Code of Practice


Table of Contents

1.1   Introduction

1.2    Definitions

1.3    Water Quality

1.4    Source Water Monitoring

1.5    Manufacturing and Operational Requirements

        1.5.1     Manufacturing Requirements

        1.5.2     Operational Requirements

1.6    Product Water Monitoring

1.7    Labelling


Code of Practice


  • Introduction


This Code of Practice has been developed by The International Foundation for the Protection of Drinking Water (IFPDW)
as a minimum requirement of the production of safe and hygienic bottled water for human consumption.

Compliance with the conditions of this code is a mandatory requirement for the registered use of the IFPDW
endorsement and ‘Mark’ on bottled water products.


  • Definitions


    1. Certified Source” when referring to a bottled water plant product or process water, means
      the source of water whether it be from a spring, artesian well, drilled well, public water system,
      or any other source that has been inspected by IFPDW and the water analysed, and found of
      a safe and sanitary quality with or without treatment.

    2. Bottled Water” means water that is intended for human consumption and that is sealed in bottles
      or other containers with no added ingredients except that it may optionally contain safe and suitable
      antimicrobial agents.


  • Bottled Water Plant” means any place or establishment in which bottled water is prepared [for sale].

  • Plant Operator” means who owns or operates a bottled water plant, and who meets the requirements
    of [State training certification/IFPDW certification?]

  • Drinking Water” means water that is intended for human consumption and that is sealed in bottles
    or other containers with no added ingredients except that it may optionally contain safe and suitable
    antimicrobial agents.

  • Approved Laboratory” means an analytical laboratory approved by [State authority and/or IFPDW]
    for the measurement of bottled water quality.


  1. Representative Sample” means a sample consisting of 10 sub-samples (consumer units = bottles), one
    taken from 10 different randomly chosen shipping cases to be representative of a given lot.

1.3    Water Quality

All bottled water shall be from a Certified Source and shall meet the standard of IFPDW Bottled Water Quality Standard.

1.4     Source Water Monitoring

Certification of the source water other than from a public water supply must be based upon a field inspection of the source
and a review of information prepared a competent and professionally qualified hydrogeologist that shall demonstrate the
integrity of the source a d safety of the catchment operations, and that shall include:

  1. [List of investigation and reporting requirements – see IBWA code]

1.5   Manufacturing and Operational Requirements

       1.5.1   Manufacturing Requirements

Bottled Water shall be prepared, packaged and held under sanitary conditions in compliance with
Good Manufacturing Practice (GMP). A fundamental requirement of bottled water GMP is that all
product water is obtained from a Certified Source.

The GMP applicable to bottled water plants shall include criteria relating to:

  1. plant and ground maintenance, including sanitary maintenance of buildings, fixtures and facilities
    including water supply, plumbing, sewage disposal, drainage etc;

  2. plant construction and design, including separation of the bottling room, protection of processing
    operations, adequate ventilation, and enclosure of washing and sanitising operations;

  3. sanitary facilities, including

    • certified sources of both product and operations water;

    • minimum annual analysis of source water for chemical contaminants;

    • analysis once every four years of source water for radiological contaminant;

    • once a week sampling and analysis of source water for microbiological contaminants; and

    • separation and maintenance of locker and lunch room areas;

    d.    sanitary operations, including

    • adequate sanitation of all product contact surfaces;

    • adequate drainage and protection from contamination of mult-service containers, utensils,
      disassembled piping and equipment;

    • protection of single service containers, caps and seals; and

    • sanitary filling, capping, closing, sealing, and packaging of containers;

    e.    equipment design and construction, including materials of construction;

    f.    production and process controls specific to the production and processing of bottled water, including


  • sampling and inspection of containers and closures;

  • product sample analysis as follows:


  • bacteriological analysis once a [day] of each type of water produced
    during a day’s production;


  • chemical, physical and radiological analysis at least annually of a representative
    sample from a batch or segment of a continuous production run for each type
    of water produced during a day’s production;


    g.    record keeping

    • maintenance and retention of records of product sample analysis;

    • maintenance and retention of source certification

    • maintenance and retention of other GMP records

    • availability of required records for official review

1.5.2    Operational Requirements

Water Treatment Process

The purpose of the water treatment process shall be to reduce the level of any constituent in the
source water below the IFPDW Bottled Water Quality Standard, or to prevent a contaminant
entering the product water in amounts that exceeded the Bottled Water Quality Standard.

Bottled water which originates from a source which is not protected from surface contamination
shall be subjected to ozonation, filtration rated at one micron or other effective process which
removes or destroys the cysts of the parasite Giardia lamblia and Cryptosporidium.

Microbiological Control Standards

Bottled water shall be subject to effective germicial treatment by ozonation or carbonation at a minimum
of three volumes of carbon dioxide or other equivalent disinfection approved by the International Foundation
for the Protection of Drinking Water.

[Waivers for filtration and germicidal treatment – based on documented proof of supply security and
bottled water plant practice in compliance with other International and State requirements]

Dedicated Equipment

Bottled wager shall not be transported or stored in bulk tanks, or processed or bottled through equipment
or lines used for any ono-food product.

[Detailed requirements of transportation, handling and testing of bulk water]

Multi-Food Equipment

To minimise the potential for microbiological contamination of the finished product, non-carbonated water
shall not be transported, stored, processed, or bottled in or through lines or equipment through which has
passed milk, fruit juice, or other food products likely tot contribute nutrients for microbial growth,
unless said lines, equipment, or holding tanks have been cleaned in accordance with the conditions following;

[Detailed conditions for cleaning tanks, lines and fillers prior to processing bottled water]

Corrective Actions

The bottled water plant operator shall develop and maintain procedures for the notification of
[State Regulatory Body], notification of IFPDW Water Quality Standard has been exceeded
or have reason to believe circumstances exist that may adversely affect the safety of the bottled
water, including but not limited to source contamination, spills, accidents, natural disasters, or
breakdowns in treatment.

In order to facilitate product identification or recall, each bottled water product shall have a
code affixed which contains either the date of manufacture, or a lot or batch number.

[Inclusion of authority of State Regulator to order public notification and recall of product]

Water Plant Operator Competency

A bottled water plant shall not be operated except under the supervision of a competent person
qualified by experience, education and training to operate and maintain the plant’s facilities.

[Educational and training requirements can be detailed here. Requirement for IFPDW registration?]

1.6    Product Water Monitoring

To verify that the bottled water product is in compliance with the IFPDW Water Quality Standard, representative
samples the product shall be monitored as follows:


  • Microbiological


Take and analyse a representative sample from a batch or segment of a continuous run for each type
of bottled water produced by the plant for Total coliforms [E.coli, faecal coliforms]. Sampling and analysis
shall be performed in-plant [daily] by qualified plant personnel and analysis shall be performed at least
once per week by an approved laboratory.


  • Chemical, physical and radiological


Take and analyse a representative sample from a batch or segment of a continuous run for each type of bottled
water produced by the plant at least once per year for the chemical, physical and radiological parameters in
the IFPDW Water Quality Standards.

The analyses shall be carried out by such methods approved by [State authority or IFPDW], or by internationally
recognised methods for drinking water analysis.

All records of product water analyses shall be maintained at the plant for a period of not less than [2] years,
and shall be available for inspection.

1.7    Labelling

Bottled water shall be labelled in a manner so as to establish a a Standard of Identity and a Standard of Quality of the product.

Product Identity

The name of the product is “Bottled Water” and shall be labelled accordingly or alternatively with one or more
of the following terms as appropriate:

  1. Artesian Water” means bottled water from a well tapping a confined aquifer in which the water level
    stands some height above the top of the aquifer.

  2. Ground Water” means bottled water from a sub-surface saturated zone that is under pressure
    greater than or equal to atmospheric pressure.

  3. Mineral Water” means water containing not less than 250 parts per million (ppm) total dissolved solids (TDS),
    origination from a geologically and physically protected ground water source. Mineral water shall be distinguished
    from other types of water by its constant level and relative proportions of minerals and trace elements at the point
    of emergence from the source, due account being taken of the cycles of natural fluctuations.
    No minerals may be added to this water.

  4. Spring Water” means water derived from an under ground formation from which water flows naturally to
    the surface of the earth. There shall be a natural force causing the water to flow to the surface through a natural orifice.
    Spring water shall only be collected at the spring or through a borehole tapping the under ground
    formation feeding the spring. The location of the spring shall be identified on the label.

  5. When bottled water comes from a community or municipal water source the label shall state
    from a community water system” or alternatively “from a municipal source“.

Product Quality

Where the product quality meets the IFPDW Water Quality Standard, the label may optionally show a typical analysis
of the water quality for the purposes of consumer information. The parameters chosen may be at the choice of the plant operator.

When the microbiological, physical or chemical quality of the bottled water is below that prescribed in the IFPDW
Water Quality Standard the label shall show the statement of substandard quality in the general form as follows:

“Contains Excessive _______________________________ ” with the blank filled with the parameter or name of the
chemical for which fails to meet the IFPDW Water Quality Standard.