Select Committee on Scottish Affairs Appendices to the Minutes of Evidence


Memorandum from the British Soft Drinks Association (BSDA) (DIS 2)

  Thank you for inviting BDSA to up-date its submission[3] to the inquiry.

  Since giving evidence on 9 November 2000, the Scottish Executive has published a consultative document on "The Future for Scotland's Waters". BSDA Members in Scotland, particularly those bottling water, have concerns about the way in which controls might be applied to water abstraction and the attached paper explains these points.

  Please let me know if we can assist in any further way.

British Soft Drinks

Director General

September 2001

Water Abstraction in Scotland


  1.  The Scottish water bottling industry, which accounts for about 35 per cent of UK production (900 million litres) and plays a leading role in developing the industry and consumer perception of the qualities of bottled waters, is particularly concerned that the implementation of the EU Framework Water Directive in Scotland could impose unnecessary burdens or restrictions on industry development. The Scottish Executive is currently consulting on implementation via its paper entitled "The Future for Scotland's Waters". According to the SE, some system of controls on abstractions will be required.

  2.  BSDA fully support policies and measures necessary to protect the environment and natural resources. Indeed, this is essential for Natural Mineral and Spring Water bottlers who are committed to the quality of their products and rely on the inherent characteristics of these natural resources to build the reputation of their businesses. However, it has considerable concerns that the implementation of the EU Framework Water Directive could impose controls and restrictions on water abstractions for the sake of bureaucracy rather than environmental need and thereby have a damaging effect on the development of the industry. In England and Wales, the Environment Agency is proceeding to extend time-limited abstraction licences and is seriously jeopardising the development of the industry: the industry in Scotland strongly opposes that any such system should be applied by SEPA.

The bottled water industry depends on long-term investment

  3.  Bottled water is a fast-growing sector: the UK market for bottled water is now worth more than £550 million per year, growing at an annual rate of 10-15 per cent. Consumption has more than doubled in six years and this rate of growth is predicted by market analysts to continue in the future, as the per capita annual consumption in the UK (23 litres) is well below the West European average (91 litres). To date, the Scottish industry has responded successfully to increasing demand and wants to rise to the challenge of the rapidly growing market.

  4.  The market is very competitive, with a strong presence from imported brands of 25 per cent in 2000. At present, the best-selling and best-known brands in the UK are French. Scottish companies are growing but will need time and investment to be able to match the Continental giants. Banks and other investors will not invest in bottled water companies whose businesses might be arbitrarily curtailed or restricted by the abstraction licensing system. Without investment, the industry will be unable to expand to meet consumer demand and imports will take an even larger share. This is a loss for jobs, the economy and consumer choice.

  5.  It is imperative that the licensing system in Scotland does not stifle investment, and consequently industrial growth, for bureaucratic rather than environmental reasons. BSDA is therefore pleased to read that the Scottish Executive intends to base measures on the principles of need, risk assessment and proportionality. It very much hopes that these principles will be applied in practice and that the resulting measures take account of the needs of water bottling companies. BSDA has the impression that the position of water bottlers is not sufficiently considered when licensing controls are discussed and must stress that measures devised for mains water suppliers are not relevant or appropriate for water bottling companies.

Threat to Rural employment

  6.  Owing to the source of their raw material, water bottlers are located in rural areas, providing much needed employment and economic activity. The expected rise in consumption should help to boost employment in the sector. However, this will be put at risk if abstraction licences deter investment. Instead, demand will be met by importers and jobs will effectively be exported.

  7.  This raises the question as to how the EU Framework Directive is being implemented on the Continent. Through our European network we have received no indication that Continental water bottlers might be confronted with measures which could affect their abstraction activities. This means that they are in a strong position to fill any market demand and places Scottish bottlers in a weak competitive position.

Bottled Water is a Strategic Resource

  8.  Bottled water is not only supplied through retail and on-trade outlets but is also relied upon as a strategic resource. Many mains water companies rely on back-up supplies of bottled water—through contracts with specialist water bottlers—to help them meet their public service obligations in the event of a disruption due to climatic or contamination incidents which prevents the supply or use of mains water. One BSDA Member was called upon three times last year to provide emergency supplies. Maintaining a viable and adequate domestic bottled water industry is, therefore, an essential part of overall public health strategy.

  9.  All bottled water members of BSDA who have been contacted have arrangements or contracts to supply bottled water to water companies, local authorities, hospitals etc in the event of contamination or disruption of the mains water supply.

Water Bottling Uses only a Tiny Proportion of the Overall Water Supply

  10.  It is important that the environmental impact of water bottling is seen in context so that proportionate rules can apply. At present, the Scottish industry bottles around 320 million litres of water per year. This is less than the leakage from the mains system in three hours. In other words, water bottling accounts for only a miniscule amount of water usage in Scotland.

  11.  Furthermore, compared with the way that public water supplies are managed, water bottling is a highly efficient use of water and cannot become more efficient.

Tied to a Specific Source

  12.  Natural Mineral Water and Spring Water bottlers are unique in being linked to specific sources of water. Natural Mineral Water must come from a registered, named, protected location—it cannot simply substitute its supply. Options such as using alternative supplies or relocation are not possible and these factors must be taken into account when measures are devised.


  BSDA urges legislators to take account of the particular needs of water bottlers when implementing rules relating to abstraction licences and to ensure that controls are based on environmental need, risk assessment and proportionality. The growth of the sector depends on the ability to invest and this will be seriously jeopardised if licences are time-limited or onerous to acquire.

British Soft Drinks Association

September 2001

3   See also HC 973-i, session 1999-2000, pp 1-3. Back

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