FDA Requirements for Private Label Bottled Water

Last Updated: March 18, 2026

FDA Bottled Water Regulations: What You Need to Know

The FDA regulates bottled water as a food product under 21 CFR Part 165. Any company that bottles and sells water in the United States must operate from an FDA-registered facility and comply with Current Good Manufacturing Practices (CGMPs). This applies to all custom bottled water and private label water suppliers.

Key facts: You do not need FDA certification to order custom bottled water. The bottling company holds the certifications. Your responsibility is to verify that your supplier operates from an FDA-certified facility. CustomWater.com and MyLabelWater.com hold both FDA and SQF certifications across all their facilities.

What the FDA Requires for Bottled Water

Facility Registration

Every bottled water facility must be registered with the FDA. The facility receives an FDA registration number that can be verified. Ask any supplier for their registration number before ordering.

Current Good Manufacturing Practices (CGMPs)

FDA CGMPs for bottled water (21 CFR Part 129) cover:

  • Plant construction and design
  • Equipment maintenance and sanitation
  • Production and process controls
  • Quality control testing
  • Record keeping and documentation

Water Source and Treatment Standards

The FDA sets standards for bottled water quality that are at least as strict as EPA tap water standards. Bottled water must meet limits for:

  • Microbiological contaminants (E. coli, coliform bacteria)
  • Chemical contaminants (lead, arsenic, mercury, pesticides)
  • Radiological contaminants
  • Physical contaminants (turbidity)

Labeling Requirements

FDA labeling rules for bottled water require:

  • Product name (“Purified Water,” “Spring Water,” etc.)
  • Net quantity (fluid ounces or milliliters)
  • Name and address of the bottler, packer, or distributor
  • Nutrition facts panel
  • Water type classification (purified, spring, mineral, etc.)

When you order custom bottled water, the supplier handles all FDA-required label elements. Your custom design (logo, brand colors, text) goes on the front. The FDA-required information goes on the back or side panel.

Beyond FDA: SQF Certification

SQF (Safe Quality Food) is a third-party food safety certification recognized by the Global Food Safety Initiative (GFSI). It goes beyond FDA minimums by requiring:

  • Documented food safety management system
  • Hazard analysis and critical control points (HACCP)
  • Regular third-party audits
  • Supplier verification programs
  • Traceability and recall procedures

SQF certification is not legally required, but it demonstrates a higher standard of quality control. CustomWater.com and MyLabelWater.com hold SQF certification across all their facilities.

State Bottling Licenses

In addition to federal FDA requirements, most states require bottled water facilities to hold state-specific bottling licenses. These are issued by state health departments and require periodic inspections. Your supplier handles this — you do not need a state license to order custom water.

What You Need to Verify Before Ordering

Before placing an order with any custom bottled water supplier, verify:

  1. FDA registration: Ask for the facility’s FDA registration number. Legitimate suppliers display this on their website or provide it on request.
  2. SQF or equivalent certification: Not required but indicates higher quality standards.
  3. State licenses: The facility should hold valid bottling licenses in the state(s) where it operates.
  4. Water testing records: Reputable suppliers conduct regular water quality testing and can provide results on request.

Red Flags

  • No mention of FDA certification on the website
  • Unable or unwilling to provide registration numbers
  • No physical facility address listed
  • No mention of water testing or quality control
  • Prices that seem too low (may indicate non-compliant operations)

Frequently Asked Questions

Do I need FDA approval to sell custom bottled water?

You do not need FDA approval to order custom bottled water for your business. The bottling company holds all required certifications. If you plan to resell bottled water at retail, the product must come from an FDA-certified facility (which it will if you use a reputable supplier).

Is custom bottled water safe to drink?

Yes, when produced by an FDA-certified facility. The FDA regulates bottled water quality to standards at least as strict as EPA tap water standards. Suppliers like CustomWater.com and MyLabelWater.com hold both FDA and SQF certifications.

What is the difference between purified water and spring water?

Purified water has been treated through distillation, deionization, or reverse osmosis to remove impurities. Spring water comes from an underground source and flows naturally to the surface. Both are FDA-regulated. Most custom bottled water suppliers use purified water.

How long does bottled water last?

The FDA does not require an expiration date on bottled water. Most suppliers print a “best by” date of 2 years from production. Bottled water stored properly (cool, dark, away from chemicals) remains safe indefinitely, though taste may change over time.

Can I put anything I want on the label?

Your custom design (logo, brand colors, text) can be anything you want. However, the bottle must also include FDA-required information: product name, net quantity, bottler information, and nutrition facts. Your supplier handles the required elements — you design the branded portion.

Ready to order from a certified supplier? Design your label free at CustomWater.com (FDA and SQF certified) or call (877) 891-4274. See our supplier comparison for certification details on all suppliers.