Bottled water is covered by two Codex standards: CXS 108-1981 for natural mineral waters and CXS 227-2001 for all other bottled or packaged drinking waters. In the GCC the matching Gulf Technical Regulations are GSO 987:2021 for bottled natural mineral water and GSO 1025:2014 for bottled drinking water.
This guide is for owners, plant managers and QA staff of still, sparkling and carbonated water plants, and for the inspectors who license them.
Which standard applies to your water?
The first question is what the water is. Natural mineral water is a defined product. Under CXS 108 it comes from an underground source, has a characteristic and stable mineral content and is packaged close to the source. It should also be recognised as natural mineral water by the authority of the country where it emerges.
Everything else falls under CXS 227, the General Standard for Bottled/Packaged Drinking Waters (Other than Natural Mineral Waters). It splits these into two groups. Waters defined by origin come from a specific underground or surface resource without passing through a public supply. Prepared waters can come from any supply, including the mains, and may be treated in any way that leaves them safe.
Neither group may contain sugars, sweeteners or flavourings. Once those are added, the product is a soft drink and falls outside both standards.
How do the rules differ between mineral water and packaged water?
The table compares the two routes on the points an inspector checks first. It is based on the Codex texts as published by FAO and the GSO store records, read in October 2026.
| Point | Natural mineral water | Other bottled or packaged water |
|---|---|---|
| Codex standard | CXS 108-1981, revised 1997 and 2008, amended 2001 and 2011 | CXS 227-2001 |
| Codex hygiene code | CXC 33-1985 (revised 2011) | CXC 48-2001 |
| Gulf Technical Regulation | GSO 987:2021, edition 4 | GSO 1025:2014, edition 3 |
| Source | Underground, protected, recognised by the national authority | Any source for prepared waters. A specific protected resource for waters defined by origin |
| Treatment allowed | Only removal of unstable constituents such as iron, manganese, sulphur or arsenic by decantation or filtration, plus changes to carbon dioxide | Limited for waters defined by origin. Any treatment for prepared waters, provided the result is safe |
| Chemical limits | A list in CXS 108 itself, for example arsenic 0.01 mg/l and nitrate 50 mg/l | The health-related values in the latest WHO Guidelines for Drinking-water Quality |
| Transport before bottling | Transport in bulk containers before packaging is prohibited | Not restricted by the standard |
What does CXC 48-2001 expect of a packaged water plant?
CXC 48, the Code of Hygienic Practice for Bottled/Packaged Drinking Waters, applies the Codex General Principles of Food Hygiene to water. It asks for a hazard analysis on HACCP principles covering microbiological, chemical and radiological hazards. Protected underground sources usually need less treatment than surface water or unprotected wells.
Where treatment is needed, the code describes multiple barriers. Chlorination, ozonation, ultraviolet light and filtration can be combined against pathogens. Filtration, activated carbon and reverse osmosis deal with chemicals. The code points out that one does not replace the other.
Treatment must not create harmful by-products. The code names bromate, which ozonation can form, and residues of treatment chemicals. Filling and capping should happen in an enclosed area separated from the rest of the plant, with dust, airborne microorganisms and condensation monitored.
What changes for a mineral water, a purified water and a carbonated water line?
A natural mineral water plant has little room to treat its way out of a problem. CXS 108 allows very little treatment, so control sits at the source: a protected catchment, sound well construction and monitoring. If the water is found polluted during production, the standard requires the producer to stop until the cause is removed.
CXC 33 sets the microbiological checks for mineral water at the source, during production and on the end product. The criteria are that E. coli, coliforms, enterococci and Pseudomonas aeruginosa are not detected in 250 ml, and sulphite-reducing spore-formers not in 50 ml. A plate count limit of 100 cfu/ml applies only up to 12 hours after packaging.
A purified water plant drawing from the mains is the opposite case. Treatment is the control, so the records that matter are treatment validation, filter and membrane changes, disinfectant dosing and bromate results where ozone is used. Under CXS 227 an untreated mains water must say "From a public or private distribution system" on the label.
A carbonated water line adds carbon dioxide as an ingredient. Under CXS 227 the label reads "carbonated" or "sparkling" when the gas is not wholly from the water's own source. Where returnable bottles are used, CXC 48 asks for each one to be inspected, washed and disinfected, and closures are never reused.
What may a bottled water label say?
Both Codex standards apply on top of the general labelling standard for prepackaged foods. Natural mineral water must be named "natural mineral water", with designations such as naturally carbonated or decarbonated used only as defined in CXS 108.
CXS 227 prohibits medicinal claims, and other health claims must be true and not misleading. A place name can only appear in the trade name of a water defined by origin collected at that place. Your national regulator may set further rules, so check the GSO regulation as adopted in your market.
Where do the WHO guidelines fit?
CXS 227 does not set its own chemical limits. It requires packaged water to meet the health-related values in the most recent WHO Guidelines for Drinking-water Quality. On the WHO drinking-water quality page, that is the fourth edition incorporating the first, second and third addenda, published on 17 June 2026.
Check which version your regulator's limits are based on, because national tables often lag behind WHO updates. For water supplied by tanker or stored in building tanks before it reaches a plant, see our guide to drinking water supply standards. Ice made from the same water has its own ice plant safety guide.
How AGS can help
AGS publishes three single-document guidelines for water and beverage plants. Each is one editable Word document.
- Technical & Hygiene Guidelines - Drinking Water Packing Factories: 1 document.
- Technical & Hygiene Guidelines - Carbonated Water Factories: 1 document.
- Hygiene & Sanitation Guidelines - Bottled Beverage Industry: 1 document.
Frequently asked questions
Can tap water be sold as bottled water?
Yes, as a prepared water under CXS 227, if it meets the safety requirements. If it is bottled without treatment that changes its composition, the label must say it comes from a distribution system.
Can natural mineral water be treated like other bottled water?
No. CXS 108 allows a narrow set of treatments, such as separating iron or manganese compounds by decantation or filtration, without changing the essential mineral content. Safety comes mainly from protecting the source and the plant.
Do GCC countries follow Codex or GSO for bottled water?
GSO publishes GSO 1025:2014 and GSO 987:2021 as Gulf Technical Regulations, and Codex texts are the international reference behind them. Each member state's regulator decides how they apply, so confirm the version it enforces.
Does a hygiene guideline replace a HACCP plan?
No. A guideline sets out good practice. Your HACCP plan applies it to your own source, treatment and line, and is what an inspector or certification body assesses.
AGS provides independent documentation toolkits. This guide and the referenced documents are not affiliated with, endorsed by or approved by the Codex Alimentarius Commission, FAO, WHO, the GCC Standardization Organization or any national regulator.
Reviewed October 2026. Facts checked against the sources current at publication.
