New
Community Directives for mineral water in tight containers
In
addition to tap water, human nutrion is based also on conditioned waters,
i.e. waters that meet specific requirements fo human use. Packed in
containers of different type. On purpose we avoided the term “drinking
water”, as it has a specific juridical meaning, whose definition changes
fom country to country. The marketing of suitably treated bottled waters,
or waters packed in containers is a common practice in coutries where, due
to hygienic conditions, one should refrain from drinking tap water or
water of insecure orign as for example spring water. We refer to waters
different from natural mineral water, though they are to be found anyplace
around the globe. These waters include, for example, spring waters,
various types of table water, in many countries even distilled water is
often marketed as drinkable water. What brought to this decision? And
which possibilities and opportunities exist for the marketing of this kind
of water in Italy? A short review on the quality of the various waters for
human use, for a better descripition
of the varieties deserves a short review. Real and legal quality of drinking waters in Italy
Directive EEC/80/778 established the parameters according to wich a water can be defined as drinking water all over the Euripean Community. This directive has been included in the Italian regulations by the D.P.R. 236/1988, wich sets the max. Allowed concentrations (CMA) of the purity parameters(1). Drinkable waters according to the a .m. CMA are considfered suitable for human consumption: in this case one speaks of legal quality. It should be mentioned that Community regulations on drinking water have been recently changed by the directive 98/83/CE (2). This directive will have to be included in the Italian regulations by the end of December 2000. As a result, many legal quality parameters must be – in some cases even notably – changed(3), and therefore also the potabily criterea will change. A more modern quality concept, better meeting the needs of modern drinkers, must take into account the fact that consumers are not only concerned with the hygienic-sanitary protection of water, they also want it to have satisfactory organoleptic properties. Moreover, the request concerning environmental protection, energy saving, lower environmental impact in order to cut the consumption of resources na energy for the production of water must be considered as well. From this point of view, the quality concept changes, we could define it here “real quality”as in addition to the hygienic properties, is takes into account a series of factors having a different incidence on the consmer’s choice. The concept may be expressed with the following ratio: Qtot = f (Qraz+Qemoz+Qserv+Qamb) Where total quality is defined as a function consisting of several parameters: - Rational aspects of the quality of the product (Qrax); - The emotion aspects (Qemoz); - The quality of services linked with the sale and the use of the product (Qserv); - The environmental incidence in terms of energy and resources for the production, distribution, use and diposal of the products and its sub-products(Qamb). From an accurate examination of water above said one may think that the product “natural mineral water” as for its characteristics (presentaion, gassing, etc)perfectly meets all customer’s expectancies. We’ll givea closer consideration to mineral water consumption in Europe and to the readiness of consumers to pay twice as much for a liter of natural mineral water if compared to tap water. Is it just a matter os “bubbles”? Legal
and real quality of natural mineral waters in Italy Natural mineral waters are grounds water and, unlike mains waters, and their origin can surface water chanels; they are characterized by specific - clinically recognized – physiological properties. Moreover they must have natural hygienic characteristics of “ original purity”. Original purity must be well preserved until the consumption, and the different content of salt and other elements characterizing its peculiar effects, are the discriminating parameters that make the difference between natural mineral waters and drinking waters. With reference to the definition of the “effects” according to the DM 12/11/1992 No. 542 – mainly consisting in increased diuresis, improved functioning of the gastroenteric apparatus, the mineral content – it can be stated that all mineral waters submitted to the necessary tets meet at least one of these requeriments(4) Even in this case, as already done for drinking waters, and which quality is sensed by the consumer. The legal quality, from the profile of the chemical composition, is defined by Art. 6 of the DM 12/11/1992 no. 542, mentioning the evaluation criteria of the specification of natural mineral waters. This article points out the substances that become pollunting or undesirable in case of values exceeding the established concentration. It is important to observe that the limit values of several parameters notably differ from the corresponding parameters set for drinking waters. Hence, it is legally possible and technically corretc to say that there might be a natural mineral water production of drinkable water wich, if supplied from the mains, may not be considered drinkable. Consumers assign to mineral water specific health values, as fot example that the regular drinking of mineral water may cure the lack of specific minerals while contributing to the attainment of a good physical form. From a close-up on the regulations concerning the use and the marketing of natural mineral waters (D.L. 25/1/1992 no 105 for the enforcement of the EEC regulation 80/77/EEC, the “natural” concept of a mineral water can be defined also according to Art. 7 of the same decree in matters of treatments allowed for a natural mineral water. This articles establishes the right of the producers to perform specific physical and chemical interventions on the water, however without changing the natural aspect of the product. In short, following interrventions are allowed: collection, canalization, mechanical elevation,storage in tanks or basins (all physical operations) and the separation of unstable elements (as irn and sulphur) by filtering eventually preceded by oxygenation. All this provided that no modification is made to the composition of these waters and therefore to the essential components that contribute to their peculiarity. In the end the total or partial elimination and incorporation of free carbon doixide by physical procedures is also possible. Art. 8 forbids any other treatment of mineral water, as for example:conditioning, addition of bactericide or bacteriostatic substances and any other intervention that may change the microbiology of the natural mineral water. As for other beverages, like wine(5) the concept of “natural” is given a legal rather then real meaning (6), Naturalness, in fact, means “no un-allowed treatment” rather than “untreated”. The directive 96/70/EC dated October 28,1996 amending directive 80/777/EEC of July 15, 1980 in maters of unification of the laws of the member Countries on the use and the marketing of mineral waters opens new perspectives, even to the allowed treatments (art. 4), and therefore to the meaning of naturalness. Art. 4 includes follwing treatments: a-Separation of unstable elements, as iron and sulphur compositesm, by filtering or decating, eventually preceded by oxygenation, provided that this teratments does not change the composition of specific water elements, which confer to the water its peculiar properties; b-Separation of the components of iron, manganese, sulphur and arsenic in some mineral waters by means of a treatment with ozone enriched water, provided that this treatment does not change the composition of specific water elements, wich confer to the water its peculiar properties, and that specific requeriments are met. These requeriments are: - The treatment must respect the measures set by the Permanet Commitee for foods appointed by the Commission with decision 85/271/ECC; - The trearment must be notified to the competent authorities and controlled by them. c.Separation of the undesired components not included in those mentioned at point (b); the same condition apply. It should be pointed out that, while the
oxygenation with air or oxygen doesn’t have any disinfecting action, the
one with ozone may have it, and it can even cause the formation of
undesired sub-disinfecting products(7). Conditioned
waters in the Italian and European regulations The mentioned Italian regulation on natural mineral watrs (DM 12/11/1992 no 542) at Art. 16 mentions the possibility waters” defining them in general as “drnking waters, no matter how they are marketed”, but it forbids the use of any phrases, names, marks or images, wich may mislead and generate confusion with natural mineral waters. This possibility of conditioning drinking water is confrimed by the fact that in theb DPR 236/88 a specific value (point 62 of Enclosure I) is established for the bacteriological specidfications of waters for human consumption packed in closes containers. Important representatives of the Ministry of health denied the possibility of selling packed drinking or spring waters due to the lack os a relevant detailed regulation. However, according to a survey performed by the competent Health Departmants (ASL), their distribution on the market is a really. They are the waters (Contained in polycarbonate return bowls of 18-L-capacity) distributed in bureaus, fuel stations, etc usually with the relevant refrigerating column.In Italy often these waters – with different names – are real mineral waters coverning another market noche. To support this possibilty there also is the recent Decree of Law May 1st. 1999, no 152 “Directives on the protection of waters from pollution, enforcement of the Directive 91/271/EEC concermning the treatment of urban waste waters and of the directive 91/676/ECC on water protection from pollution deriving from nitrates used in agriculture” , published in the Ordinary Apendix no 101 to the Official Gazette. Even though the title of the decree of Law refers to urban waste waters and to the problems of nitrate pollution, the decree itself includes norms concerning also: a) Surfece fresh watres used for the production of drinkable water; b) Fresh waters that must be protected and improved to be suitable for the life of fish; c) Waters for the life of mollusks. In this context, the new Decree of Law regulates the concessions for the use of the use of the water (which are all public) and, at article 24, it states: “The concessions for the use of natural mineral waters and of spring waters have been granted taking into account the provisions and marketing requeriments of drinkable waters and the provisions of the protecting plan “This confirms the possibility that, next to natural mineral waters, even spring waters may be marketed. Spring waters are provided for in directive 96/70 EC on natural mineral waters are provided for in directive 96/70 EC on natural mineral waters ar article1, as integration to the previous directive 80/777/EEC, Part.4 bis of Art.9: “The term spring water is reserved to the waters for human consumption, in their natural state and bottled at the spring, as long as: - they meet the use requeriments as specified in Annex II, Par. 2 and 3 applied in toto to spring waters; - they meet the labelling specification as of Art. 7, Par. 2, points b) and d) and Art.8; - they were not submitted to different treatments as those mentioned in Art. 4. Other treatments may be authorized by the procedure mentioned in Art. 12. Furthermore, spring waters must meet the provisions of directive 80/778/EEC of the Council, july 15, 1984, on the quality of the water for human consumption(8). “Therefore, they must have the same chemical specifications as drinkable waters, and the same original purity of natural mineral waters. In Italy the relevant regulations are on the run at ministry level. It seems that the same regulations valid for natural mineral waters will be implemented, expect for the parts on the health-favorable (clinical and pharmacological) properties. There are some perplexies on the fact that – unlike other member Countries, the Italian rule proof provides for strict regulations as those on natural mineral waters, even in matters as the spring, composition. On November 3, 1998 the European Union enforced the directive 98/83/EC of the Council on the quality of waters for human consumprion(9). The transposition of this directive into the Italian regulative system will lead to important modifications to the management of treatment plants and to the distribution of the legal quality. Art. 2 is particulary interesting from our point of view. It defines the waters for human consuption in terms of “treated or non-treated waters, for drinking, kitchen use for for the preparation of food or for other domestic use, apart from their origin(10), supplied via the mains, in tanks, basins, botles or containers”.These waters are not natural mineral waters, since the direcive explicitly does not aplly to them (art. 3) as they are provided for in directive 80/777/ECC and the last modification with the directive 96/70/EC. Nor are they medical waters according to the regulation 75/65/ECC, nor spring waters (reference in the directive 96/70/EC). Article 5 of the directive sets the parameters that must (art. 6) be complied with, “for waters packed in bottles or containers and directed for sale, at the bottling site”(11). Art 9 decides on the possible exceptions to the
application of the derogation; at point 8 it points out that “the
present article is not valid for waters for human Art. 10 establishes that the member Countries shall implement all necessary measures so that no substance or material in a higher than allowed concentration will be present that many be harmful to human health in the new plants fr the preparation and distribution of waters for human consumption or associated impurities or materials. This intricate definition refers to “plants” and therefore, next to the water treatment and transport, even the packaging plants must be included. Specific qaulity norms are contained in the Annex to the directive. Annex I sets the specific microbiological parameters for waters sold in bottles and containers. These parameters are more restrictive than those for tap water. Escherichia coli, Enterococchi and Psuedomonas Aeruginosa have a parametric value of 0/250 ml; the estimate of the colonies shall not exceed 100/ml at 22ºC and 20/ml at 37 ºC. For mains water the limits are 0/100 ml only for Escherichia coli and Enterococchi. As already know, the new directive sets a strick limit (10 micrograms/liter) for the concentration of lead; this limit shall be gradually reached in the course of 15 years. The same applies to the limits of the concentration of bromate ion (10 micrograms.liter) and trialometani (100 micrograms/liter). Table B2 of Annex II sets the minimum frequency of sampling and containers and directed for sale. This frequency is determined by the volume produced every day; the control frequency gradually increases whenever there is na increased production from lower volumes (10 m³ / day ) to higher ones (60 m³/day). Conclusions As for the other packed waters, let’s briefly mention that there are no tecnical problems for the installation and management of a water packaging line for human consumption in bottles or containers. The problem is a lega-regulatory problem on one side and na economical on the other side. There are no doubts on the fact that for human consumption the European union allows the distrbution of packed waters, which are different from natural mineral waters. How far a regulation is required to go must still be discussed. In our opinion nothing ele should be necessary except for the assessment of the real potability of the water and of eligibility of the bottling plant. The economical aspect, on the contrary, is quite different. Considering the curent “ battle” prices of the Italian mineral water market-largely deriving from packaging and transport – there is no significant cost differential. However, experts are not the real judges of convenience, this is the task of the market. Hence, the preliminary study of other European markets seems to be fundamental for any iniative in this direction. It has been already mentioned that the mineral waters bottled in France are divided in theree water types: - natural mineral waters (eaux minerale naturelle) - spring waters (eaux de source) - table waters (eaux de table) Most of the market is taken by natural mineral waters, followed by spring waters and a minor share by table water. On other markets(12), for example in Germany, table waters are quites widespread by adding suitable concentration of salts, and de-ionized and purified waters. On the Spanish market, next to the “agua minero medicinale”, corresponding to our natural mineral water and whose healthy properties are controlled by the Ministry of Health, there are the “agua potare”, apring waters originating from the underground but whose therapeutic properties have not been demonstrated. In countries with precarious hygienic conditions and lacking a distribution mains system, various types of waters are distributed, usually in plastic containers. To make them drinkable, these waters are treated with ozone, UV and even distillation. Plastic, bottle-shaped 0.5-lt.-containers in PVC or PET are the most popular. Smaller, plastic portion containers with na aluminium foil for closure are less widespread. For a certain period natural mineral water in aluminuim portion-cans covered a small market niche (airlenes); but basically this format had a promomotional scope. Natural mineral water in 1-lt.botles produced in laminated material did not meet customer’s satisfaction, probably due to the lack of “emotions”; however, they are used for the distribution of water in emergency cases. It should be reminded that, in Italy, natural mineral waters can’t be packed in containers of more than 2-lt-volume. In the end, in matters of mains water, it must be said that probably the operators should better control the organoleptic properties, since the compliance to legal quality parameters isn’t always in favour of the consumer. In matters of natural mineral waters, a better differentiation vs. Other water categories fo human consumption is hoped for, though it might cause na increase of the selling price.The other categories of packed waters should then be marketed at intermediate prices. Source: PACKING AND BOTTLING INTERNATIONAL MAGAZINE 01/2001
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