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Do I mention water or drinking water on soft drinks label?


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#1 Mária

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Posted 06 December 2018 - 09:49 AM

Please advise,

it is permissible/ possible  to label water in a compound product ( for  example   soft  drinks  , or other similar products) in accordance with Regulation n. 1169/2011

by the term only   "water"?

Or should  : "drinking water" :  be mentioned?

 

 Thank you 



#2 pHruit

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Posted 06 December 2018 - 11:34 AM

Hi Maria,
"Water" is fine - as you're selling a foodstuff it's considered implicit that this is potable/drinking water!



#3 Mária

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Posted 06 December 2018 - 11:55 AM

Hi Maria,
"Water" is fine - as you're selling a foodstuff it's considered implicit that this is potable/drinking water!

For the explanation: the problem is:  we sometimes use drinking  water and sometimes spring water - for the same  soft  drink product. 
But we do not want to have two different labels, so we just want to use the term "water" ...


#4 pHruit

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Posted 06 December 2018 - 12:39 PM

Part of the challenge will be that this is set up as Directive at European level, so is then implemented independently by member states through their own local regulations.

I certainly think it would be acceptable in the UK, as whilst there are specific criteria for both "Natural Mineral Water" and "Spring Water", for "Water" it would generally be acceptable to use several sources, subject to the usual requirement to not mislead the consumer. Nonetheless it's an unusual question as normally it is the other way around - most brands want to actively promote/advertise that they're using spring water!

I'm not sufficiently familiar with Slovakian legislation to be able to confidently advise on that specifically though, so you may need to check with your local regulatory body (or the regulator in the countries of sale, if different).



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#5 Mária

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Posted 06 December 2018 - 01:11 PM

Part of the challenge will be that this is set up as Directive at European level, so is then implemented independently by member states through their own local regulations.

I certainly think it would be acceptable in the UK, as whilst there are specific criteria for both "Natural Mineral Water" and "Spring Water", for "Water" it would generally be acceptable to use several sources, subject to the usual requirement to not mislead the consumer. Nonetheless it's an unusual question as normally it is the other way around - most brands want to actively promote/advertise that they're using spring water!

I'm not sufficiently familiar with Slovakian legislation to be able to confidently advise on that specifically though, so you may need to check with your local regulatory body (or the regulator in the countries of sale, if different).

Thank you






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