Tuesday, 24 November 2020

Status of UK's Natural Mineral Waters in EU/EEA after 1 January 2021

Essentially, if exporting to EU/EEA states and Northern Ireland, an application for recognition of mineral water has to be made after 1 January 2021.

UK mineral waters would be regarded as 3rd country waters and have to be accepted by a member state. If one member state (EU and EEA) recognises the UK mineral water, all states will recognise the mineral water automatically. 

The UK mineral water must comply with the requirements of the 2009 Directive for mineral water (2009/54/EC).

Note that Northern Ireland is included solely because of the Northern Ireland Protocol. 

Applications have to be made in the language of the member state approached. Currently, Republic of Ireland and Malta cannot accept applications because of lack of administrative capability. Some countries will charge an administrative fee plus expenses (for example to visit the source).

 The requirements for TVC count at source are interpreted differently in the UK compared with the 2009 Directive. The Directive indicates maximum values of 20/ml and 5/ml at 22 deg C and 37deg C respectively, whereas the UK interpretation treats these figures as a guide only. If values are higher than these, some clarification will be required when making applications. 

Some countries (for example France) have suggested applying now to save time. Other counties will allow existing stocks in a country to be used up before applying the recognition requirements.