Community Practitioners' and Health Visitors' Association

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CPHVA Response to the Draft Natural Mineral Water, Spring Water and Bottled Water (Amendment) (England) Regulations 2001  


The Community Practitionersí and Health Visitorsí Association (CPHVA) welcomes the opportunity to comment on the draft Natural Mineral Water, Spring Water and Bottled Drinking Water (Amendment) (England) Regulations 2001 and understands that the document relates to England only. With regards to the proposed restrictions:-

(a) The proposed compositional and labelling requirements for bottled water labelled as being suitable for the preparation of infant food.

We support the labelling requirements specifying preparation requirements for the named product, warning of health hazards of incorrect preparation; the inclusion of a statement reinforcing the superiority of breast milk compared to infant and follow-on formula. In addition, that natural mineral water will comply with the provisions of the relevant Directive 80/778 before 25 December 2003, Directive 98/83 after that time

b) The proposed restrictions on advertising and promotion of suitability for infant feeding

The CPHVA feels quite strongly that the restrictions should apply to any pictures of infants or text idealising its use when preparing infant feeds. In addition, promotion by retailers to promote or induce the sale of any infant formula should never be permitted. (c) The proposed limits for sulphate, manganese, tritium and total indicative dose in Table A (as amended by the draft Regulations) The CPHVA supports the limits for sulphate, manganese, tritium and total indicative dose that will bring them in line with tap water. The effects of tighter legislation for bottled water whether natural mineral, spring and bottled water will, once successfully enforced, reduce inconsistency in practice and use for infant feeding. The restrictions with regard to advertising will add weight to our concerns regarding the ethical activities of commercial infant formula companies.

Lead Professional Officer
13th June 2001