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Water holds an extraordinary position in South Africa.
It exists as both drinking water, a fundamental human right enshrined in the Constitution, and packaged water, a regulated food product subject to stringent safety laws.
This dual identity presents unique problems in a country straddling the demands and legislation of a first-world population seeking premium quality and a developing-world reality where millions simply need access to safe water.
The growing demand for alternative drinking water sources, compounded by a water deficit projected at 17% by 2030, is pushing the boundaries of regulation. As refill water stations become more prevalent, a clear divide is emerging between regulated packaged water and the largely unregulated water refilling industry.
The refill water industry could potentially offer more affordable relief as drinking water to households when the tap is dry or unsafe.
This industry has, however, ridden on the back of the packaged water industry for more than 20 years, offering re-filled water as a greener and more affordable alternative, without having to adhere to any of the requirements and legislation for packaged water. The implications for public health, food safety and consumer trust are profound.
Packaged water versus refilled water
Packaged water, regulated as a food product, undergoes meticulous safety and quality controls. Bottled water adhering to the South African National Bottled Water Association standards is sourced from protected and sustainable origins, processed in hygienic facilities and subject to batch testing and traceability. This ensures the safety and shelflife of the product.
In contrast, water from refill stations exists in a regulatory grey area. Often sourced from municipal taps, it might initially meet drinking water standards but lacks the protections required for long-term storage or microbiological safety. Moreover, most refillers are illegally pre-filling (filling, sealing and labelling) and selling water as a packaged product without adhering to the rigorous protocols of packaged water production.
Refilling a hidden health concern
Refilled-water stations, while providing a low-cost alternative, pose significant health risks due to contamination potential.
Equipment, such as the pipes, taps and lids used in the refilling process, is rarely sanitised to the standards required for food products. In retail environments, consumers handle the filling equipment, which could lead to the water being contaminated.
Without sterilisation, bacteria like Pseudomonas and E coli can thrive, particularly in environments where municipal chlorine is removed from the water.
Refilled water is designed for immediate consumption, yet many refill stations pre-fill and store water without the necessary microbiological protections.
This creates a dangerous scenario where consumers believe they are purchasing safe, packaged water but, in reality, they are exposed to a product with unknown shelflife, no traceability and significant contamination risks.
Consumers also have no idea which processes are used to purify the water and if indeed the water is of better quality than it was in the tap. The water is not tested per production batch and thus recall is impossible.
First-world expectation
South Africa’s dual socio-economic realities exacerbate the issue. Packaged water is first and foremost sold as a healthy beverage alternative, yet it is always available in times of emergencies to stand in as a supply of drinking water. Consumers often demand high-quality packaged water, seeing it as a premium, safe and convenient alternative to other beverages or even tap water.
Lower-income communities prioritise access to affordable drinking water and are vulnerable to being misled by seemingly safe alternatives.
This dynamic places immense pressure on water providers to balance safety, affordability and accessibility. For legitimate players in the packaged water industry, maintaining rigorous safety standards is non-negotiable. The unchecked growth of the refilling industry, however, risks eroding consumer confidence and undermining public health.
Murky area of pre-filled bottles
One of the most pressing concerns is the illegal pre-filling of water bottles by refill stations. According to food safety legislation, bottled water must be produced in controlled environments with proper hygiene, risk assessments and traceability. Retail settings where bottles are filled and stored fail to meet these requirements, exposing consumers to contamination risks and mislabelling.
The pre-filling of bottles by refillers undermines trust in the industry and creates an uneven playing field for legitimate packaged water producers. Tackling this issue requires robust enforcement of food safety laws, along with penalties for non-compliance.
To maintain consumer trust and uphold safety standards, the industry must continue to advocate for stronger regulations and consumer awareness.
By clearly distinguishing between packaged water as a food product and refilled water as a short-term alternative, the industry can safeguard public health while addressing the diverse needs of South Africans.
While refill stations might offer affordability, their unregulated practices pose significant risks. It is incumbent upon the packaged water industry, regulators and consumers to work together to ensure that every South African has access to safe, reliable drinking water — whether it comes in a sealed bottle or from a tap.
Charlotte Metcalf is the chief executive of the South African National Bottled Water Association and serves on the South African Bureau of Standards committee for non-alcoholic beverages. She is a professional member of the South African Association for Food Science and Technology and represents the bottled water industry on the Consumer Goods Council of South Africa forums as well as internationally with the Natural Mineral Waters Europe and the International Council for Bottled Waters.