Bottled Water/Water Dispensing Machine Registration Details, FAQ and Step-by-Step Guide

Overview

Bottled water available at retail in Michigan may be from in-state or out-of-state sources. Its origin can be from community or non-community water supplies, groundwater or surface water. The bottle label states the origin of the water or who to contact for additional information about the source.

The source of the bottled water must comply with the Michigan Safe Drinking Water Act, the water source, bottling facility, and the treatment and bottling practices must comply with state and federal regulations for basic sanitation, design and construction, including 21 CFR part 129. The Michigan Department of Environment, Great Lakes, and Energy (EGLE) does the initial source water approval. The bottled water processing firms are licensed by the Michigan Department of Agriculture and Rural Development.

Frequently Asked Questions

If my company is not located in Michigan, do I still need to register?

Yes, even companies from outside the U.S. must register to sell bottled water products in Michigan.

What do I register?

The brands and types of water that you will be selling in Michigan. See the Bottled Water Step-by-Step Guide below for guidance on how to register your water.

If my company is located in Michigan, do I need to do anything besides register?

Yes, you must also obtain a food establishment license from the Michigan Department of Agriculture and Rural Development and receive a source approval letter from the Michigan Department of Environment, Great Lakes, and Energy.

What is an approved source?

Your water must come from a protected and approved source. Whether the source is a spring, artesian well or a municipal water system, you must have a source approval letter. Instate source approval letters can be obtained from the Michigan Department of Environment, Great Lakes, and Energy. Out-of-state establishments distributing in Michigan must also have source approval and provide documentation to MDARD. All sources must be equivalent and approved by the regulatory agency with jurisdiction (includes foreign entities, federal, state or local water regulatory agencies). See the Bottled Water Step-by-Step Guide for directions.

Do all firms registering to sell bottled water in Michigan require a source approval letter?

Yes. See the Bottled Water Step-by-Step Guide for directions.

What types of beverages must be registered?

Only bottle water that meets the standard of identity found in 21 CFR part 165. Products that contain fruit juice, sugars, artificial sweeteners, corn syrups, etc., are considered drinks and do not require registration.

What about machines that process water in a grocery store? Do they need to be registered?

Yes. All machines that process water, wherever they are located, must be registered. Review the Bottled Water Step-by-Step Guide below for directions and guidance on how to register your water dispensing machine.

If I have more than one machine at a single location, how many registrations do I need?

You need one registration for each machine.

What are the roles of the different agencies involved in bottled water regulations in Michigan (MDARD, EGLE, FDA, etc.)?

The Michigan Department of Agriculture and Rural Development (MDARD) and the U.S. Food and Drug Administration (FDA) both have jurisdiction over bottled water manufacturers in Michigan. The Michigan Department of Environment, Great Lakes, and Energy (EGLE) is responsible for the source water approvals of in-state firms. Regulatory agencies from other states and the FDA are responsible for inspecting out-of-state firms that produce bottled water. The FDA regulates imported bottled water (from other countries).

Does MDARD test bottled water? If so, how often?

MDARD does not test bottled water on a routine basis. Testing is conducted if bottled water is implicated in a foodborne illness investigation. Firms that produce bottled water are required to test the water.

Bottled Water Registration Step-by-Step Guide

This guide has been established to help guide potential manufacturers/distributors of bottled water through the process of developing and registering bottled water and water-dispensing machines.

The guide details the steps necessary to develop a water source with the intent of bottling for drinking purposes. Also included is information on registering bottled water dispensing machines.

Step 1: For in-state Bottled Water Manufacturers, contact the Michigan Department of Environment, Great Lakes, and Energy (EGLE), at 517-388-9818, for water source approval.

Drinking Water & Environmental Health Division For in-state Bottled Water Manufacturers, EGLE will provide onsite inspection, if necessary, as well as evaluation of the water in question. EGLE will then approve or reject the source.

**All in-state water sources must be approved by EGLE prior to sale, or offering for sale, bottled water, whether the source is municipal, spring or well.

***Out-of-state bottled water manufacturers, please see the Out-of-state Bottled Water Source Documentation.

Step 2: Manufacturers within Michigan are required to obtain a Michigan Department of Agriculture and Rural Development Food Establishment License. Because bottling water is considered food processing, applicable laws and regulations must be followed. As one of your first steps, review the Food Establishment Licensing Step-by-Step Guide, or contact MDARD at 800-292-3939 for more information on food establishment licensing.

Step 3: Familiarize yourself with Michigan laws and regulations governing the production, sale and distribution of bottled water in the state of Michigan:

Step 4: Register the bottled water product and/or water-dispensing machine with the Michigan Department of Agriculture and Rural Development, Food and Dairy Division.

  • Bottled Water Manufacturers

The bottled water manufacturer is required to register each brand and type of water that will be sold in Michigan. A brand of water for example is "Jack's Spring Water." Another brand would be: "Jane's Spring Water." Types of water for example would be: "Joe's Spring Water," and another type could be: "Joe's Drinking Water." If a firm manufactured all four of those items, they would be required to register 4 products, at $25.00 each for a total of $100. (Please note that the size of the container does not matter.) An example label or a proposed label needs to be included with your registration application. Additional instructions are attached to the Bottled Water Registration Application (FI-152) form.

If your firm manufactures more than 100 brands of Bottled Water, please review and follow: "Special Instructions for Firms with over 100 Brands of Bottled Water", on the Bottled Water Registration Application (FI-152) form.

  • Water Dispensing Machines

The owner of a water-dispensing machine is required to register each machine before the water is offered for sale. Application with instructions may be found here: Water Dispensing Machine Registration Application (FI-153) form

If you are registering more than four machines at separate locations, please use the following form: Water Dispensing Machine Registration - Attachment for Listing Multiple Locations (FI-171a)

Contact

If you have questions concerning bottled water or water-dispensing machine registration, contact the Michigan Department of Agriculture and Rural Development at 800-292-3939 or write to the Food and Dairy Division at:

Michigan Department of Agriculture and Rural Development
Food and Dairy Division
P.O. Box 30017
Lansing, MI 48909

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