Label-less water bottles and digital labels in Thailand under Notification No. 462

A label-less water bottle is a drinking-water bottle that carries no label and no printing ink on the bottle itself. Notification No. 462 describes this as showing the label or symbol without label material and without printing ink on the container, except on the cap. The basic details are therefore formed in the bottle, for example by embossing or engraving, or printed on the cap, and the remaining label information is provided through a digital label on the cap.

The same idea is also called a label-free or no-label bottle, and in Thai ขวดไร้ฉลาก or น้ำดื่มไร้ฉลาก. Label-less means without label material, not without information: everything the law requires must still be shown, only it moves to the bottle surface, the cap and the digital label.

A digital label is food label information published in a digital form that a consumer opens on a mobile phone. For bottled drinking water, the Thai Food and Drug Administration (Thai FDA) gives a QR code on the cap as the example: scanning it opens the full label page for the product. Under Notification No. 462, that page must carry the complete label information required by Thai food labelling rules and must be accessible at all times.

The notification itself uses the term digital label and does not say that it must be a QR code. The Thai FDA nevertheless gives a QR code on the cap as its example in both of its press releases on the subject, dated 9 January 2025 and 6 July 2025, so this article uses QR code to mean the common form of digital label.

Yes. Notification of the Ministry of Public Health (No. 462) B.E. 2568 (2025) Re: Drinking Water in Sealed Containers was published in the Royal Gazette on 11 December 2025 and took effect on 12 December 2025. It allows bottled drinking water to show its label without label material and without printing ink on the container, except on the cap, provided the minimum details are shown on the container and the rest is provided through a digital label on the cap.

The notification appears in the Royal Gazette, Volume 142, Special Part 386 Ngor, pages 15 to 18. It is dated 28 November 2025, was issued by the Minister of Public Health, and replaces five earlier notifications on the same subject, the first of them from 1981. The Thai FDA described the change as adding rules that let clear, plastic-label-free water bottles show their information through a digital label.

At least four items must appear on the container: the food name, or the brand, trademark or registered trademark; the food serial number; the net volume; and the day, month and year, or month and year, of production, best-before or expiry, marked MFD or MFG, BB or BF or BBE, or EXP or EXD respectively. This is set out in clause 10 (1) of Notification No. 462, which also states that text shown this way need not be in a contrasting colour.

The food serial number is the product registration number known in Thailand as the อย. (Or Yor) number. The four items can sit on the bottle, on the cap or be split between them: the notification says on the container, and a Thai FDA Food Division summary of the draft notification, dated 18 August 2025, gives their place as the container (bottle or cap). On the AP water that P.A.S. Intergroup produces, the logo is embossed on the bottle and the QR code is printed in the centre of the cap, with the net volume above it.

Details that change with every production run, such as the production, best-before or expiry date, are excepted from the digital label and must be shown on the container, so a consumer reads the date from the bottle itself without scanning anything.

Yes, for a label-less bottle. Clause 10 (2) of Notification No. 462 requires a bottle without label material and without printing ink on the container to provide the remaining label information through a digital label on the cap. A QR code, the form of digital label the Thai FDA gives as its example, therefore goes on the cap, not on the bottle, and the cap is the part of the container the notification exempts, so it may carry ink.

This matches what the Thai FDA said while the rule was in draft. Both of its 2025 press releases use the same wording: other information is to be shown through a digital label, such as a QR code on the cap.

The digital label must carry the complete label information required by the Ministry of Public Health notification on labelling of prepackaged food, together with the statements specific to each type of water, such as the characteristics of the source for source-identified water, or the words added carbonate for water carbonated from another source. The one exception is the production, best-before and expiry date, which must be shown on the container instead. This is clause 10 (2) of Notification No. 462.

The labelling notification currently in force is Notification of the Ministry of Public Health (No. 450) B.E. 2567 (2024). The table below shows where each item belongs. The digital-label rows follow the examples in the Thai FDA Food Division summary and are not a complete list of every requirement in Notification No. 450.

Yes. Clause 10 (3) of Notification No. 462 requires food information shown through a digital label to be accessible at all times, with the system controlled so that it keeps working without interruption. If the QR code will not scan, the link breaks or the website hosting the page goes offline, the consumer cannot see the label information the notification requires.

For an organisation ordering water under its own brand, this raises questions to put to the producer before ordering: who maintains the digital label page, how long it will stay online, and who updates it if the label information changes. A bottle stays in circulation until its best-before date, so although the notification sets no end date, in practice the page should stay available at least for as long as the last batch is on the market and in consumers’ hands.

Yes, if the bottle carries neither label material nor printing ink on the bottle and has no digital label, such as a QR code, on the cap. Clause 10 (2) of Notification No. 462 requires such a bottle to provide the remaining label information through a digital label on the cap, so a bottle that only has an embossed name or logo does not show its label as the notification requires. Section 51 of the Food Act B.E. 2522 (1979) provides that whoever violates a notification issued under section 6 (10), the labelling power, is liable to a fine of up to 30,000 baht.

The provision is applied in practice. In August 2024, for example, the Thai newspaper Matichon reported that selling imported food without Thai-language labels fell under section 6 (10) and was punishable under section 51 by a fine of up to 30,000 baht.

Two cases need to be kept apart.

1. A bottle labelled, or printed, with complete label information on the bottle This bottle follows the general labelling rules rather than the label-less route, so it does not need a QR code on the cap.

2. A bottle with no label and no printing ink on the bottle This bottle must carry the four minimum items on the bottle or cap and must always have a digital label on the cap. If either is missing, its labelling does not meet the notification.

The question is therefore not simply whether there is a QR code, but whether the label information is complete and shown where the notification requires.

The notification does not name who carries the duty, and section 51 applies to whoever violates it. In practice the producer or importer holding the food serial number is directly responsible for the label, but sellers can also face action, as in the Matichon case. With corporate-branded water, a bottle that falls short also goes out under the name and logo of the organisation that ordered it, so it is worth asking for sample bottles and scanning the QR code on the cap yourself, using the checklist at the end of this article.

Within two years of 12 December 2025, under clause 12 of Notification No. 462. The period applies to producers and importers of drinking water licensed before that date under Notification No. 61 (1981) as amended, to producers and importers of water containing carbon dioxide or oxygen licensed under Notification No. 356 (2013) on beverages in sealed containers, and to food producers who use water as an ingredient or in processing. Licences granted from 12 December 2025 must comply straight away.

The two-year period covers the whole notification, which deals with water quality, contaminants and containers as well as labelling, so every existing licensee must meet all of it by December 2027, whatever bottle it uses.

Going label-less is a choice. The Thai FDA press release of 6 July 2025, describing the draft, called the digital label voluntary: a producer may keep labelled bottles or switch to label-less ones, but a label-less bottle must have a digital label on the cap.

A label-less bottle removes label material, adhesive and printing ink from the bottle. The Thai FDA says the change is intended to reduce waste from label materials, make plastic recycling less complicated, lower the cost of recycled plastic resin and of recycling, and reduce the chance of ink and adhesive contaminating recycled resin.

The RecyClass design-for-recycling guidelines for clear PET bottles, updated in January 2025, class direct printing on the bottle as not compatible with recycling, except production or expiry dates, which have limited compatibility when printed and are fully compatible when laser-marked. They also cap the share of the surface that may be covered by non-PET material. A bottle with no label leaves only PET and the cap, which is consistent with the Thai FDA’s reasoning.

As for how much plastic is saved, South Korea, where label-less bottled water became compulsory in 2026, estimated a reduction of about 2,270 tonnes of plastic a year, based on roughly 5.2 billion bottles produced the year before.

Labels and caps have to be separated before a bottle can be recycled. The process is described in how PET bottles are recycled and in common questions about PET bottles and recycling.

Yes. Water containing carbon dioxide falls within the definition of drinking water in sealed containers in Notification No. 462, so the same digital label rules apply. Natural mineral water is excluded from Notification No. 462, but Notification of the Ministry of Public Health (No. 464) B.E. 2568 (2025) Re: Natural Mineral Water (No. 2), which took effect on the same day, also permits a digital label on the cap for containers labelled without label material or printing ink, except, according to the Thai FDA Food Division summary, natural mineral water that must carry a fluoride warning.

Notification No. 462 also covers source-identified water, which must carry additional statements such as the characteristics of the source and its geographical location. These statements can be placed in the digital label like any other information.

Several, and at least one makes it compulsory. South Korea has required bottled water to be label-less since 1 January 2026: the product name, brand, production and expiry dates, water source and contact details are printed on the bottle or cap, and a QR code on the cap gives the full details. In Japan, Asahi began selling its Asahi Oishii Mizu mineral water in label-less PET bottles in 2018, at first by the case only.

South Korea gave single bottles sold in physical shops an extra year, because of concerns that some small retailers might not yet have checkout equipment that reads QR codes; online and multipack sales had to comply straight away. Asahi reports that its distribution volume of label-free products in 2023 was eight times that of 2019.

AP (Thailand) is among the first organisations in Thailand to move its corporate-branded drinking water to label-less bottles with a digital label on the cap since Notification No. 462 took effect. The 250 ml AP bottle has the AP logo embossed on the bottle, with the QR code of the digital label printed in the centre of the cap and the net volume above it, and it is produced by P.A.S. Intergroup.

An organisation can order it from a drinking water plant that can produce bottles embossed with its brand and print caps in line with Notification No. 462. P.A.S. Intergroup produces label-less corporate-branded water at its own plant in Sam Phran, Nakhon Pathom: it designs bottles embossed with the client brand, blows them from preforms, purifies the water by reverse osmosis (R.O.), prints the QR code of the digital label and the net volume on the cap, and sets up and maintains the digital label page the QR code opens, under GHPs and HACCP, certified by Bureau Veritas.

Beyond the label information the notification requires, clients can add images or PDF files introducing the organisation to the digital label page, as on the digital label page of AP’s drinking water. Anything added should stay within clause 11 of the notification: no suggestion that the water treats or prevents disease, and nothing misleading about its source, composition or properties.

The plant has a rooftop solar system with an installed capacity of 370 kilowatts, and offers rPET bottles, made with resin from ENVICCO, as an option for clients who want to use less virgin material. How rPET differs from virgin PET is explained in what rPET is and how it differs from virgin PET.

Organisations that want to move their own-brand water to label-less bottles can contact P.A.S. Intergroup for advice and sample bottles.