Päring

Dear Commission

Dear Colleagues,

I would like to seek your opinion on an issue relating to the labelling of natural mineral waters (NMW).

In accordance with Regulation No 1169/2011 on consumer information, the nutrition declaration does not apply to natural mineral waters, as provided for in Article 29(1)(b)

Directive 2009/54/EC on mineral waters, sets out in Article 7 the specific labelling rules for natural mineral waters, including the analytical composition of the waters.

At present, there is an operator in Portugal that intends to place a natural mineral water on the market with an analytical composition in accordance with the Directive and

a nutrition declaration to highlight the absence of fat, carbohydrates, protein, and energy in the NMW, claiming that as Regulation 1169/2011 does not apply, this is not prohibited and, provided they comply with the requirements, it is permitted.

Our understanding is that this is not possible; however, the operator has shown us labels for some NMWs that contain this information.

We would therefore like to know your opinion on:

1. Do you consider it acceptable for both analytical composition and nutritional declaration to coexist on the same label?

2. Are you aware of any water on the market that displays this information.