requirement to change the stated typical analysis in line with any drift away
from the previous levels.

That the updated typical analysis parameters should be readily available to the
general public as well as enforcement agencies.

A requirement to change the typical analysis on the label in line with

periodically reviewed and re-set level. These parameters to include the
normally observed microbiological levels.

Specify which parameters must be stated in the typical analysis on the label.
These to include

pH
Salt rather than Sodium
Calcium
Nitrates
Chloride
Fluoride

Specify which additional parameters can voluntarily be stated.

Specify how these levels are stated on the label. E.g.

o Consumers are interested in the amount of Salt present in each pack
rather than the mg/Litre of Sodium.
o The detection level of the test should be given rather than zero levels.
o The pH level of any water after the addition of carbon dioxide should
be given rather than the level of the source water.

CONTENTS
-

BACKGROUND
i. LEGISLATION
ii. AIMS

METHOD
i. STATISTICS

RESULTS
i. CHEMICAL ANALYSIS
1. pH VALUES
2. NITRATE
3. CHLORIDE
4. CALCIUM & MAGNESIUM
5. SODIUM
6. FLUORIDE
7. POTASSIUM
ii. MICROBIOLOGICAL EXAMINATION
1. TOTAL VIABLE COUNT
2. COLIFORM COUNTS

CONCLUSIONS

GUIDELINES

APPENDIX A RAW RESULTS

- APPENDIX B NUTRITIONAL INFORMATION

- APPENDIX C - GUIDELINES FOR THE RECOGNITION
AND EXPLOITATION OF NATURAL MINERAL WATERS

BACKGROUND
LEGISLATION

- The Private Water Supplies Regulations 1991

- The Water Supply ( Water Quality ) Regulations 2000
- The Natural Mineral Water, Spring Water and Bottled
Drinking Water Regulations 1999 as amended
With proposed amendments to the latter The Natural Mineral
Water, Spring Water and Bottled Drinking Water (Amendment)
(England)(No.2) Regulations 2004.

Tap Water is treated in order to remove bacterial and algal colonies living in the
water. Public Analyst doesnt find bugs in tap water unless there is a local problem
with storage on site.
Natural Mineral Water (NMW) is a statutory name for a specific type of water. A
NMW must be officially recognised through a local authority after a qualifying period
of two years, during which time it is repeatedly analysed. It must also be registered
with the Food Standards Agency. It must come from a specified ground water source
which is protected from all kinds of pollution. The water may not be treated in any
way to alter its original chemical and microbiological composition. In addition
NMWs must provide certain information on their labels such as a statement of the
analytical composition, which is required to indicate the characteristic constituents of
the water. There is, therefore no control over which mineral levels are labelled so
long as they are characteristic of the water. As of November 2004 there were 98
recognised Natural Mineral Waters from the UK.
Spring Water is a statutory name for water which comes from a single non-polluted
ground water source. Unlike NMW there is no formal recognition process required
although it must still be registered with the local authority. Many NMWs begin their
lives as Spring Waters trading as such during the two year testing period. Unlike
NMWs, Spring Waters may undergo permitted treatments but like NMWs must meet
microbiological criteria.
Drinking Water ( or Table Water which is the trade name applied to other bottled
drinking waters ) is any bottled water other than NMW or Spring Water. After NMW
and Spring Water the regulations only talk about Drinking Water. It applies to water
which may come from more than one source and may include the public water supply.
Treatment is permitted which results in the water achieving the
compositional/microbiological requirements of the regulations. Some companies may
also add mineral salts to their waters to replace those minerals lost during treatments
or to enhance those which already exist.
Guidelines for the recognition and exploitation of natural mineral waters. See
Appendix C for the 3rd Draft written by the Ministry of Agriculture Fisheries and
Food, May 1989.

- Tap water is safe, costs a fraction of a pence per litre and is environmentally friendly
in terms of transporting it direct to your home.
- The Drinking Water Inspectorate has found that if tap water has been chilled,
most of us cant taste the difference between tap and bottled water.
- When Health Which? taste-tested bottled water the panel of testers liked the tap
water as much as the bottled waters Bottled water on test, August 2000.
- So why should bottled water be so popular at 1,000s times the price of tap
water. Not to mention the environmental cost of transporting all those bottles ?
e.g. Blue water by the Ultimate Water Company reputably sold at 11.00 a litre !
AIMS
- To compare compositional analysis with declared values on label.
- To compare nutrition properties of mineral waters/spring waters with other bottled
waters and tap water.
- To use results to inform consumers of health issues re sodium levels and presence of
other minerals.

METHOD
The aim was to sample a variety of different waters available within this area. The
following types were sampled
- 31 samples of Natural Mineral Water
} 59 bottled
- 21 samples of Spring Water
} water samples
- 7 samples of Drinking Water
} in total
- 9 samples of Tap Water
Flavoured waters will not be looked at in this survey ( as these are covered by the
Food Labelling Regulations and need to be considered as soft drinks ).
Informal samples were taken. With bottled water unopened bottles were purchased
noting the price per litre at time of sampling. For tap water samples the tap was
allowed to run for 2 minutes prior to filling sterile sampling bottles provided by the
Public Analyst.
The analyst has reported on each water sample for :- Standard Micro Test
- Colony count at 22C after 72hrs
- Colony count at 37C after 24hrs
- Total Coliforms number per 250ml
- E. coli numbers per 250ml
- Chemical Analysis :- Nitrate
- Chloride
- Calcium
- Magnesium
- Fluoride
- Sodium
- Potassium
- pH value
Regulations set maximum levels for these parameters in all water except for
Natural Mineral Waters. In the case of Natural Mineral Waters no limits are set
but the water has to comply with the stated Typical Analysis.
STATISTICS
The chemical and pH values were compared with the Typical Analysis, where
stated, for each of the samples. These Typical Analyses were mainly taken from
the labels, but a few were available from websites. The differences of the actual
values found from those values declared, were noted and used to determine what
would be considered a reasonable difference from declared values. Most values
for the chemical composition were within 30% of the declared values. There
seemed to be greater variation for Chloride and Fluoride discussed later. Values
with greater than 30% difference from stated values were therefore considered
unacceptable

RESULTS
See Appendix A for the raw results.
CHEMICAL ANALYSIS
pH Values
The pH value is a measure of a solutions acidity or alkalinity, with a value of 7
being neutral neither acidic or alkaline. Pure water is neutral and therefore has a
pH value of 7 ( but carbon dioxide soon dissolves in the pure water making it
more acidic ). Acidic solutions have a pH of less than 7, while alkaline solutions
have a pH of greater than 7.
The proposed amendments to The Natural Mineral Water, Spring Water and
Bottled Drinking Water Regulations 1999, seek to increase the range of allowed
pH values to :Minimum 4.5 pH
Maximum 9.5 pH
The pH values of the samples were found to range from 4.2 to 8.7 from acidic to
alkaline. 3 samples had a pH value less than the proposed minimum of 4.5, while
being labelled as having values of 6.3 to 6.5. Manufacturers seem to be required to
label the pH value of the source water not the pH value of the water as sold.
All the sparkling versions of bottled water were found to be on the acidic side of
neutral. This is due to the introduction of Carbon Dioxide into the water, to give it
the fizz, which produces Carbonic Acid in solution rendering the whole acidic.
The potential problem here is that acidic drinks can damage teeth. This is a
recognised problem for children who consume fizzy soft drinks, and are therefore
encouraged to drink water instead. But what if they drink sparkling bottled waters
which are themselves acidic ?
The artificial carbonation of bottled waters can decrease the ph to levels of 4.5 or
lower. While helping to keep the water bacteriologically pure, it does make the
water aggressive and can lead to problems such as leaching of minerals from teeth
if drunk regularly. Drinking water with low pH levels could therefore cause
concern for Dentists.
39 of the survey samples were bottled waters with a stated pH value printed on the
label :-

pH Value

Bottled Water with pH Labelled

10
9
8
7
6
5
4
3
2
1
0
1

9 11 13 15 17 19 21 23 25 27 29 31 33 35 37 39
Samples
Actual pH

Labelled pH

pH values of 7 and above are Neutral to Alkaline, and are not an issue. Values
between 6 and 7 are probably not an issue, being only slightly Acidic. This graph
shows 14 samples with actual pH values below 6. All but 2 of these have stated
values higher than the actual found, these being values above 6.
Food Name

pH

Labelled

% Diff

Budgens Montgomery Spring - Sparkling NMW

5.2

8.24

-36.9

Highland Spring - Sparkling NMW

5.1

7.8

-34.6

Morrisons - Sparkling Spring Water

5.3

8.1

-34.6

TESCO Ashbeck Mountain Spring - Sparkling NMW

4.3

6.5

-33.8

CO-OP Fairbourne Springs Sparkling NMW

5.2

7.85

-33.8

Safeway Savers Sparkling Table Water

4.2

6.3

-33.3

Shepley Spring Water Sparkling

5.3

7.8

-32.1

Aqua-Pura - Sparkling NMW

4.4

6.4

-31.3

Asda - Fountain Head Sparkling Spring Water

5.3

7.5

-29.3

Hadham - English Spring Water Sparkling

5.5

7.4

-25.7

TY NANT - Sparkling NMW

5.1

6.8

-25

Harrogate Spa - Sparkling Spring Water

5.3

-24.3

4.6

8.7

5.2

4.3

20.9

Sainsbury's Caledonian - Sparkling NMW

Sainsbury's Pennine - Sparkling Spring Water

Of the 39 samples with a stated pH :-7 samples were labelled with an alkaline pH, but were found to be acidic;

- 5 samples with either a neutral pH or a slightly acidic pH were found to be

much more acidic.
- Where both a still and sparkling versions of a bottled water were sampled,
they both had the same stated pH.
NITRATE NO3
Nitrates are naturally present in all sources of water. Higher levels in water can
indicate contamination, whether from Human or animal waste or fertiliser runoff
from farmers fields. For this reason levels are strictly controlled in tap water. All
the samples analysed were well below the maximum levels set for tap water.
Natural Mineral Waters are not allowed to be treated, so nitrates already present in
these waters can not be removed. Great care is therefore taken to ensure the
Natural Mineral Waters comes from a source well away from such potential
sources of contamination.
Many aquifers are showing increasing nitrate levels and there is a tendency not to
state nitrate levels in the typical analysis. Excessive nitrate can give rise to two
problems: infantile methaemoglobinaaemia and the formation of nitrosamines.
The nitrate itself is not a direct toxicant, but it is the conversion of nitrate to nitrite
which causes the problems. This can occur readily in the digestive tract under
certain conditions, so low nitrate levels are desirable.
Up to a maximum of 50mg/Litre of Nitrate is allowed in Tap Water, Spring Water
and Drinking Water.
- Bottled waters sampled ranged from less than 5 mg/Litre to 33 mg/Litre.
- Tap water sampled ranged from 16mg/Litre to 27mg/Litre.
All of these were within the limits specified.
Actual levels below 5 mg/Litre were not reported as this is the limit of detection
employed in the laboratory. For results stated as <5 mg/Litre it cant be
established that either no Nitrate was present or that it was present but at levels
less than 5 mg/Litre. Only 29 out of 68 samples ( 20% ) had levels of Nitrate
above 5 mg/Litre :Samples with levels above 5 mg/L NO3
35
30

mg/Litre

25
20
15
10
5
0
1

11

13

15

17

19

21

23

25

27

29

Of these 29 samples only 19 bottled waters with levels above 5 mg/Litre

voluntarily labelled the typical levels of nitrates present :-

% Difference from stated NO3 levels

% Difference

60
40
20
0
-20
-40

10 11 12 13 14 15 16 17 18

Series1 43 33 33 26 17 15 11 10 10 10 10

-8

-9 -33

The only brand to significantly understate the levels of nitrate present was
Hadham Naturally Pure English Spring Water with 23 mg/Litre labelled as
typically present but actually having 33 mg/L for Sparkling ( 43% difference ) and
29 mg/Litre for Still ( 33% difference ).
One sample ( Ashe Park Natural Mineral Water not shown here ) stated the
Nitrogen content of Nitrate as 6.9 mg/Litre, rather than state the actual Nitrate
level. From this it was calculated that the Nitrate level would be 30.5 mg/Litre, the
Public Analyst actually found 31 mg/Litre. Paragraph 15 of the Guidelines ( see
Appendix C ) seems to suggest that Nitrate levels should be expressed as NO3
mg/Litre.
5 samples stated a Zero level for Nitrates. 26 further samples stated Nitrate levels
of less than 5 mg/Litre ( 4 of these less than 1 mg/Litre ). The Public Analysts
results can neither confirm nor refute this statement.
Food Name

Stated NO3

Budgens Montgomery Spring - Sparkling NMW

0<5

Budgens Montgomery Spring - Still NMW

0<5

CO-OP Fairbourne Springs Still NMW

0<5

CO-OP Fairbourne Springs Sparkling NMW

0<5

Springbourne Still NMW

0<5

Buxton - Still NMW

0.1<5

TY NANT - Sparkling NMW

0.1<5

TY NANT - Still NMW

0.1<5

Vittel NMW

0.6<5

CHLORIDE - Cl

This is naturally present at low levels in all water supplies. The highest level
found in the bottled waters sampled was 186 mg/Litre, Chloride is not dangerous
at these concentrations. Chloride seems to have a taste threshold of about 200
mg/Litre, but even this level wasnt reached.
The amounts of Chloride present varied between :Tap Water
18mg to 72mg per Litre
Bottled Water
4mg to 186mg per Litre
Stated Values
4.5mg to 155mg per Litre
Even the highest level of Chloride found was less than half the maximum of
400mg/Litre allowed by regulation for Tap, Spring and Drinking water.
55 samples out of the 59 bottled water analysed stated a typical figure for the
presence of Chloride in the water.
The Public Analyst found much greater variation in the results from the analyses
as a whole for Chloride. The Public Analyst as a result considered 50% variation
to be the limits of acceptability. 18 of the samples were found to have above a
30% difference from the stated value, while 7 of these had a difference above
50%.
6 samples understated the presence of Chloride by greater than 50% ( the worst
being a 500% difference ).

53

49

45

41

37

33

29

25

21

17

13

600.0
500.0
400.0
300.0
200.0
100.0
0.0
-100.0
-200.0

% Difference

Cl Difference from Label

Samples

Bottled waters have both much lower and much higher levels than tap water
depending on the geology of the water source.
CALCIUM - Ca & MAGNESIUM - Mg

These are naturally present in water at varying amounts, and together contribute to
the hardness of the water. The local tap water is hard, so it is not surprising that
the majority of bottled waters have less calcium than local tap water.
Tap, Spring and Drinking water is allowed the following levels :Calcium
up to a maximum of 250mg/Litre.
Magnesium
up to a maximum of 50mg/Litre.
-

56 bottled water labels stated a typical level for Calcium;

Calcium levels stated on labels varied from 4mg to 190mg per Litre;
Calcium levels in the water source found varied from 4.4mg to 202mg/L;
1 sample had added calcium as an ingredient (see below) to 359mg/Litre;
8 samples had a difference of greater than 30% (3 greater than 50%);

55 bottled water labels stated a typical level for Magnesium;

Magnesium levels stated on labels varied from 2mg to 85mg per Litre;
Magnesium levels found varied from <0.1mg to 81mg per Litre;
14 samples had a difference greater than 30% (9 greater than 50%).

No water source exceeded the maximum level allowed for Calcium in tap water,
even the locally hard tap water did not reach half the permitted level. The sample
with calcium as an ingredient, however, did exceed this level. 2 European Natural
Mineral Waters exceeded the maximum level permitted for Magnesium in tap,
spring or drinking water :- San Pellegrino Sparkling Natural Mineral Water at 56mg/Litre
- Badoit Sparkling Natural Mineral Water at 81mg/Litre
The Private Water Supplies Regulations 1991 set a minimum hardness of 60
mg/Litre of Calcium. 40 bottled water samples were below this level. The same
level applies for Spring Water and Drinking Water but only where the water has
been softened or desalinated. 17 samples of these categories of bottled water were
below this limit, but these were unlikely to have been softened or desalinated.
There is no such corresponding requirement for Natural Mineral Waters.
In the case of Danone Activ the label stated a typical value of 31mg/Litre of
Calcium in the Spring Water, the Public Analyst actually found 359mg/Litre. This
product is actually Still Water plus Calcium calcium being added to the water
to provide as much calcium as a 250ml glass of milk.
SODIUM - Na / SALT
Sodium in association with chloride ( Salt Sodium Chloride ) occurs naturally as
a very dilute salt in all water sources.
Sodium is permitted to a maximum level of 150mg/Litre in Tap, Spring and
Drinking water.
In fact one of the Natural Mineral Water samples reached this level of Sodium :- BADOIT Sparkling Natural Mineral Water with 152mg/Litre of Sodium

Of the bottled water only 2 samples did not state a typical level in the water for
Sodium these were Table Waters, which gave no typical analyses at all, as
allowed by the regulations.
Only one sample significantly understated the level of Sodium present
Co-op Fairbourne Springs Still Natural Mineral Water stated 31.2mg/Litre, BUT
78mg/Litre were found by the Public Analyst. While the Co-op Fairbourne
Springs Sparkling Natural Mineral Water was found only to have 26mg/Litre of
Sodium.
FLUORIDE - Fl
The Fluoride levels in the tap water sampled ranged from 0.08mg/Litre to
0.23mg/Litre ( at the highest level less than one sixth of the maximum allowed ).
The Fluoride levels in the bottled waters sampled ranged from 0.08mg/Litre to
0.55mg/Litre ( more than double the highest from the tap water, but still only
about one third of the maximum allowed for tap, spring and drinking water ).
24 of the bottled waters sampled stated a level for the presence of Fluoride in the
water. These showed a much greater variation from the stated levels than most of
the minerals tested ( up to 321% difference ) but the actual levels are so low these
percentage differences are probably meaningless.

0.6
0.4
0.2

Samples

31

29

27

25

23

21

19

17

15

13

11

0
1

Fl mg/Litre

Fluoride in Natural Mineral Waters

37

34

31

28

25

22

19

16

13

10

0.4
0.3
0.2
0.1
0
1

Fl mg/Litre

Fluoride in other Water

Samples

POTASSIUM K
Potassium occurs in all water sources in trace amounts.
The maximum level allowed for Potassium in Tap, Spring and Drinking water is
12mg/Litre.
62 out of 68 samples, had levels of Potassium that were less than half the
maximum allowed for tap water.
The highest Potassium level found was at 10.9 mg/Litre in Badoit Sparkling
Natural Mineral Water. At these levels water is unlikely to make a significant
contribution to the daily recommended Potassium intake and is unlikely to have an
adverse effect on health.
The biggest differences between the stated level and the levels found in the water,
were due to over statements so safe levels were not exceeded.

MICROBIOLOGICAL EXAMINATION
Total Viable Count
The Total Viable Count (TVC), or Aerobic Colony Counts, is a test used to
measure the general quality of water. The data is commonly used to plot changes
in water quality over time. The legislation requires there be No significant
increase over that normally observed.
A summary of the Total Viable Counts per ml of water are as follows :Natural Mineral Waters
- only 1 sample had a zero count at 22C and 5 samples had counts in excess
of 1,000;
- only 2 samples had zero counts at 37C, with 1 sample having a count in
excess of 1,000;
Spring Water
- 2 samples had zero counts at 22C, with 3 samples having counts in excess of
1,000;
- 3 samples had zero counts at 37C, the highest being 410;
Drinking Water
- the counts at 22C ranged from a count of 1, to 1 sample with over 1,000;
- 1 sample had a zero count at 37C, the highest count being 17;
Tap Water
- 3 samples had zero counts at 22C, the highest count being 20;
- the counts at 37C ranged from 4 to 30.

Coliforms Counts
No coliform counts were recorded. Such an absence of coliforms bacteria
indicates that there is no faecal pollution in the waters sampled.

CONCLUSIONS
pH VALUES
pH values given on labels were the typical values for the water from the
source, NOT the pH value of the bottled water after the Carbon Dioxide has
been added.
This is misleading, especially for those trying to avoid acidic drinks in order
to have healthier teeth.
NITRATE
The levels of nitrates found in bottled water do not indicate potential health
problems. But there seems to be a trend for the Nitrate levels to increase over
time, possibly with changing farming / land use patterns. This could be a
significant increase on that labelled where the original exploitation of the water
was some considerable time ago.
As already stated above, Nitrates are naturally present in all sources of water and
its unlikely that no nitrate is present in the samples labelled as having 0 Nitrates.
It could be construed that this 0 value is technically incorrect and misleading, the
bottle should be marked with the limit of detection of the test house. 4 further
samples stated Nitrate levels of less than 1 mg/Litre statements of <1 mg/Litre
should be possible.
CHLORIDE
The levels of Chloride found in bottled water do not indicate potential health
problems. However there is a problem with the accurate labelling of Chloride
levels present.
55 samples out of the 59 bottled water analysed stated a typical figure for the
presence of Chloride in the water. This is a very high level of voluntary labelling.
Could this be due to the fact that high levels are equated with bad tastes ? If so a
level of understating of the Chloride levels could be expected, and this does seem
to be an issue.
Even allowing a 50% variation in the level of Chloride found compared with that
stated, 6 samples managed to understate the Chloride level by more than 50%.
With 12 understating by more than 30%.
CALCIUM / MAGNESIUM
Waters from areas with chalk dominated geology, which are high in calcium in
particular, are naturally hard. These minerals are particularly important in the
production and maintenance of healthy bones. Recommended daily levels are
specified for both of these minerals, to ensure continued health. For example for
19 to 50 year olds :Mineral
Male
Female
Calcium
700 mg
700 mg
Magnesium

300 mg

270 mg

It is unlikely that high levels of these mineral would cause any health problems. In
fact drinking hard water has been linked to reduced risk of heart attacks. Only 3
samples showed levels above what is allowed for tap, spring or drinking water.
These samples are :1 - Danone Activ which was found to have a total Calcium level of 359 mg/Litre,
which was in fact described as Still Water plus Calcium. This product is
therefore being sold as a refreshing and simple way to top up you and your
familys calcium levels.
The label also states :-

1 litre of
Danone Activ provides
as much Calcium as
A 250ml
glass of
milk*
=37% calcium RDA*
Nutritional Information: 100 ml provides Energy 0kj/0kcal, Protein0g,
Carbohydrate 0g, Fat 0g, calcium 30mg.
1 litre provides calcium 300mg = 37% RDA*
Ingredients: Spring Water 99.1% (Typical Analysis per litre : calcium 31mg,
sodium 8mg, magnesium 6mg, potassium 7mg, nitrates 3mg, chlorides 16mg,
sulphates <5mg, silica 8mg ), calcium carbonate/chloride/sulphate, carbon dioxide.
*RDA = Recommended Daily Allowance ( 800mg/day )

The label refers to calcium levels of 30 mg in the Nutritional Information, 31

mg in the Ingredients List / Typical Analysis, and 300 mg in reference to the
RDA. If not misleading the label is certainly confusing.
The label seems to indicate that that there are 31mg/litre of calcium present
in the source spring water, and calcium is added to a level of 300mg/litre.
However, the Public Analyst actually found 359 mg/Litre of Calcium in this
product a difference of almost 20% extra.
2 As previously stated two samples of Natural Mineral Water were found to
exceed the permitted levels for Magnesium. These levels only apply to tap, spring
and drinking waters they do not apply to Natural Mineral Waters. There are no
relevant maximum limits for minerals in Natural Mineral Waters, so long as the
composition of this water is reasonably stable. In any case the levels found are
unlikely to indicate any health concerns.

SODIUM / SALT
This is a key element in bottled water and is essential for health. In healthy adults
excess sodium is excreted, but in sensitive adults such as those with hypertension
and heart weakness, infants with immature kidneys and the elderly, high sodium
levels may cause problems and so a low sodium diet is often advised.
Deaths of babies have occurred from drinking formula feeds made up with high
sodium mineral waters, so if bottled water needs to be used, choose one with the
lowest sodium levels. This is also the reason behind the requirement for an
untreated tap, when salt using water softeners are installed in houses.
Sodium is associated with high blood pressure, hence the recent emphasis on
reduced salt diets. An adults daily maximum dose of salt is 6g, a minimum
amount is considered to be 1.6g per day.
For routine use by the family it may be advisable to look for a water with less than
150 mg/Litre, and preferably less than 50 mg/Litre. Only 12 samples were found
to have levels above 50 mg/Litre, the highest being at 152 mg/Litre. Again the
maximum level of 150 mg/Litre of Sodium do not apply to Natural Mineral
Waters they can legally have levels higher than this so long as the composition
of the water is stable.
See information on the Food Standards Agency website :http://www.salt.gov.uk
This includes a Salt Calculator
Using the Salt Calculator on a level of Sodium at 150 mg/Litre we get
375mg/litre of Salt are present in each Litre of water
If a person drinks 2 Litres of such water a day, as advised, then 0.75g of salt will
be consumed this is equivalent to 12.5% of the daily allowance.
This is a significant proportion of a person daily salt intake especially when
most people would not think of salt being present in the water they drink.
FLUORIDE
Traces of Fluoride occur naturally in many water sources. Fluoride is added to tap
water in some areas at the request of the local Health Authority to protect the teeth
of young children.
http://www.dentalhealth.org.uk/faqs/leafletdetails.php?LeafletID=17
It seems to be generally accepted that the addition of fluoride to water supplies to
bring the level above 0.6 mg/Litre led to a reduction in tooth decay in growing
children, with the optimal beneficial effect occurring around 1.0 mg/Litre. Other
studies have indicated that fluoride is also beneficial to older people in reducing
the hardness of the arteries and in the treatment of osteoporosis.

Fluoride levels in excess of 1.5 mg/Litre lead to an increase in the occurrence and
severity of dental fluorosis ( teeth becoming mottled and brittle ) without
decreasing the incidence of decay, missing teeth or filled teeth. Long-term
exposure to Fluoride may result in permanent grey to black discolouration.
Children who drink water containing fluoride in excess of 5 mg/Litre also develop
severe pitting of the enamel. This explains the maximum levels of 1.5mg/Litre
allowed in Tap, Spring and Drinking water. Some water sources have to reduce
the level of Fluoride to make it safe
No Fluoride being added to the tap water sampled locally.
POTASSIUM
Potassium occurs in all water sources in trace amounts. Recommended daily
levels are specified for this mineral, to ensure continued health, at 3,500mg/day.
Although it is an essential element, the body finds it difficult to deal with excess
potassium, resulting in kidney stress and possible kidney failure. Although
potassium is not considered to be toxic, long-term exposure to high potassium
concentrations should be avoided. Hence the maximum level allowed for
Potassium in Tap, Spring and Drinking water is 12mg/Litre.
TOTAL VIABLE COUNT
The Total Viable Count (TVC), or Aerobic Colony Counts, is a test used to
measure the general quality of water. The data is commonly used to plot changes
in water quality over time. Aerobic bacteria, yeasts and mould are all detected as
colonies growing on a standard growth medium which is inoculated from the
water sample. A physical count of the number of separate colonies found growing
on the growth medium produces the TVC figure.
The inoculated growth media are incubated at 22C and 37C, this gives two
separate TVC figures for a water sample. The lower incubation temperature will
encourage the growth of bacteria that may be derived from environmental sources.
The higher incubation temperature will encourage the growth of bacteria that may
be derived from human or animal sources.
The legislation for Natural Mineral Waters requires there be No significant
increase over that normally observed. These levels, to have any legal validity,
need to be checked at source or almost immediately after bottling. The samples in
this survey were taken from shop shelves obviously some considerable time
after bottling and therefore have no legal basis. In any case the levels normally
observed at source are not known by the Public Analyst and can not be compared
to the levels found in the bottles.
The reason for testing at or near the source is that if any viable colonies are
present they can grow and multiply after bottling. As already stated Natural
Mineral Waters can not be treated to remove their presence, the emphasis must
therefore be on obtaining water which is isolated from any sources of pollution.
High TVCs found in bottled could be due to multiplication of living organisms
after bottling from low numbers present in the source water. It is however

impossible for the Public Analyst to state what these levels would have been at the
time of bottling.
COLIFORM COUNTS
Any pathogenic micro-organisms in water supplies will probably be present in
low numbers and the methods for their detection are usually difficult and timeconsuming. Reliance is therefore placed on simpler and quicker tests for the
detection of indicator organisms, usually Coliforms bacteria. Coliforms bacteria
are always present in the faeces of man and warm-blooded animals in large
numbers. An absence of Coliforms bacteria indicates that there is no faecal
pollution ( or that it has been eliminated and therefore the risk of the water
containing pathogenic bacteria may be considered remote. Surface waters may
contain large numbers of Coliforms bacteria whereas ground waters drawn from
well-constructed and maintained wells and boreholes are less prone to
contamination and may contain no Coliforms.
No Coliforms were found in any of the samples. This indicates there is no
problem, and the producers controls seem to be adequate.
TAP WATER - V - BOTTLED WATER
It is very difficult to come to any firm conclusions here regarding the merits and
disadvantages of the different waters sampled in this survey. For one thing there is
such a wide variation in Natural Mineral Waters, let alone the other forms of
bottled water.
What is clear, however, is that tap water as a result of the required treatments,
consistently sit within the safety limits of whichever parameter is being looked at.
The very nature of Natural Mineral Waters
- they have high mineral contents;
- the mineral content varies from source to source;
- they cant be treated in any way other than by the addition of
carbon dioxide;
means that some vulnerable consumers need to take care which brands they
consume. This is not the case with tap water, which also has the advantage of :- being ecologically friendly ( it is not transported by road etc over
large distances, or even around the world );
- being a fraction of the cost of bottled water;
Are consumers actually paying considerable sums for WATER when they buy
bottled products ?
OR
Are they buying into the image of PURITY ?
If they are actually buying the latter these results show they should be paying
a fraction of these prices for tap water !

GUIDELINES FOR THE RECOGNITION AND

EXPLOITATION OF NATURAL MINERAL
WATERS
See APPENDIX C
Manufacturers have stated these are the only guidelines they have to help them
negotiate the complexities of the legislation. The Third Draft, copied here in
Appendix C, date from May 1989. This was a time before the major boom in the
bottled water industry and sometimes refers to practices no longer current.
The following points are mentioned in the numbered paragraph from the
Guidelines :2 Refer to 1985 Regulations, now revoked and replaced.
3 The composition of Natural Mineral Waters must be reasonably stable.
It doesnt state what reasonable means.
4 The conditions surrounding a catchment area can change over time and so
therefore can the composition of the water.
With the previous point, this seems to indicate that the composition of the water
can remain reasonably stable while changing over time. The composition may
drift over time such that after a few years the composition may be quite different
from the time it was originally exploited, whilst still remaining reasonably stable.
Meanwhile the label will still carry the typical analysis from the time the water
was originally exploited.
This would seem to be a major factor in the large differences seen between the
actual composition of the Natural Mineral Water and the composition stated on
the label.
13 Refers to tests to determine the Dry residues at 180C and 260C.
These are tests that are not generally carried out now.
Various intervals of testing are stated for different parameters :21 Parasites and Pathogens at not less than 6 monthly intervals over 2 years;
22 Coliform testing to be carried out at least monthly intervals;
23 Total Viable Colony Count be measured monthly over a period of 2 years;
The normal viable count can then be established by assessing the range of counts
over this period.

25 Pollution testing to be carried out at 3 monthly intervals over 2 years.

These intervals between tests seem rather long in light of current good
manufacturing practice. It also only refers to test taking place within the initial
two year period. Can they stop worrying about tests after this period ?
26 Refers to Stability
the composition of natural mineral water should be inherently stable. It is
recognised that some variation will inevitably occur in all waters, but
unfortunately the Directive offers no useful guidance on what degree of variation
is permissible. . To establish stability, it is necessary to collect information over
a sufficiently long period to demonstrate the extent to which the composition
varies. These guidelines recommend an analytical regime for a number of
parameters over a period of two years. It is recommended that the variation of
results should be within the following limits.
Characteristic

Frequency

Acceptable Variation

Mineral content, determined

As dry residue and
Electrical conductivity

monthly

+20%

Individual anions, captions,

And non-ionised compounds

three monthly

+20%

In addition, the level of the total viable count should be no higher than that
normally observed.
Notice the acceptable variations are only stated as +, not +/-.
What does inherently stable and no higher than that normally observed
mean ? Is this no higher than normally observed during the first two year period,
or what is currently observed ?
The Guidelines can therefore be considered a mixed blessing, or even a
hindrance to good manufacturing practice. They certainly seem to be a
hindrance to clear, accurate and informative labelling. They appear to be at
the root of the problem of giving consumers misleading information.

APPENDIX A
THE RAW RESULTS
Food Name

/L
pH NO3 Cl

CO-OP Fairbourne
Springs - Still NMW

0.33

Highland Spring - Still

NMW

0.50

Highland Spring Sparkling NMW

0.55

CO-OP Fairbourne
Springs Sparkling NMW

0.55

Budgens Montgomery
Spring - Sparkling NMW

0.34

Budgens Montgomery
Spring - Still NMW

0.25

Sainsbury's Pennine Sparkling Spring Water

0.22

Sainsbury's Pennine Still Spring Water

0.22

Sainsbury's Low Price Sparkling Table Water

0.22

Sainsbury's Low Price Still Table Water

0.22

Safeway Savers
Sparkling Table Water

0.04

Safeway Savers Still

Table Water

0.12

Evian - NMW - Still

0.34

Ca Mg

7.6 <5

53 49

7.7 <5

6 28

5.1 <5

Fl
7

Na
0.42

ColonyCount
22'C 37'C Coliforms E. coli

78 6.6 >1000

7 <0.08

5.1 <1 >1000

5 28

0.31

5.1 <1

5.2 <5

19 56

0.24

26 7.6

5.2 <5

51 48

3.4

0.32

76 5.3

7.5 <5

31 45

4.5

0.34

69 5.4

5.2 <5

72 59

24

0.16

28 4.7

7.7 <5

72 57

21

0.13

31 4.2

114

5.3 <5

62 23

0.19

23

7.9 <5

65 21

0.18

62 4.1 >1000

10

4.2

22 18 6.5

2.2 <0.18

7.2 2.2

6.1

22 14 6.2

1.9

9.9

7.2 <5

6 72

7.4 <5

0.09

27 <0.08

6.5 <1

50

106 60

24

0.29

14 <1

5.3 <5

10 23

0.38

66 2.4

10

7.9 <5

63 26

11

0.17

96

4 >1000

5.3 <5

69 26

11

0.18

87

7.1 <5

4 73

2 <1 >1000

7.1 <5

18 46

5.7 3.3 >1000

6.4 <1

Dasani - Pure, Still Water 0.39

Shepley Spring Water

0.25

Asda - Fountain Head

Still Spring Water

0.09

Asda - Fountain Head

Sparkling Spring Water

0.09

Aquarel - Spring Water

0.50

Harrogate Spa - Still

Spring Water

0.49

Asda - Glenburn Spring

Sparkling

0.70

5.1 <5
5 30
Hadham - English Spring 0.48
Water - Still
7.4 29 18 112
Hadham - English Spring 0.48
Water - Sparkling
5.5 33 22 121
Buxton - Still NMW
0.32
7.5 <5
36 50

2.7 <0.08
16

0.13

7 <0.08
2.9

0.16

8.1 1.7

72

0.11

8.5 1.8

19

0.15

24

1 >1000 >1000

Food Name

/L
pH NO3 Cal Ca Mg

Vittel NMW

Fl

Na

ColonyCount
22'C
37'C Coliforms E. coli

0.36

7.2 <5
TESCO Asbeck Mountain 0.22
Spring - Sparkling NMW
4.3 22
TESCO Asbeck Mountain 0.22
Spring - Still NMW
6 23
TESCO Value - Still
0.09
Spring Water
7.3 21
TESCO Value - Sparkling 0.09
Spring Water
5.4 21
TESCO Perthshire
0.23
Mountain Spring - Still
NMW
7.4 <5
0.23
TESCO Perthshire
Mountain Spring Sparkling NMW
5.2 <5
San Pellegrino 1.08
Sparkling NMW
5.2 <5
Acqua Panna - Still NMW 1.05
8
6
TY NANT - Still NMW
1.85
7.3 <5
TY NANT - Sparkling
1.85
NMW
5.1 <5
Sainsbury's Caledonian - 0.49
Sparkling NMW
5 <5
Sainsbury's Caledonian - 0.24
Still NMW
7.4 <5
BADOIT - Sparkling
0.92
NMW
6
7
Volvic - Still NMW
0.35
7.1
7
Danone Activ - Still Water 0.38
plus Calcium
6.8 <5
Asda - Eden Falls Still
0.48
NMW
6.9 27
Lakeland Willow Spring
0.86
Water - Still
7.6 22
Deeside - NMW Still
0.49
6.4 <5
Aqua-Pura - NMW - Still 0.31
6.5
8
Aqua-Pura - Sparkling
0.31
NMW
4.4
8
Perrier - NMW fortified
1.00
with gas from the spring
5.5
5
Morrisons - Still Spring
0.21
Water
7.6 <5
Morrisons - Sparkling
0.21
Spring Water
5.3 <5

6 77

19

0.14

7.4 4.7

24

23

14 8.8

2.3 <0.08

9.5 2.1

17

14

14 10

2.5

9.9 2.2

41

12

30 91

3.4 <0.08 14.8 1.5

453

410

33 98

3.3

12

11

0.11

0.08

15 1.6

8 38

12 <0.08

10 <1

112

12

11 21

13 <0.08

9.1 <1

76

62

64 202

56

0.55

34 2.4

80

75

9 31 0.09

7.2 <1 >1000

14 16

13

0.13

21 <1

134

14

18 23

12

0.18

20 <1

8 33

10

0.24

9 <1

14

6.1 <1

6 30

5 <0.8

54 145

81

0.52 152 11

11 8.5

0.24 10.8 5.7

68

186 359

0.08

7.9 6.2

15

20 25

3.9 <0.08

15 2.3

20 86

14 <0.08

13 1.4

485

41

30

8.1 1.8

6 4.4 0.49
6 7.5

2.7

2 <0.08

6.4 <1

21 4.6

1.7

0.13

6.2 1.2

22 135

0.13

11 1.2

12 27

10

0.29

54 2.4

379

13 28

10

0.35

60 2.7

Food Name

/L
pH NO3 Cal Ca Mg

M & S Still NMW Carding Mill

0.40

M & S Still Spring Water

0.40

M & S Sparkling Spring

Water

1.20

Strathmore - Still Spring

Water

0.70

Strathmore - Sparkling
Spring Water

0.70

Deveron Valley - Still

Scottish Spring Water

0.60

Harrogate Spa Sparkling Spring Water

0.33

Brecon Carreg - Still

NMW

0.53

Fl

Na

6.6

8 18 15

4.3 <0.08

10 <1

7.1

14 12 108

4.3 <0.08

7.7

5.7

11 26 106

21

7.7 <5

163 64

5.2 <5

161 51 <0.08

ColonyCount
22'C
37'C Coliforms E. coli

12 1.4

53 2.7

760

0.08

53 2.6

0.08

12 <0.08

7 <5

81 47

0.25

45 3.1

31

60

5.3 <5

21 46

16

0.16

5.5 3.3

17

28

7.6 <5

10 61

17 <0.08

7.7 <5

30 85

5.3 <1

Springbourne Still NMW

7

0.21

38 4.6

540

55

7.4

24 22 104 0.12

12

12 1.5

10

7.7

19 18 103 <0.08

9 1.1

32

17

7.7
Tap Water - Bedfordshire 0.03
area
7.6
Tap Water - Hertfordshire 0.03
area
7.5
Tap Water Oxford area 0.03
8.2
Tap Water - Aylesbury
0.03
domestic
7.5
Tap Water - Trading
0.03
Standards
7.5
Ashe Park Natural
Mineral Water - Cooler
Water
7.4
Tap Water Tower Block 0.03
7.5
Tap Water - Marlow
0.03
7.5

16 66 89 0.22

45 8.7

10

19 72 99

0.2

47 9.5

10

21 19 106 <0.08

11 1.3

20

26 29 88 0.23

19

13

26 22 98 0.11

12 1.8

13 1.8

16

14

9 <1 >1000

705

Tap Water - Chesham

area

0.03

Eden Water - water

cooler
Tap Water Great
Brickhill area

0.03

27 21 94

2 <0.08

31 108 18

0.33

26 18 106

0.15

13 1.8

20

30

26 20 107 0.15

12 1.9

12

0.33

13 2.1

Infinity Ionic Micro Water

8.7 <5
28 6
Dasani - No longer in Production
Danone Acitv' - with added calcium
Infinity - from New Zealand, not currently being sold
NMW = Natural Mineral Water

APPENDIX B
NUTRITIONAL INFORMATION
The daily Reference Nutrient Intake ( RNI ) is an amount of a nutrient that is
enough or more than enough for about 97% of people in a group. This is different
to RDAs Recommended Daily Amount 15% of RDA is considered a Good
or Significant source of that nutrient. RNIs for adults between 19 and 50 years
( different to RDAs ) :Male
Female
Calcium ( Ca )
700mg
700mg
Chloride ( Cl ) no level given, average intakes range from 85 145 mmol
Magnesium (Mg )
300mg
270mg
Fluoride
no level given. 0.5 2.6g / day over short period gives rise to
acute and potentially fatal fluorosis
Sodium
1600 mg
Potassium
3,500 mg

APPENDIX C