Thailand Updates the Regulation Regarding Natural Mineral Water

Compared with the current version issued in 2000, the revisions in the new regulation regarding natural mineral water mainly involve product classification, mineral contents, contaminant and microorganism levels, as well as labeling requirements.

On October 16, 2024, Thailand Food and Drug Administration (Thai FDA) published the Ministry of Public Health Notification No. 454 regarding Natural Mineral Water (hereinafter MOPH Notification No. 454) on its official website, specifying the classification, quality standard, microorganism levels, package and labeling requirements of natural mineral water. The new regulation will be effective starting from April 10, 2025, replacing the MOPH Notification No. 199 Re: Mineral Water issued in 2000. Products conforming to the 2000 version can continue to be sold within two years from the effective date of the new regulation.

Compared with the 2000 version, the amendments mainly involve the following aspects:

Product definition

The product definition of natural mineral water is amended. As per the new regulation, "Natural mineral water" means water obtained from natural water sources and containing important minerals that are beneficial to health and remain according to the properties of that water source. The product shall not undergo any process other than quality improvement processes (the text in red is newly included).

Product classification

Natural mineral water is now classified into fives types, which are 1) naturally carbonated natural mineral water; 2) decarbonated natural mineral water; 3) non-carbonated natural mineral water; 4) natural mineral water fortified with carbon dioxide from the source; 5) carbonated natural mineral water.

Treatment of product quality improvement

MOPH Notification No. 454 clarifies that quality improvement treatments for natural mineral water must be conducted at the specific source site. The only exception is when the water is transported from the source through a closed piping system that prevents contamination and preserves the essential composition of the natural mineral water.

Mineral contents

The requirements for mineral contents in natural mineral water are adjusted as below:

Mineral	MOPH No. 454 (2024)	MOPH No. 199 (2000)
Manganese	0.4 mg/L	2 mg/L
Total Arsenic	0.01 mg/L	0.05 mg/L
Barium	0.7 mg/L	1 mg/L
Selenium	0.01 mg/L	0.05 mg/L

Contaminant levels

The contaminant levels are revised, for example:

Contaminant	MOPH No. 454 (2024)	MOPH No. 199 (2000)
Nitrite	0.1 mg/L	0.02 mg/L
Bromate	10 ug/L	/

Microorganism levels

The new regulation imposes stricter microbiological standards for natural mineral water; no Coliform bacteria, Escherichia coli, Enterococci, or Pseudomonas aeruginosa shall be detected in 250 mL samples, and no spore-forming sulphite-reducing anaerobes are allowed in 50 mL samples. These prohibitions mark a change from the 2000 version, which only required the absence of Escherichia coli and other pathogenic microorganisms, and set a maximum level for Coliform bacteria.

Use of food additives

The use of food additive should follow MOPH Notification regarding Food Additives. As per the latest regulation (MOPH No. 444), only Carbon dioxide is permitted in the production of carbonated natural mineral water.

Labeling

Labeling requirements are revised in the new regulation. For example, the product should be additionally indicated with the type of natural mineral water and the source. The labeling and advertising prohibitions are also specified, for instance, the enterprises cannot use text suggesting that the natural mineral water can treat, relieve, cure or prevent disease.