Q&A on the National Food Safety Standard for Packaged Drinking Water GB19298-2014

[Abstract] This standard applies to packaged drinking water intended for direct consumption, i.e., water sealed in packaging containers that comply with food safety standards and relevant regulations, and suitable for direct drinking. It does not apply to natural mineral water.

I. Development Background

According to the former Ministry of Health's "Notice on Issuing the 2010 Work Plan for the Cleanup and Rectification of National Food Safety Standards" (Health Office Supervision Document [2010] No. 106), the Zhejiang Provincial Health Supervision Institute, the China Beverage Industry Association, the National Drinking Water Product Quality Supervision and Inspection Center, and the Zhoushan Municipal Health Supervision Institute undertook the drafting work of the "National Food Safety Standard for Packaged Drinking Water". The drafting group analyzed relevant domestic and international standards and safety indicators for packaged drinking water. Based on the "Hygienic Standard for Bottled (Barrelled) Drinking Water" (GB 19298-2003) and the "Hygienic Standard for Bottled (Barrelled) Purified Drinking Water" (GB 17324-2003), it integrated and revised to form the "National Food Safety Standard for Packaged Drinking Water" (GB 19298-2014). This standard was approved and issued by the National Health and Family Planning Commission on December 24, 2014, and came into effect on May 24, 2015. The labeling requirements for packaged drinking water (4.1 and 4.2) in the standard came into effect on January 1, 2016.

II. Scope of Application

This standard applies to packaged drinking water intended for direct consumption, i.e., water sealed in containers that comply with food safety standards and relevant regulations, and which is suitable for direct drinking. It does not apply to natural mineral water. Natural mineral water will be addressed in a separate revision of the "National Food Safety Standard for Drinking Natural Mineral Water" (GB 8537).

III. Raw Material Requirements

The raw materials for packaged drinking water come from two main sources: public water supply systems and non-public water supply systems. Non-public water supply systems can be further divided into surface water and groundwater.

Water sources from public water supply systems should meet the requirements of the "Standards for Drinking Water Quality" (GB 5749).

Water sources from non-public water supply systems should meet the hygiene requirements for drinking water sources in GB 5749, specifically: when using surface water, it should meet the requirements of the "Surface Water Environmental Quality Standard" (GB 3838); when using groundwater, it should meet the requirements of the "Groundwater Quality Standard" (GB/T 14848). After treatment, the water quality of these non-public water supply systems should meet the requirements of GB 5749 before entering the subsequent processing stages of packaged drinking water production. Since the pH value of water from non-public water supply systems generally does not change after treatment, the pH value of water used in food processing can be determined by referring to the pH values of the "Surface Water Environmental Quality Standard" (GB 3838) or the "Groundwater Quality Standard" (GB/T 14848).

IV. Labeling Regulations Regarding "Added Food Additives for Flavor Adjustment"

According to the *National Food Safety Standard - Standard for the Use of Food Additives* (GB2760-2014), when food additives such as magnesium sulfate, zinc sulfate, calcium chloride, and potassium chloride are added for flavor adjustment, the phrase "Added food additives for flavor adjustment" or similar wording must be displayed near the product name. For products using only processing aids (such as nitrogen), according to the *National Food Safety Standard - General Rules for Labeling of Prepackaged Foods* (GB7718-2011), the processing aids do not need to be labeled, nor is the phrase "Added food additives for flavor adjustment" required.

V. Naming of Packaged Drinking Water

The name of packaged drinking water must be truthful and scientific, and must not be named after one or more components other than water. The labeling of packaged drinking water should comply with the *National Food Safety Standard - General Rules for Packaging of Prepackaged Foods* (GB 7718), and should be clear, conspicuous, and durable, making it easy for consumers to identify and read when purchasing. Product names for packaged drinking water must not include terms such as "activated water," "small molecule cluster water," "functional water," "energy water," or other unscientific content.

VI. Regarding Microbiological Indicators

This standard retains the coliform bacteria indicator and adds a Pseudomonas aeruginosa indicator. It no longer retains indicators for total bacterial count, mold and yeast count, Staphylococcus aureus, Salmonella, and Shigella.

Total bacterial count, mold, and yeast are hygiene indicator bacteria and generally do not affect public health. However, excessive control of hygiene indicator bacteria and sterilization may lead to increased bromate levels in drinking water, posing a health risk. Currently, relevant standards and regulations of the Codex Alimentarius Commission (CAC), the International Committee for Microbiological Standards of Foods (ICMSF), the International Bottled Water Association (IBWA), the United States, Australia, and the European Union do not establish hygiene indicator bacteria indicators for packaged drinking water. Our commission is currently drafting the "National Food Safety Standard - Hygienic Specification for the Production of Packaged Drinking Water," which will strengthen the monitoring and management of hygiene indicator bacteria through process control during production and processing. Therefore, this standard no longer retains the aforementioned indicators.

Based on drinking water testing results and relevant Chinese standards such as CAC, ICMSF, and others, this standard retains the coliform bacteria indicator and adds an indicator for opportunistic pathogens—Pseudomonas aeruginosa (also known as Pseudomonas aeruginosa). Since there are no internationally recognized indicators for Staphylococcus aureus, Salmonella, and Shigella in drinking water, and there is insufficient scientific evidence for these indicators, they are no longer included in this standard.

VII. Implementation of Labelling Requirements

The labelling requirements (4.1 and 4.2) for packaged drinking water in this standard will be implemented from January 1, 2016. The labelling of packaged drinking water produced after January 1, 2016, must comply with the requirements of the National Food Safety Standard for Packaged Drinking Water (GB19298-2014). Packaged drinking water produced before this date can continue to be sold until its expiration date.

VIII. Labelling of Bottled Water Refill Containers

From January 1, 2016, the labels of bottled water refill containers must comply with the provisions of this standard. For turnover drums that have product names that do not comply with the provisions of this standard directly injection molded or painted on the drum body, the name shall be corrected (such as by using a label on the drum opening) and the drum shall be allowed to be used until December 31, 2016, and sold within the product shelf life.