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GMP for bottled drinking water plants in Thailand
What drinking water GMP means in Thailand
Drinking water GMP in Thailand means the Good Manufacturing Practice rules that plants producing drinking water in sealed containers must follow. Thai law has no separate GMP notification just for drinking water. Plants follow MOPH Notification No. 420 B.E. 2563, which has basic requirements for every food plant plus Specific Requirement 1 for drinking water in sealed containers, natural mineral water and ice produced by filtration.
On the product side, MOPH Notification No. 462 B.E. 2568 on drinking water in sealed containers took effect on 12 December 2025, replacing Notification No. 61 from 1981. Clause 8 of the new notification requires producers and importers of drinking water for sale to follow the notification on production methods, equipment and food storage, which is GMP 420.
This article covers both sides together: what the plant needs under GMP, and what quality the finished water must reach. For an overview of all GMP 420 sections, see GMP 420 requirements and audit criteria.
Which waters are in scope
Clause 4 of Notification No. 462 defines drinking water in sealed containers to include waters defined by origin and water containing dissolved carbon dioxide, but not natural mineral water, which has its own notification. The Thai FDA explanatory notification adds that spring water is a water defined by origin, and that water with added minerals, vitamins or flavour becomes a beverage in sealed containers instead.
One result for plants: unflavoured soda or carbonated water, previously a beverage, now falls under the drinking water notification. The Thai FDA premises guideline says drinking water plants using filtration and carbonation follow the GMP 420 basic requirements together with Specific Requirement 1.
Producers or importers licensed under Notification No. 61, or carbonated water producers licensed under beverage Notification No. 356, before the new notification took effect, including food producers that use water as an ingredient, must comply with Notification No. 462 within two years of its entry into force under Clause 12.
Bottled water plant GMP: the basic requirements
The GMP 420 basic requirements have five sections: location and buildings, equipment and machinery, production process control, sanitation, and personal hygiene. In drinking water plants, the usual weak points are:
- Filling area. A filling room or controlled filling zone, separated areas, and protection from pests.
- Water-contact materials. Pipes, holding tanks and filling nozzles that can be cleaned, with a maintenance plan.
- Finished product. Tested at a government or accredited laboratory at least once a year.
- Records. Production and distribution records kept at least 1 year after the expiry date on the label.
- Self-assessment. At least once a year.
- Workers. Free of the diseases listed by ministerial regulation, washing hands, wearing hair covers, suitable clothing and shoes, and trained.
These basics are the same as in any food plant, but in drinking water a small lapse, such as an open filling room or an unsanitised nozzle, shows up directly in microbiological results.
Specific Requirement 1 step by step: from raw water to capping
Specific Requirement 1 of GMP 420, for drinking water in sealed containers and natural mineral water processed by filtration, has four main points.
1.1 Know your raw water
Hold a laboratory report on raw water quality at least once a year, used to design a water conditioning system that is adequate and suitable. The Thai FDA production controller manual also recommends retesting whenever the water source changes.
1.2 Pre-condition raw water
Reduce the initial microbial load before the main conditioning stage as needed. For natural mineral water, essential components must not change.
1.3 A verifiable conditioning system
The system must bring hazards in raw water down to legal levels. Equipment must work and match the production rate, and the performance of filters or disinfection units must be checked regularly, with records.
1.4 Prevent recontamination
- Clean and sanitise food-contact surfaces at filling, such as fillers and nozzles, with records.
- Reusable containers must be washed and sanitised correctly and protected after washing, for example rinsed with the water to be filled and filled at once.
- Single-use containers are rinsed with the water to be filled, or another measure is used, then filled at once.
- Fill in a clean filling room, with the filling platform above the floor, directly from the nozzle, and seal immediately in a way that does not contaminate.
- Fillers wear clean clothes, aprons, hair covers and masks, wash hands before work, and do not touch their mouths or the inside of containers.
- 1Test raw waterLaboratory report at least once a year
- 2Pre-conditionReduce microbes before the main stage as needed
- 3Condition the waterEquipment matched to output, performance checked and recorded
- 4Prepare containersWash, sanitise or rinse with the water to be filled
- 5Fill in a clean roomSanitised nozzles, platform above the floor
- 6Seal at onceController verifies records for every batch
Source: MOPH Notification No. 420 B.E. 2563, Specific Requirement 1
Production controller and premises licence
Production controller
Clause 3 of Specific Requirement 1 requires the plant to appoint, in writing, a food process control supervisor based at the site, who oversees every batch and verifies process control records. The supervisor must have passed the course for production controllers of drinking water, natural mineral water and ice, run by the Thai FDA or a training unit on its list.
The Thai FDA manual adds that one controller may serve only one site, though a site may appoint more than one. The law does not require the controller to be present at all times during production, but a site with a controller and no consistent quality controls fails the specific requirement.
Licence or site number
The same manual explains that a site with machinery of 50 horsepower or more, or 50 or more workers, counts as a factory and files form Or.1 for a food production licence (Or.2). Below that threshold, it files form Sor.Bor.1 for a Sor.Bor.1/1 certificate. Both give a site number, after which the product is notified to obtain the 13-digit food serial number.
If you are planning a new plant, see GMP certification steps for a factory.
Drinking water quality standard Thailand: what GMP must deliver
The whole GMP system exists so that water leaving the plant meets Clause 6 of Notification No. 462. The key figures are:
- Physical. Colour no more than 15 Hazen units, no odour, turbidity no more than 4 NTU, and pH no more than 8.5 except for waters defined by origin; water used in food production must be between 6.5 and 8.5.
- Chemical. Total dissolved solids no more than 500 mg/L, total hardness no more than 100 mg/L except for waters defined by origin, and contaminants within the schedule, such as arsenic and lead at no more than 0.01 mg/L and fluoride at no more than 0.7 mg/L. Other contaminants follow WHO guideline values or Codex principles.
- Microbiological. Coliforms and E. coli below 1.1 per 100 mL by MPN, and pathogens within the MOPH notification on pathogenic microorganisms.
The Thai FDA explanatory notification says contaminants are chosen for testing by source type or surrounding land use, and that water passing through a public supply or using disinfectants must also be tested for bromate and by-products. Tests must be done by a government or accredited laboratory. To plan raw water and product testing, see our testing and laboratory service.
GMP manual for drinking water: documents and records to keep
The most direct reference is the Thai FDA Food Division manual for production controllers of drinking water, natural mineral water and ice, revision 2 of January 2025, used in controller training. It is not law, but it explains how to apply GMP 420 in drinking water plants in detail and recommends forms Tor.Sor.2 (63) and Tor.Sor.3 (63) for self-assessment.
Form Tor.Sor.3 (63) is the record auditors use for Specific Requirement 1. It gives pass or fail results, with columns for first and second corrections. A plant that uses the same form on itself sees gaps before the auditor arrives.
At a minimum, keep:
- The annual raw water analysis report
- A diagram of the conditioning system and performance checks for filters or disinfection units
- Cleaning and sanitising records for fillers and nozzles
- Washing records for reusable containers
- The controller's appointment letter and course certificate
- The annual finished product test results
- Self-assessment records
Drinking water labels and banned wording
Clause 10 of Notification No. 462 applies the prepackaged food labelling notification. The container must show at least the food name or trademark, the food serial number, the net volume, and the manufacturing, best-before or expiry date marked MFD or MFG, BB or BBE, or EXP or EXD.
Bottles without labelling material or ink on the body may show the remaining information through a digital label on the cap, except the manufacturing or expiry date, and the digital system must be accessible at all times. Waters defined by origin must show the source location, and carbonated water must carry the statements the notification sets.
Clause 11 prohibits names or statements that imply preventing, relieving or curing disease, statements that mislead about the nature or source, and using local or village names in the product name if the water does not come from there. The controller manual adds that alkaline water claims need a measured pH above 7 and not above 8.5. Check a label draft before printing with the label check.
Existing producers, soda water and spring water: what to file
The Thai FDA premises guideline under Notification No. 462 covers two cases: plants producing carbonated water, and plants producing natural mineral water that is spring water now falling under drinking water. Operators must review their data and contact officials.
- If an audit is needed, apply for an audit, obtain the audit report, then file form Sor.4 or Sor.Bor.2 to amend the food type.
- If no audit is needed, where the plant already has a water conditioning system meeting GMP 420 basics and Specific Requirement 1, has a production controller, and changes no machinery, layout or food type, file Sor.4 or Sor.Bor.2 with the notice-of-intent form.
On the product side, a separate guideline says the system updates the notification reference for existing electronic approvals. Paper approvals must be amended by the operator, and spring water approved under the old notification must be amended for type, kind and process, with the food name reviewed.
Drinking water GMP checklist before an audit
Use the checklist below before applying for an audit or a follow-up visit. If you want consultants to review the site first, see our factory setup and GMP service or contact us.
For plants that already passed, keeping GMP depends on records made every day, not records filled in before a visit. The difference becomes clear when a finished product fails a microbiological test and the plant must trace which day the filtration or nozzle sanitising went off plan.
For GMP basics in general, see what is GMP.
- ✓Latest raw water testPlus a new one when the source changes
- ✓Filter or disinfection performance recordsDone regularly to plan
- ✓Nozzle sanitising and container washing recordsMatching actual production days
- ✓Production controller appointmentWith the course certificate
- ✓Annual finished product resultsFrom a government or accredited lab
- ✓Labels meeting Notification No. 462No disease prevention or cure wording
- ✓Self-assessment recordsForms Tor.Sor.2 and Tor.Sor.3, at least yearly
Source: Notification No. 420 · Notification No. 462 · Thai FDA production controller manual
Frequently asked questions
Which GMP applies to Thai drinking water plants?
MOPH Notification No. 420 B.E. 2563, both the basic requirements and Specific Requirement 1 for drinking water, natural mineral water and filtered ice. Clause 8 of Notification No. 462 points to this GMP.
How often must raw and bottled water be tested?
GMP 420 requires a raw water laboratory report at least once a year and finished product testing at a government or accredited lab at least once a year. The Thai FDA manual also recommends retesting raw water when the source changes.
Must the production controller be on site at all times?
The Thai FDA manual says the law does not require constant presence, but the controller must be appointed in writing, have passed the course, and may serve only one site.
Does unflavoured soda water follow drinking water GMP?
Under Notification No. 462, water containing carbon dioxide falls within drinking water, and Thai FDA guidance applies GMP 420 basics plus Specific Requirement 1 to filtration and carbonation plants.
Can a label say alkaline water?
The Thai FDA controller manual says the measured pH must be above 7 and not above 8.5, and claims implying disease prevention or cure are not allowed.
Sources
- MOPH Notification No. 420 B.E. 2563 (2020) on production methods, equipment and food storage · Open source · Search our archive
- MOPH Notification No. 462 B.E. 2568 (2025) on drinking water in sealed containers (in force 12 December 2025) · Open source · Search our archive
- Thai FDA explanatory notification on the MOPH notification on drinking water in sealed containers · Open source · Search our archive
- Thai FDA guideline on premises licensing for importers and producers under Notification No. 462 · Open source · Search our archive
- Thai FDA guideline on product licensing under Notification No. 462 · Open source · Search our archive
- Form Tor.Sor.3 (63): audit record for Specific Requirement 1 (drinking water, natural mineral water and ice produced by filtration) · Open source · Search our archive
- Thai FDA manual for production controllers of drinking water, natural mineral water and ice (revised January 2025) · Open source · Search our archive
This article is for general information. It is not a Thai FDA ruling or legal advice, and rules change — check the latest notification or ask an expert before filing or producing.
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