First decision: refill shop or bottling plant?
Everything downstream — licences, equipment, labelling, capital — depends on this choice, and many new owners don't realise they're making it.
A purified-water refill shop (a "water shop") treats municipal or borehole water on site and dispenses it into containers the customer brings or buys. You are a food premises: you need a municipal Certificate of Acceptability (COA) under R638 of 2018 (the general hygiene regulations for food premises under the Foodstuffs, Cosmetics and Disinfectants Act), and your water must be safe drinking water — which in South Africa means measured against SANS 241.
A bottling operation — filling sealed containers for resale — steps into a second regulatory layer: R718 of 2006 (as amended), the regulations relating to all bottled waters, which govern how packaged water is categorised (natural, defined-by-origin, prepared), treated and, together with the food labelling regulations, how it must be labelled. The industry body SANBWA runs an additional voluntary standard its members bottle to.
The practical advice: start refill, add bottling only when a customer actually asks for it in volume. Refill is lighter on capital and compliance, and it's where the neighbourhood demand is. Bolting on R718-grade bottling later is a project, not a pivot.
The licences you actually need
- Certificate of Acceptability (COA) — issued by your municipality's Environmental Health department under R638, before you trade. The inspection looks at premises hygiene: washable surfaces, hand-wash facilities, waste handling, pest control, staff facilities.
- Municipal trading/business licence — requirements vary by municipality for premises selling foodstuffs; ask the same Environmental Health office while you're there.
- If bottling: R718 compliance + labelling — product category rules and label content (including the labelling regulations under the same Act). This is the layer refill-only shops avoid.
- Water source rights — municipal supply is straightforward (you're a customer); a borehole for commercial supply raises water-use questions with your municipality — ask before you sink it.
None of this is exotic — but our research base includes municipal notices from other countries announcing that refill stations failing quality tests a second time will be shut down. The licence gets you open. The quality regime keeps you open.