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Natural Mineral Waters Europe aisbl

NMWE

Natural Mineral Waters Europe (NMWE) represents over 500 producers of natural mineral and spring waters.

Lobbying Activity

Meeting with Aurel Ciobanu-Dordea (Director Environment) and

20 Jan 2026 · Single-use Plastics Directive

Natural Mineral Waters Europe demands priority access to recycled plastic

6 Nov 2025
Topic — This consultation addresses the upcoming Circular Economy Act for sustainable production.
Message — NMWE calls for industry-led systems guaranteeing producers priority access to their recycled packaging. They urge the Commission to prevent governments from using producer fees for non-waste-related activities.12
Why — This would safeguard a steady supply of high-quality recycled plastic at an affordable price.3
Impact — Other sectors would lose access to food-grade plastic unless they invest in collection infrastructure.4
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Meeting with Alexandra Nikolakopoulou (Head of Unit Health and Food Safety)

4 Nov 2025 · Natural mineral waters, update on NMWE’s actions

Meeting with Pascal Arimont (Member of the European Parliament) and FoodDrinkEurope

17 Oct 2025 · Water resilience

Mineral water producers urge priority for human hydration needs

4 Mar 2025
Topic — The EU is developing a strategy to manage water scarcity and ensure resilience.
Message — The group advocates for prioritizing life-sustaining hydration and the full implementation of current water laws. They insist that water management must remain local and that water bottled as product should not face reduction targets.123
Why — Exempting product water from efficiency targets protects the industry's primary commercial output.4
Impact — Chemical manufacturers and industrial polluters face higher costs under the polluter-pays principle.5
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Meeting with Per Clausen (Member of the European Parliament, Shadow rapporteur)

4 Dec 2024 · Meeting on the ongoing negotiations on the Water Pollutants file

Response to Environmental Implementation Review 2025

5 Jul 2024

Please find attached NMWE's contribution to the call for evidence on the EU environmental law - 2025 implementation review. Best regards, NMWE Secretariat
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Natural Mineral Waters Europe urges protection for bottle recycling loops

2 Oct 2023
Topic — Revision of EU rules on end-of-life vehicle design and recycling.
Message — NMWE calls for the EU to prioritize closed-loop recycling for all products. They request priority access to their own recycled material to meet legal targets.123
Why — Securing their own materials allows beverage producers to meet mandatory EU recycling obligations easily.4
Impact — The car industry loses access to easy recycled materials, ending their ability to free-ride.5
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Water producers urge flexible rules for plastic bottle recycling

30 May 2023
Topic — This consultation establishes rules for measuring recycled plastic in beverage bottles.
Message — NMWE wants to include factory scraps in recycling targets and average results across producers. They also recommend reporting data only in 2025 and 2030 rather than every year.123
Why — Including industrial scraps makes it easier for producers to meet mandatory targets.45
Impact — Environmentalists lose if using factory waste masks a failure to recycle consumer plastic.6
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Response to Ecodesign for Sustainable Products - Product priorities

12 May 2023

Please find attached NMWE's contribution to the public consultation on new product priorities for Ecodesign for Sustainable Products. Best regards, the NMWE Secretariat.
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Mineral water producers seek flexible plastic packaging rules

3 May 2023
Topic — The EU is defining sustainable investment criteria for water and circular economy.
Message — NMWE recommends creating a combined threshold for recycled and bio-based plastic content. They warn that the 65% recycled content target poses technical challenges.12
Why — Combining materials would help producers reach sustainability targets despite recycled plastic shortages.3
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Meeting with Kateřina Konečná (Member of the European Parliament, Shadow rapporteur for opinion)

27 Apr 2023 · Packaging and Packaging Waste Regulation

Natural Mineral Waters Europe demands priority access to recycled plastic

24 Apr 2023
Topic — Review of EU packaging rules to reduce waste and improve recycling efficiency.
Message — The group requests priority access to recycled materials to maintain a closed loop for beverage bottles. They also urge the Commission to bring forward deposit system deadlines and make reuse targets more flexible for producers.123
Why — Secured access to recycled PET helps water producers meet legal targets while lowering material costs.4
Impact — Non-beverage industries lose access to high-quality recycled plastic for their own manufacturing processes.5
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Meeting with Malte Gallée (Member of the European Parliament)

20 Apr 2023 · Packaging and Packaging Waste

Meeting with Luisa Regimenti (Member of the European Parliament, Shadow rapporteur) and Amazon Europe Core SARL and

9 Mar 2023 · PPWR

Meeting with Virginie Joron (Member of the European Parliament, Rapporteur for opinion)

8 Mar 2023 · emballage / eau minérale (PME...)

Meeting with Martin Hojsík (Member of the European Parliament)

7 Mar 2023 · Plastics, packaging, recycling, circular economy, waste

Meeting with Patrizia Toia (Member of the European Parliament) and European Aluminium AISBL

2 Mar 2023 · Packaging and Packaging Waste Regulation (meeting taken by the assistant responsible)

Meeting with Salvatore De Meo (Member of the European Parliament, Rapporteur)

27 Feb 2023 · PPWR

Meeting with Delara Burkhardt (Member of the European Parliament, Shadow rapporteur) and The Coca-Cola Company and

16 Feb 2023 · Packaging waste

Meeting with Peter Van Kemseke (Cabinet of President Ursula von der Leyen) and Union of European Beverages Association

21 Nov 2022 · EU Packaging and Waste Packaging Legislation: upcoming revision.

Meeting with Caroline Boeshertz (Cabinet of Executive Vice-President Valdis Dombrovskis) and The Brewers of Europe

17 Nov 2022 · Draft proposal of a Regulation on Packaging and Packaging Waste (PPWR)

Meeting with Peter Liese (Member of the European Parliament, Rapporteur) and European Environmental Bureau and

14 Oct 2022 · ETS

Water producers urge EU to prioritize groundwater in nature restoration

19 Aug 2022
Topic — This initiative proposes legally binding targets to put European biodiversity on recovery.
Message — NMWE requests that groundwater ecosystems receive extensive and rigorous protection from pollutants. The group encourages multi-stakeholder approaches to manage agricultural lands and forest restoration sustainably. They seek an ambitious EU framework that supports voluntary industry actions for ecosystem preservation.123
Why — Stronger environmental standards help companies maintain the natural purity of their water products.45
Impact — Agricultural operations near catchment areas must reduce chemical use to prevent runoff.67
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Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans) and FoodDrinkEurope and Nestlé S.A.

29 Jun 2022 · Revision of the Packaging and Packaging Waste Directive

Response to Amendment of Regulation (EU) No 282/2008 on the recycling of plastic materials to be used as food contact materials

18 Jan 2022

Natural Mineral Waters Europe (NMWE) supports the objective of the Commission's draft Regulation on recycled plastic materials intended to come into contact with foods and welcomes the opportunity to provide comments. Our contribution can be found attached.
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Response to Calculation, verification and reporting of data on the separate collection of SUP beverage bottles

17 Jun 2021

Natural Mineral Waters Europe (NMWE) welcomes the development of the draft Implementing Decision in order to ensure correct implementation of Article 9 SUPD on setting separate collection targets for beverage bottles. NMWE members have already embarked on a transformation journey to become a circular business, through collaboration with value chain partners on separate collection, quality sorting and recycling in order to incorporate an increasing amount of recycled materials back to beverage containers. In order to make their bottles circular, producers need a consistent supply of high-quality, food contact, recycled material. To meet these requirements, separate collection is essential. NMWE was the first sector to endorse Deposit Refund Systems (DRS), in July 2019, as an efficient way to meet the quantitative and qualitative requirements for PET collection and uptake of recycled PET. As far as the Implementing Act is concerned, we believe that some of its provisions need to be further developed/clarified: - The terms “weight of single-use bottles placed on the market” and “weight of separately collected waste single-use bottles” need to be comparable (i.e. empty bottles including weight of caps, lids, labels, adhesives) – Article 3.1 is not clear (The weight of single-use bottles placed on the market shall include only the weight of such bottles that were placed on the market after having been filled with beverage). Although, obviously, the intention is to have like to like comparisons the text in its current state could be misinterpreted - Article 2.5 (Quality assurance systems): we believe that there should never be a discount on quality. Even though the Implementing Act is on separate collection, the same Directive obliges beverage producers to use recycled PET in closed loop. To do so, with mechanical recycling, we need the highest (food grade) quality PET to be collected and we would like to see this point invigorated - Article 2.7 refers to a „paragraph 1, point (b)“. It should not refer to paragraph 4 (b)? - Article 3.2 adjustment of imports and exports is very important especially in some small EU countries. However, the vehicle to adjust those is not clear. Even countries with Deposit Refund Systems are unable to count the imported bottles (exemption some North European countries which have mutually recognized their DRS’ barcodes) - In the Annex, the first formula seems to be incorrect – detailed comments will follow Natural Mineral Waters Europe (NMWE) Natural Mineral Waters Europe represents almost 550 natural mineral and spring water producers in Europe, most of them small- and medium sized companies. NMWE is dedicated to promoting the unique qualities of natural mineral and spring waters as well as sustainable use of water resources and circular economy.
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Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton) and Zero Waste Europe and

8 Jun 2021 · Circular economy, waste management and deposit return schemes

Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans) and Zero Waste Europe and

8 Jun 2021 · Circular economy, waste management and deposit return schemes

Response to Environmental claims based on environmental footprint methods

31 Aug 2020

The European Green Deal with its Circular Economy Action Plan and its Farm to Fork Strategy announced actions to empower consumers to make informed, healthy and sustainable food choices, including an action to examine ways to harmonise voluntary green claims for food products. The European Federation of Bottled Waters (EFBW) welcomes the Commission’s intention to use the Product Environmental Footprint (PEF) methodology as a reference upon which to substantiate green claims in the EU. Indeed, compliance with the harmonised category rules developed in the context of the PEF will provide credible, and reliable information to consumers. Empowering consumers implies that the information conveyed to them is easy to understand as well as be supported by a harmonized scientific and regulatory framework across the EU. EFBW is proud to have participated alongside other sectors and stakeholders, in the European Commission’s landmark initiative to develop the Product Environmental Footprint (PEF) methodology as a robust method to measure and communicate the environmental footprint of products. In early 2014, EFBW responded to DG Environment’s call and volunteered to join the pilot phase on defining EU-harmonised category rules for the evaluation of the environmental footprint of food and non-food products. This led to the approval of Product Category Rules for Packed Waters in April 2018. The methodology developed under the PEF project is a useful reference tool but will need to be a living methodology requiring regular updating and improvement in the light of data availability and scientific evidence. EFBW fully supports the use of PEF for assessing improvements in the environmental performance of a product over time or for internal assessment of a producer’s sustainability efficiency but we do not find it meaningful using PEF to compare products within the same category or between categories. This is because packed water has such a low overall footprint that the margin of error may be higher than the differences between two natural mineral waters. Regarding comparisons between categories, PEF category rules (PEFCRs) are based on several impact categories while each sector should identify the most relevant ones (different from other sectors). Therefore, we suggest that communication on the environmental performance of products remains voluntary (at producers’ discretion) but that producers opting for doing so to rely on assessments carried out in line with the PEFCRs developed for their relevant sector. Indeed, setting a level playing field is critically important to avoid unfair competition and deliver consistent information to consumers. The development of PEFCRs for all sectors is crucial in that respect. As far as the PEF logo is concerned, given the extensive range of information already required on the labelling for most EU products we support the option of an off-pack label which via digital means (i.e. scanning of the barcode) allows producers to convey detailed and comprehensive environmental information, avoiding simplistic or erroneous judgements. Any policy framework to substantiate green claims must be designed to allow for innovation in improving environmental performance of a product and it should not favour a specific communication channel. Policy coherence is also important when PEF will play role in EU Green Deal’s Sustainable Product Policy and Green Public Procurement. In terms of policy options, we believe that option 2 is the right way forward. Overall, EFBW members believe that measures should be based on sound science taking into consideration all impacts across the full life cycle of the product as well as its packaging.
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Response to Review of the requirements for packaging and feasibility of measures to prevent packaging waste

31 Jul 2020

EFBW would like to share its views on the roadmap of the upcoming review of Packaging & Packaging Waste Directive (PPWD). All drink containers used by natural mineral and spring water producers, be it PET, glass or aluminium, are fully recyclable while overpackaging is absent from this sector. Our members are committed to further improving the sustainability of their packaging, by making it fully circular. We support the European Commission’s intention to boost design for recycling. EFBW is a founding member of the European PET Bottle Platform (EPBP), a voluntary industry initiative providing design guidelines for recycling and evaluating new bottle packaging solutions and technologies on the market. Apart from designing for recycling, it is crucially important to create the right conditions for these packaging materials to be effectively recycled. Thus, it is pivotal that each EU MS has the infrastructure in place to deal with all these well-designed packaging materials. Drink bottles made of PET are already the most recycled of all plastic packaging. However, despite industry’s efforts in setting up and financing packaging recovery organizations, the current level of collection of PET beverage bottles varies substantially across the EU. In some Member States the level of collection reaches 96% while in others 14%. For natural mineral and spring water producers, it is of paramount importance to have consistent supply of high-quality recycled materials so that they can use them in their new bottles. For that reason, efficient collection and sorting systems must be in place in every EU country. EFBW endorsed Deposit Refund Systems (DRS), in July 2019, as an efficient way to meet the quantitative and qualitative requirements, foreseen in the SUP Directive, for PET collection and uptake of recycled PET. Apart from collection, the supply of secondary materials needs to be invigorated with the development of chemical recycling which has the potential to complement mechanical recycling in the achievement of recycling targets. Measures adopted under PPWD, EPR fee modulation and SUP Directive should be consistent and pursue the same objectives. Regarding PPWD, we believe that the Essential Requirements should serve as a baseline for the placing of packaging on the market while the EPR fee modulation should be the driving force towards continuous improvement in the design of packaging materials. We also believe that “minimum requirements” for DRS, similar to the ones for EPR in 2018 Waste Framework Directive’s revision, need to be established so that Member States are properly guided should they wish to introduce such a collection system. Sound Impact Assessment should guide any policy measures on packaging and taking into account its specific application. Reuse and refill systems should be implemented when they demonstrate an improved environmental performance from a life cycle assessment (LCA) perspective. This should be compliant with the Product Environmental Footprint (PEF) Category Rules defined under DG Environment’s leadership in which EFBW proudly participated.
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Meeting with Marius Vascega (Cabinet of Commissioner Virginijus Sinkevičius)

23 Jul 2020 · Circular economy in beverage industry

Response to EU 2030 Biodiversity Strategy

20 Jan 2020

EFBW welcomes the European Commission’s EU Biodiversity Strategy 2030. Biodiversity is a critical indicator both for a well performing ecosystem and for human prosperity. Sustainable resource management has always been a top priority for natural mineral and spring water producers. Producers have been safeguarding catchment areas for as much as hundred years, helping to protect the natural ecosystems through which water flows to reach its natural source. The areas of land surrounding underground water sources are subject to rigorous and extensive environmental protection. The "impluvium" - where rain and snow seep into the soil to then journey underground through layers of rock - is a highly protected zone and can extend up to several thousands of hectares. Producers usually work in partnership with local communities, public authorities and farmers to ensure the protection of the sources. This collaboration not only helps safeguarding biodiversity and natural habitats, but also contributes to regional, social and economic activity. EFBW is also partner in EU’s WaterProtect project. It relates to the Horizon 2020 Work Programme under the topic ‘Food security, sustainable agriculture and forestry, marine and maritime and inland water research and the bioeconomy’, and addresses the Topic: Water farms – improving farming and supply of drinking water. Under such project, EFBW provides expertise related to water safety and water protection in natural mineral water protection areas. The aim is to showcase the close cooperation between farmers, communities, NGOs and bottled water producers to reduce point source and diffuse pollution at catchment scale in the benefit of the local biodiversity. Concretely, the natural mineral and spring water producers benefit biodiversity with the following actions: - Creation of large protections areas - Protection and restoration of peaty wet areas (very high biodiversity reservoir) - Cooperation with local authorities, farmers and NGOs to avoid pollution from agrochemicals - Advice on the use of agrochemicals and prohibition of road salt in the catchment areas - Prohibition of water drainage and promotion of percolations/infiltration - Use of biodegradable oil in all forestry engines To guarantee the quality and purity of its waters, for instance, one of our members cooperated with the BeeOmonitoring tool and the expertise of BeeOdiversity to monitor biodiversity and the quality of the environment in the protection zones. The first results, back in 2015, confirmed the very positive impact of the protection zone on the quality of biodiversity: very high biodiversity (twice as large as neighbouring rural areas), absence of contaminants (around 500 compounds tested) and increase of the bee population (from 160,000 to 400,000 bees). As far as packaging is concerned, natural mineral and spring water producers recognize that the improper disposal of and the lack of well performing collection systems for beverage bottles constitute a threat to marine biodiversity. For us bottles are valuable resources which need to be collected, recycled and then incorporated into the new bottles. Our sector has taken many actions in relation to the Circular Economy. Our suggestions in relation to EU Biodiversity Strategy 2030 are the following: - Share best practices occurring at micro-level (like our industry’s contribution) and establish synergies to transform them at macro-level - Link EU policies to concrete biodiversity objectives
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Response to A new Circular Economy Action Plan

20 Jan 2020

EFBW welcomes the European Commission’s new Circular Economy Action Plan (CEAP). The European natural mineral and spring water producers market their products in various fully recyclable packaging materials, such as PET, glass or aluminium, which today already achieve a higher than average EU collection and recycling rate. Our members are committed to further improving the sustainability of their packaging, by making it fully circular. EFBW was the first sector within the food and drink industry to pledge, on 15 May 2018, for 90% collection of PET water bottles and increased uptake of recycled PET in bottles by at least 25% by 2025. EFBW and its members also pledged specific tonnage of additional recycled PET use by 2025, following the EU Plastics Strategy and are signatories to the EU’s Circular Plastics Alliance. In order to make their beverage containers fully circular, producers need a consistent supply of high-quality, food contact, recycled material. To ensure the high quantity and quality of recycled PET for instance, separate collection is essential. This can occur either via existing well-performing curbside collection or by the introduction of well-designed Deposit Refund Systems. Once beverage containers are collected, sorted and recycled then a well-functioning internal market for secondary raw materials is needed. The latter will safeguard that supply and demand of recycled materials match, which is crucial for their uptake by the industry. Innovative technologies such as chemical (or enhanced) recycling could help satisfying the increased demand for recycled plastics, for instance. EFBW was also the first sector to endorse Deposit Refund Systems, in July 2019, as an efficient way to meet the quantitative and qualitative requirements for PET collection and uptake of recycled PET. This is how natural and spring water producers can achieve a strong circular economy and give every bottle a second life. Natural mineral and spring water producers fully support the European Commission’s intention to boost design for recycling. EFBW and its members are involved in pan-industry initiatives on product design. For instance, EFBW is a founding member of the European PET Bottle Platform (EPBP), a voluntary industry initiative providing design guidelines for recycling and evaluating new bottle packaging solutions and technologies on the market. Under this initiative, the PET value chain devotes particular attention to both eco-design and light-weighting solutions. EFBW fully supports the intention of CEAP to empower consumers by providing them with reliable and comparable information on product’s sustainability. The sector participated voluntarily in the Commission’s Product Environment Footprint Category Rules (PEFCR) for food and non-food products. Specific category rules for packaged water enable bottled water producers to assess their environmental performance based on qualitative life cycle assessment. Our members have already embarked on a transformation journey to become a fully circular business, through separate collection, quality sorting and recycling to incorporation of a high percentage of recycled materials back to beverage containers. Well performing collection systems and availability of high quality (food grade) recycled materials are key success factors to achieve this transformation. Natural mineral water and spring waters are food products. Food producers must adhere to strict legal requirements for packaging materials that come into contact with food and beverages. In addition, natural mineral waters must retain their pristine qualities (original purity) from source to final consumer, meaning they must satisfy the most stringent EU hygiene and quality requirements. The swift finalisation of pending authorisation procedures for plastics recycling processes in food contact will pave the way towards an increased uptake of recycled content.
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Meeting with Helena Braun (Cabinet of First Vice-President Frans Timmermans)

10 Apr 2018 · Discussion on the Natural Mineral Water Directive and Plastics

Response to Revision of the Drinking Water Directive (RECAST 2017)

30 Mar 2018

The European Federation of Bottled Waters (EFBW) welcomes the opportunity to comment on the Commission’s Proposal for a Revision of the Drinking Water Directive (Recast 2017) COM (2017) 753.
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Meeting with Nathalie Chaze (Cabinet of Commissioner Vytenis Andriukaitis)

12 Dec 2017 · Legislation on mineral waters

Response to Revision of the Drinking Water Directive

27 Mar 2017

EFBW supports every effort towards facilitating healthy hydration and increasing access to water, whether from the tap or from bottled water. Tap and bottled water are two complementary sources of hydration for the European citizens. EFBW was surprised to see the disparaging arguments against bottled water in the Inception Impact Assessment (IIA) of Drinking Water Directive’s revision. The objectives of Directive 98/83 are to improve the access to safe drinking water and sanitation and ensure that drinking water meets high quality standards in the long term. Thus, putting the revision of the DWD under the Circular Economy Package does not seem consistent with the objectives of the Directive 98/83. In that context, the comparison between tap and bottled water (on point C, preliminary assessment of expected impacts), as far as economic, social and environmental impacts are concerned, is irrelevant. The references on the Circular Economy and bottled water surprisingly occurred only in this IIA and not in any of the previous documents (roadmap or the REFIT evaluation (SWD(2016) 428 final)). In addition, there does not seem to be any link between the listed policy options and the economic, social and environmental impacts from shifting bottled water consumption to tap water consumption. EFBW is in favour of high quality drinking water for all European citizens. Studies show that people do not drink enough and are not meeting EFSA guidelines for water intake. For EFBW, discrimination against any source of hydration goes against public health interest. The IIA in question wrongly compares two different products, which is not relevant for the directive’s objectives. We strongly believe that the assumptions made about bottled water in the IIA is a case of unscientifically supported and unfair discrimination against a healthy product.
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