Does Ambiguous Refill Water Pose Risks to South African Consumers?

South Africa’s growing demand for alternative drinking water sources has led to an increase in refill water stations. While these provide a seemingly affordable and accessible solution, they operate in a regulatory grey area, posing significant risks to public health, food safety and consumer trust. The South African National Bottled Water Association (SANBWA) warns that urgent intervention is required to ensure consumers are not misled by potentially unsafe drinking water.

Legislative Interpretation

Charlotte Metcalf, CEO of SANBWA, highlights the stark contrast between regulated packaged water and the largely uncontrolled refill water industry: “Packaged water is classified and legislated by the Department of Health as a food product, meaning it must adhere to legislation in the FC&D Act. SANBWA member bottlers further adhere to strict internationally benchmarked safety and quality controls. In contrast, refill stations and shops are not held to the same rigorous standards, leading to concerns over contamination and consumer safety.”

Refilled water is assumed to be classified as drinking water and must adhere to SANS 241 as does tap water. There are no legislated requirements for treatments allowed, however, and so the possibility exists for unsafe sources and insufficient physical and chemical treatments to be used. This category only allows for water to be filled on the spot in new bottles provided by the shop or in consumers’ own bottles. When shops prefill water into sealed bottles the category changes to packaged water and all food legislation must apply.

The Dangers of Refilled Water

Refill water is mostly sourced from municipal taps and may initially meet drinking water standards. It could also be sourced from unprotected boreholes in commercial areas or from water transported in tanks. The source water is rarely tested to ensure that the processing capabilities of purification equipment can indeed remove all chemical and microbiological contaminants. After the removal of chlorine the final product is unprotected from any contamination from pipes, tanks, filling nozzles, the environment and handling. Unlike packaged bottled water, it lacks the necessary protections for long-term storage or microbiological safety. There is no (or at best irregular) testing of the final product to verify consumer safety.

Equipment such as pipes, taps and lids used in the refilling process are in some cases rarely sanitised to the required food safety standards. Consumers often handle the filling equipment in retail environments, increasing the likelihood of contamination. Furthermore, the removal of municipal chlorine from the water creates an environment where bacteria such as Pseudomonas and E. coli – introduced by unsanitary conditions and human handling – can thrive.

While packaged water must by law consider safe product handling and storage and verify the shelf life refilled water does not take this into consideration. Storing bulk drinking water safely will depend on the hygiene in the facility, the bottle cleanliness and the processing efficiency as well as the way the water is handled when exposed, consumed and stored.

The Murky Grey Area of Pre-Filled Bottles

One of the most pressing concerns is the illegal pre-filling of water bottles at refill stations. According to Metcalf, many refillers are illegally pre-filling and selling water as a packaged water product without adhering to food safety regulations: “Consumers may believe they are purchasing safe, packaged water when, in reality, they are exposed to a product with no traceability, unknown shelf life and significant contamination risks.”

According to South African food safety legislation, bottled water must be produced in controlled environments with proper hygiene, risk assessments, verified shelf life and traceability. But many refill stations pre-fill and store water without these essential protections: “This practice undermines trust in the industry, misleads consumers and creates an unfair competitive environment for legitimate packaged water producers.”

This grey area is exacerbated by unscrupulous companies selling plug-and-play water bottling systems and franchises to uninformed customers who believe that they are starting a refilling AND water bottling business.

Metcalf stresses that addressing this issue requires strict enforcement of food safety laws and penalties for non-compliance: “Without proper regulation, consumer confidence in the safety of their drinking water will continue to erode.”

Ensuring Safe Drinking Water for All

“We must ensure that every South African has access to safe, reliable drinking water, whether it comes in a sealed bottle or from a tap, but riding on the back of the packaged water industry and misleading the public is not the answer.” Metcalf says.

SANBWA calls for urgent collaboration between regulators, industry stakeholders and consumers to distinguish clearly between packaged water, which adheres to stringent safety protocols, and refill water, which remains largely unregulated: “While affordability is important, it cannot come at the expense of public health and consumer safety.”

The water refill industry needs minimum standards and must refrain from producing packaged water in unsuitable shop environments.

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Author: Petra Peacock from Chimeracomms on behalf of SANBWA.

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