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Indonesia's Bottled Drinking Water Industry (AMDK): Regulatory Framework, Water Source Classifications, National and International Standards, Production Technologies, Quality Assurance Systems, and Market Structure Analysis

Category: Water
Date: Oct 28th 2025
Indonesia's Bottled Drinking Water Industry (AMDK): Regulatory Framework, Water Source Classifications, National and International Standards, Production Technologies, Quality Assurance Systems, and Market Structure Analysis

Reading Time: 45 minutes | Exchange Rate: 1 USD = IDR 16,500 (October 2025)



Key Highlights

• Comprehensive Regulatory Framework: Indonesian bottled drinking water (AMDK - Air Minum Dalam Kemasan) industry governed by Ministry of Industry Regulation 96/2011 establishing production requirements, National Standards (SNI) 3553:2023 for mineral water and SNI 6241:2015 for demineralized water, Ministry of Health Regulation 492/2010 on drinking water quality parameters, and mandatory certification through BPOM (National Agency of Drug and Food Control) ensuring product safety, quality consistency, and consumer protection across diverse water source types including natural mineral springs, reverse osmosis (RO) treated water, and desalination processes[1]


• Water Source Classification System: Indonesian AMDK regulations distinguish multiple water source categories each with specific quality requirements and labeling obligations including Air Mineral (natural mineral water from protected underground sources containing naturally occurring minerals), Air Demineral (demineralized water processed through RO, distillation, or ion exchange removing mineral content), Air Mineral Buatan (remineralized water where minerals artificially added to demineralized water), and specialized categories including Air Pegunungan (mountain water) and Air Artesis (artesian water) with each classification requiring compliance with corresponding SNI standards and BPOM registration procedures[2]


• Production Technology and Quality Assurance: AMDK manufacturing facilities must implement Hazard Analysis Critical Control Point (HACCP) systems per International Bottled Water Association (IBWA) standards, maintain ISO 17025 accredited laboratories for quality testing, employ multi-barrier treatment processes including filtration (microfiltration, ultrafiltration, or reverse osmosis), UV disinfection, ozonation, and aseptic packaging systems ensuring microbiological safety with routine monitoring of 52 physical, chemical, and biological parameters per SNI 3553:2023 requirements validated through third-party laboratory testing at frequencies ranging from daily (microbiological) to quarterly (comprehensive analysis)[3]


• Market Structure and Investment Scale: Indonesia's AMDK industry represents IDR 35-40 trillion annual market value (USD 2.1-2.4 billion) growing 8-12% annually driven by urbanization, rising health awareness, and limited piped water access affecting 80% of population, with market structure spanning large multinational producers (Danone-Aqua, Coca-Cola, Nestlé controlling 60-65% market share), regional brands serving provincial markets, and local producers supplying district-level demand, requiring capital investment IDR 50-150 billion (USD 3-9 million) for integrated 10,000-30,000 bottles/hour production facilities including water treatment systems, bottling lines, quality laboratories, and distribution infrastructure[4]



Executive Summary

Air Minum Dalam Kemasan (AMDK) - bottled drinking water - represents critical component of Indonesia's beverage industry addressing water access and quality challenges affecting majority of population lacking reliable piped water services meeting health and safety standards. Industry encompasses diverse water sources including natural mineral springs exploited directly with minimal treatment, purified water produced through reverse osmosis (RO) or distillation removing contaminants and minerals, remineralized water where minerals added to purified water achieving desired composition, and specialized categories including artesian wells, mountain springs, and desalinated seawater for coastal regions. Each source type employs distinct treatment technologies, quality control protocols, and regulatory compliance requirements ensuring safe, consistent products meeting consumer expectations and health standards while competing across price segments from premium natural mineral water commanding IDR 8,000-15,000 per liter to economy purified water at IDR 2,000-4,000 per liter.[1]


Regulatory framework governing Indonesian AMDK industry established through hierarchical legal instruments beginning with Ministry of Industry Regulation (Permenperin) 96/2011 prescribing technical requirements for production facilities including water source protection, treatment processes, quality assurance systems, and production documentation, National Standards (SNI) defining product specifications with SNI 3553:2023 for mineral water establishing maximum limits for 52 parameters including physical characteristics (turbidity, color, odor), chemical contaminants (heavy metals, nitrates, fluoride), microbiological indicators (total coliform, E. coli, Pseudomonas), and radionuclides, Ministry of Health Regulation (Permenkes) 492/2010 setting drinking water quality standards applicable to both packaged and distributed water, and Food and Drug Supervisory Agency (BPOM) regulations requiring mandatory product registration, facility licensing, halal certification through MUI (Indonesian Ulema Council), and compliance with Good Manufacturing Practices (GMP) ensuring hygienic production conditions.[2] Furthermore, international standards including Codex Alimentarius STAN 108-1981 for natural mineral waters, FDA regulations Title 21 CFR Part 165.110 providing US benchmark, European Directive 2009/54/EC establishing EU requirements, and International Bottled Water Association (IBWA) Model Code representing industry best practices inform Indonesian regulatory development ensuring alignment with global standards facilitating export opportunities and technology transfer.[5]


Indonesian AMDK market demonstrates substantial scale and growth trajectory driven by demographic trends including urbanization concentrating population in cities where piped water access remains limited or quality uncertain, rising middle class with increased purchasing power and health consciousness prioritizing safe drinking water, and tourism sector supporting hotel, restaurant, and retail demand. Market size estimated IDR 35-40 trillion annually (USD 2.1-2.4 billion) with consumption volumes exceeding 30 billion liters representing per capita consumption 115-120 liters/person/year significantly lower than developed markets (Thailand 250+ liters, UAE 300+ liters) indicating substantial growth potential as economic development continues.[4] Production facilities number approximately 700-800 licensed AMDK manufacturers ranging from multinational corporations operating multiple plants with advanced automation and quality systems to small-scale local producers serving district markets with basic equipment, though industry concentration increases with top 5 producers (Danone-Aqua, Coca-Cola Amatil Indonesia, Nestle Waters, Otsuka, and Wings Group) controlling approximately 65-70% market share through extensive distribution networks, brand recognition, and economies of scale. This comprehensive analysis examines AMDK industry fundamentals including regulatory framework, water source classifications, production technologies, quality assurance systems, market structure, investment requirements, and operational best practices providing manufacturers, investors, regulators, and industry stakeholders actionable guidance for business development, compliance management, and quality excellence aligned with Indonesian regulations and international standards.


Defining AMDK: Industry Scope and Product Classifications

Air Minum Dalam Kemasan (AMDK) defined under Indonesian regulations as drinking water packaged in bottles, cups, or other sealed containers, processed to meet drinking water quality standards, safe for direct consumption without additional treatment, and distributed through commercial channels for public consumption. This definition distinguishes AMDK from bulk water delivery services, water vending machines dispensing unpackaged water, and tap water distributed through piped networks, emphasizing packaging integrity, quality assurance, and commercial distribution characteristics. Ministry of Industry Regulation 96/2011 establishes AMDK production scope encompassing water sourcing from approved sources (springs, wells, municipal supplies), treatment processes ensuring safety and quality (filtration, disinfection, mineralization as appropriate), packaging in food-grade containers maintaining sterility, quality testing validating compliance with standards, and distribution maintaining cold chain or ambient conditions preserving product integrity.[1] Consequently, AMDK industry spans diverse business models from vertically integrated companies controlling water sources, treatment plants, and distribution to contract packagers processing water for brand owners, and importers bringing foreign brands serving premium segments.


Product classification system differentiates AMDK types based on water source characteristics and treatment processes applied, with regulatory implications affecting labeling requirements, quality standards, and production procedures. Primary classifications include Air Mineral (mineral water) sourced from natural underground formations protected from contamination containing naturally occurring minerals at levels providing potential health benefits without artificial addition, Air Demineral (demineralized or purified water) produced from any source through treatment processes removing dissolved minerals typically through reverse osmosis, distillation, or deionization resulting in very low Total Dissolved Solids (TDS) typically below 10 mg/L, and Air Mineral Buatan (remineralized or enhanced water) where minerals artificially added to demineralized water achieving specified composition and TDS levels typically 50-250 mg/L providing taste characteristics and potential nutritional benefits.[2] Additional specialized categories include Air Artesis (artesian water) from confined aquifers where natural pressure brings water to surface without pumping, Air Pegunungan (mountain water) from high-elevation springs suggesting pristine quality though not legally defined, Air Alkali (alkaline water) with pH adjusted above 7.5-9.5 through mineral addition or electrolysis, and specialized functional waters incorporating added ingredients like oxygen, electrolytes, or vitamins though these may fall under different regulatory categories beyond basic AMDK.


SNI 3553:2023 establishes technical specifications for mineral water (Air Mineral) defining it as water originating from natural source (spring or well) characterized by constant composition and stable microbiological characteristics under natural conditions, containing naturally occurring minerals and trace elements potentially providing beneficial properties, sourced from protected aquifer preventing contamination, and undergoing only permitted treatments including separation of unstable constituents (iron, manganese, sulfur compounds), removal of certain undesirable components (fluoride if excessive), incorporation of carbon dioxide (carbonation if desired), and disinfection only if microbiologically necessary. Standard prohibits treatments fundamentally altering mineral water's essential characteristics including desalination, demineralization, addition of minerals not naturally present, or blending with water from different sources.[3] Conversely, SNI 6241:2015 governs demineralized water (Air Demineral) defining it as water from any source treated to remove dissolved minerals resulting in TDS typically below 10 mg/L, produced through processes including reverse osmosis (membrane separation), distillation (evaporation and condensation), ion exchange (resin-based mineral removal), or combinations thereof, suitable for direct consumption or remineralization. Standard permits addition of carbon dioxide, minerals for taste and health purposes within specified limits, and disinfection ensuring microbiological safety.



AMDK Product Classification Matrix:




Air Mineral (Natural Mineral Water) - SNI 3553:2023:
• Source: Protected underground aquifer (spring or well)
• Mineral content: Naturally occurring, TDS 50-1,500 mg/L typical
• Treatment: Minimal - filtration, iron/manganese removal, ozonation
• Characteristics: Constant composition, microbiologically pure
• Labeling: Must identify source location, mineral composition[3]
• Premium positioning: IDR 8,000-15,000 per liter retail
• Market examples: Equil, Evian, Voss, Vittel, local spring sources
• Regulatory emphasis: Source protection, composition consistency


Air Demineral (Purified/Demineralized Water) - SNI 6241:2015:
• Source: Any approved source (well, municipal, surface water)
• Mineral content: Very low, TDS typically <10 mg/L after treatment
• Treatment: RO, distillation, deionization removing minerals
• Characteristics: Consistent purity, neutral taste
• Labeling: Must state "Air Demineral" or "Purified Water"[2]
• Economy positioning: IDR 2,000-4,000 per liter retail
• Market examples: Basic AMDK brands, store brands
• Regulatory emphasis: Treatment effectiveness, microbiological safety


Air Mineral Buatan (Remineralized Water):
• Source: Demineralized water as base
• Mineral content: Artificially added, TDS 50-250 mg/L typical
• Treatment: Demineralization followed by controlled mineral addition
• Characteristics: Designed composition for taste and health
• Labeling: Must disclose artificial mineral addition
• Mid-market positioning: IDR 4,000-8,000 per liter retail
• Market examples: Major brands using RO + remineralization
• Regulatory emphasis: Mineral addition limits, composition disclosure


Air Artesis (Artesian Water):
• Source: Confined aquifer with natural pressure
• Mineral content: Naturally occurring, varies by geology
• Treatment: Minimal, similar to mineral water
• Characteristics: Self-flowing from natural pressure
• Labeling: Must verify artesian source characteristics
• Premium positioning: IDR 10,000-20,000 per liter retail
• Market examples: Limited Indonesian artesian sources
• Regulatory emphasis: Source verification, geological confirmation


Specialized Categories:
• Air Alkali (Alkaline Water): pH 7.5-9.5 through mineral addition
• Air Berkarbonasi (Carbonated/Sparkling): CO₂ addition natural or artificial
• Air Oksigen (Oxygenated): Dissolved oxygen enhancement
• Air Elektrolit (Electrolyte Water): Added sodium, potassium minerals
• Air Fungsional (Functional Water): Added vitamins, antioxidants
• Regulatory status: Some fall under different BPOM categories
• Market development: Growing segments with premium pricing
• Standards: May require compliance with beverage regulations beyond AMDK


Prohibited Classifications:
• Flavored water: Not considered AMDK, falls under beverage category
• Sweetened water: Classified as beverage requiring different standards
• Therapeutic water: Health claims prohibited without regulatory approval
• Blended sources: Mineral water cannot blend multiple sources
• Artificial processing: Mineral water cannot undergo desalination
• Misleading claims: Terms like "glacier," "iceberg" require verification
• Enforcement: BPOM monitors compliance, violations subject to penalties[6]
• Consumer protection: Clear labeling ensuring informed choices



Package format specifications address container types, materials, sizes, and labeling requirements ensuring product integrity and consumer information. AMDK packaged in various formats including PET (polyethylene terephthalate) bottles dominating market with sizes ranging 240ml to 19 liters (gallon), glass bottles for premium products maintaining traditional appeal and impermeability, polycarbonate containers for reusable gallon formats though declining due to BPA concerns, multilayer pouches for economy single-serve formats in rural markets, and cups with sealed foil lids for children and institutional service. Container materials must comply with food safety standards preventing migration of harmful substances into water, maintain sterility through production and distribution preventing recontamination, and protect against light and oxygen for products sensitive to degradation. Labeling requirements per BPOM regulations include product name indicating water type (mineral, demineralized, etc.), net content in metric units, manufacturer name and address, BPOM registration number (ML or MD prefix), production date and expiration date (typically 12-24 months for bottled water), composition or ingredients (especially mineral content for mineral water), storage instructions, and halal certification logo if applicable.[6] Premium products often include additional information such as source location, mineral analysis, pH value, and total dissolved solids (TDS) providing transparency supporting premium positioning.


Water Source Types and Selection Criteria for AMDK Production

Water source selection represents fundamental decision affecting product positioning, treatment requirements, production costs, and regulatory compliance pathways with different source types presenting distinct advantages, challenges, and market opportunities. Natural mineral springs represent premium source option where underground aquifers provide naturally filtered, microbiologically pure water with stable mineral composition requiring minimal treatment, commanding highest retail prices but demanding geological surveys confirming aquifer characteristics, hydrogeological studies establishing sustainable yield, source protection zones preventing contamination, and long-term monitoring ensuring composition consistency.[1] Indonesia's volcanic geology creates numerous potential mineral spring sources particularly in Java, Sumatra, and Bali with varying mineral compositions reflecting local geological formations, though competition for spring sources intensifies among AMDK producers recognizing market premiums justify investment in source development and protection infrastructure including deep well drilling, protection zones prohibiting development within specified radii, monitoring wells tracking water levels and quality, and security measures preventing unauthorized access or contamination.


Groundwater from drilled wells represents most common AMDK source in Indonesia providing reliable supply, manageable quality, and location flexibility supporting production facilities near distribution centers reducing logistics costs. Deep wells (50-300 meters) access confined aquifers providing natural protection from surface contamination through overlying impermeable layers (clay, rock formations), typically producing water with moderate mineral content (TDS 50-500 mg/L), relatively stable composition, and minimal microbiological contamination though requiring monitoring for geological contaminants including iron, manganese, fluoride, and arsenic in certain geological formations. Shallow wells (10-50 meters) access unconfined aquifers more vulnerable to surface contamination requiring more extensive treatment but suitable for demineralized water production where minerals subsequently removed through RO processing. Well development requires hydrogeological investigation establishing aquifer characteristics, pumping tests determining sustainable yield preventing over-extraction, water quality analysis confirming suitability for AMDK production, environmental permit (SIPA - Surat Izin Pengambilan Air) from Ministry of Environment and Forestry authorizing water abstraction, and monitoring programs tracking water levels, quality parameters, and aquifer sustainability ensuring long-term viability.[7] Location selection considers geological conditions favorable for groundwater availability, proximity to target markets minimizing distribution costs, land availability for production facilities and future expansion, utility access (electricity, roads) supporting operations, and regulatory compliance including zoning approvals and environmental assessments.


Municipal water supply serves as source for AMDK particularly in urban areas where producers lack access to groundwater or springs, leveraging existing infrastructure though requiring extensive treatment to achieve bottled water quality standards and address inconsistencies in municipal supply quality. Reverse osmosis systems effectively remove contaminants, minerals, and microbiological content producing demineralized water suitable for direct bottling or remineralization to desired specifications, with treatment reliability depending less on source variability than groundwater or springs creating operational consistency. However, municipal source dependency creates vulnerabilities including supply interruptions affecting production continuity, quality fluctuations requiring adaptive treatment processes, public perception concerns associating product with "tap water" potentially limiting premium positioning, and cost structures including municipal water charges, wastewater disposal fees, and treatment expenses potentially exceeding groundwater exploitation costs. Consequently, municipal sources primarily serve demineralized water and economy segments where production efficiency and distribution advantages offset source perception limitations, with manufacturers emphasizing extensive purification processes in marketing communications addressing quality concerns while compliance with SNI 6241:2015 ensures products meet all safety and quality standards regardless of source origin.[2]



Water Source Evaluation Matrix for AMDK Production:




Natural Mineral Springs:
• Source characteristics: Protected underground aquifer, constant composition
• Quality advantages: Natural filtration, microbiologically pure, stable minerals
• Treatment requirements: Minimal - filtration, iron removal, ozonation
• Regulatory pathway: SNI 3553:2023 compliance, source protection requirements[3]
• Investment requirements: IDR 10-30 billion source development and protection
• Operating costs: Low treatment costs, moderate pumping and monitoring
• Market positioning: Premium segment, IDR 8,000-15,000/liter retail
• Challenges: Limited availability, competition for sources, long development timeline
• Examples: Volcanic springs in West Java, Bali, North Sumatra
• Yield sustainability: 50-500 liters/second typical from major springs


Deep Groundwater Wells:
• Source characteristics: Confined aquifer 50-300 meters depth
• Quality advantages: Protected from surface contamination, stable supply
• Treatment requirements: Filtration, iron/manganese removal, disinfection
• Regulatory pathway: SIPA permit, well construction standards, monitoring[7]
• Investment requirements: IDR 1-5 billion per well including exploration
• Operating costs: Pumping energy, maintenance, water abstraction fees
• Market positioning: Mid to premium segments depending on mineral content
• Challenges: Aquifer depletion risks, geological contaminants, permit competition
• Advantages: Location flexibility, scalable capacity through multiple wells
• Yield capacity: 10-100 liters/second per well typical for production


Shallow Groundwater Wells:
• Source characteristics: Unconfined aquifer 10-50 meters depth
• Quality challenges: Vulnerable to surface contamination, variable quality
• Treatment requirements: Extensive - filtration, RO, disinfection recommended
• Regulatory pathway: Suitable primarily for demineralized production
• Investment requirements: IDR 500 million - 2 billion per well
• Operating costs: Lower pumping costs, higher treatment requirements
• Market positioning: Economy segments, demineralized water products
• Challenges: Quality variability, contamination vulnerability, seasonal fluctuations
• Advantages: Lower drilling costs, easier development, widespread availability
• Suitability: Best for RO-based demineralized water production


Municipal Water Supply:
• Source characteristics: Treated municipal distribution system
• Quality variability: Inconsistent quality, chlorination residuals, pipe contamination
• Treatment requirements: Complete - typically RO, multi-stage filtration, UV
• Regulatory pathway: SNI 6241:2015 compliance for demineralized product[2]
• Investment requirements: IDR 5-15 billion treatment system for 10,000 bottles/hour
• Operating costs: Municipal water charges, wastewater disposal, extensive treatment
• Market positioning: Economy to mid-segments, demineralized products
• Challenges: Public perception, supply interruptions, regulatory complexity
• Advantages: Infrastructure availability, urban location convenience
• Applications: Demineralized water, remineralized products for urban production


Surface Water (Rivers, Lakes):
• Source characteristics: Exposed to environmental contamination
• Quality challenges: High turbidity, biological contamination, seasonal variation
• Treatment requirements: Comprehensive - coagulation, sedimentation, filtration, RO, disinfection
• Regulatory considerations: Generally discouraged for AMDK direct production
• Investment requirements: IDR 20-50 billion advanced treatment for reliable quality
• Operating costs: High chemical usage, energy intensive treatment
• Market limitations: Difficult to achieve premium positioning
• Typical application: Source for municipal supply, not direct AMDK production
• Exceptions: Some international brands use surface sources with extensive treatment
• Indonesian context: Rarely used due to alternative source availability


Desalination (Seawater/Brackish Water):
• Source characteristics: High salinity requiring extensive treatment
• Quality challenges: TDS 35,000+ mg/L seawater, 2,000-10,000 mg/L brackish
• Treatment requirements: Reverse osmosis with pretreatment and post-treatment
• Regulatory pathway: SNI 6241:2015 for demineralized product
• Investment requirements: IDR 30-80 billion for 10,000 bottles/hour capacity
• Operating costs: Very high energy consumption, membrane replacement
• Market positioning: Potentially premium for coastal resort/tourism markets
• Challenges: Energy costs, membrane fouling, brine disposal
• Applications: Limited to coastal areas without alternative sources
• Indonesian potential: Islands without groundwater, coastal resorts, remote locations



Source water quality assessment and monitoring constitutes critical operational requirement ensuring consistent compliance with AMDK standards and identifying treatment needs. Comprehensive baseline characterization includes physical parameters (temperature, turbidity, color, odor, taste), chemical composition (major ions including calcium, magnesium, sodium, potassium, chloride, sulfate, bicarbonate), trace elements and minerals (iron, manganese, fluoride, silica, various trace minerals), contaminants (heavy metals including arsenic, lead, mercury, chromium, nitrates, organic compounds, pesticides), microbiological indicators (total coliform, fecal coliform, E. coli, Pseudomonas aeruginosa, heterotrophic plate count), and radionuclides (gross alpha and beta radiation). Testing frequency per SNI and BPOM requirements includes daily monitoring of key operational parameters (turbidity, chlorine residual, pH, temperature), weekly testing of critical indicators (microbiological tests, iron, manganese), monthly comprehensive chemical analysis covering regulated parameters, and quarterly testing of full parameter suite including trace contaminants and radionuclides with all testing conducted by accredited laboratories (ISO 17025) ensuring result validity.[3] Monitoring programs establish baseline conditions, track temporal variations identifying seasonal patterns or developing trends, verify treatment effectiveness ensuring processes adequately address contaminants, document regulatory compliance supporting BPOM inspections and product registration renewals, and enable early detection of quality degradation triggering corrective actions before product quality impacts occur.


Regulatory Framework: National Standards and Compliance Requirements

Indonesian AMDK regulatory framework comprises multiple legal instruments establishing production requirements, quality standards, registration procedures, and enforcement mechanisms ensuring product safety, quality consistency, and consumer protection. Foundation established through Ministry of Industry Regulation (Permenperin) 96/M-IND/PER/12/2011 concerning Technical Requirements for Beverage Industry AMDK Products prescribing facility design standards, hygiene requirements, production documentation systems, quality control programs, and product certification procedures applicable to all AMDK manufacturers regardless of scale or product type.[1] Regulation mandates facilities maintain Good Manufacturing Practices (GMP) including physical separation of production areas preventing cross-contamination, hygienic design of equipment with food-grade materials and cleanability, personnel hygiene programs with health screening and protective clothing, pest control measures preventing contamination from insects and rodents, and waste management systems properly disposing of wastewater and solid wastes. Furthermore, producers must implement quality management systems documenting processes from water sourcing through final product release, maintain testing laboratories or contract with accredited facilities, employ qualified personnel with appropriate technical expertise, and submit to periodic inspections by Ministry of Industry officials verifying compliance with regulatory requirements.


National Standards Indonesia (SNI) establish technical specifications for AMDK products with mandatory compliance enforced through Ministry of Industry regulations. SNI 3553:2023 Air Mineral (Natural Mineral Water) revised from previous 2015 version defines natural mineral water as water from underground geological source characterized by content of certain mineral salts and their relative proportions and presence of trace elements or other constituents, taken from natural or bore source at one or more natural or bore exits, and can be clearly distinguished from ordinary drinking water by its nature and original purity, both of which have been preserved intact. Standard establishes maximum limits for 52 parameters including physical characteristics (turbidity <5 NTU, color <15 TCU, odor and taste acceptable), major inorganic constituents (limits for sodium, potassium, calcium, magnesium, chloride, sulfate, bicarbonate based on natural occurrence), trace elements and contaminants (arsenic <0.01 mg/L, lead <0.01 mg/L, cadmium <0.003 mg/L, mercury <0.001 mg/L, chromium <0.05 mg/L, copper <1.0 mg/L, fluoride <1.5 mg/L, nitrate <45 mg/L), microbiological requirements (E. coli and coliform bacteria absent in 250 mL sample, Pseudomonas aeruginosa absent in 250 mL, colony count <100 CFU/mL), and radionuclides (gross alpha <0.1 Bq/L, gross beta <1.0 Bq/L).[3] Testing methodology specifications reference ISO methods ensuring consistency and international recognition of results.


SNI 6241:2015 Air Minum Dalam Kemasan (Demineralized Bottled Drinking Water) governs purified and demineralized water products establishing requirements for water processed to remove minerals through reverse osmosis, distillation, deionization, or similar technologies. Standard permits remineralization adding minerals for health or taste purposes within specified limits while maintaining product classification as demineralized water provided total dissolved solids (TDS) remains low typically below 50 mg/L after mineral addition. Quality specifications include physical requirements (turbidity <5 NTU, color <15 TCU, no objectionable odor or taste), chemical parameters (limits for contaminants similar to SNI 3553 though natural mineral occurrence limits not applicable), microbiological requirements (identical to mineral water with E. coli and coliform absence, Pseudomonas aeruginosa absence, low colony counts), and optional specifications for products with mineral addition including minimum and maximum limits ensuring health safety and taste quality.[2] Standard recognizes diverse production technologies permit various source waters provided final product meets quality specifications and treatment adequately removes contaminants achieving demineralized status.



Indonesian AMDK Regulatory Compliance Framework:




Ministry of Industry Regulations:
• Permenperin 96/2011: Technical requirements for AMDK production facilities[1]
• Permenperin 47/2020: Additional specifications for mineral water production
• Facility design: GMP compliance, hygienic construction, process flow
• Equipment standards: Food-grade materials, cleaning protocols, maintenance
• Personnel requirements: Training, health screening, hygiene practices
• Documentation: Production records, quality testing, batch traceability
• Inspection procedures: Annual inspections, compliance verification
• Enforcement: Warning letters, production suspension, license revocation


National Standards (SNI) - Mandatory Compliance:
• SNI 3553:2023: Natural mineral water specifications (52 parameters)[3]
• SNI 6241:2015: Demineralized bottled water specifications[2]
• Physical parameters: Turbidity <5 NTU, color <15 TCU, no odor/taste
• Chemical limits: Heavy metals (Arsenic <0.01 mg/L, Lead <0.01 mg/L, Mercury <0.001 mg/L)
• Microbiological: E. coli absent/250mL, Total coliform absent/250mL, HPC <100 CFU/mL
• Testing frequency: Daily (operational), weekly (critical), monthly (comprehensive), quarterly (full suite)
• Laboratory requirements: ISO 17025 accreditation mandatory
• Certification: Product certification through Ministry of Industry


BPOM (Food and Drug Authority) Requirements:
• Product registration: ML or MD number mandatory for market authorization[6]
• Registration validity: 5 years renewable upon demonstration of continued compliance
• Facility inspection: GMP compliance verification before registration approval
• Labeling requirements: Product name, net content, manufacturer details, registration number
• Composition disclosure: Mineral content, TDS, pH for transparency
• Expiration dating: 12-24 months typical, validated through stability testing
• Post-market surveillance: Random sampling, laboratory testing, compliance monitoring
• Enforcement powers: Product recall, facility closure, criminal prosecution


Ministry of Health Standards:
• Permenkes 492/2010: Drinking water quality parameters and requirements
• Applicable to AMDK: All drinking water regardless of distribution method
• Microbiological standards: Coliform bacteria, E. coli, pathogen absence
• Chemical standards: Comprehensive inorganic and organic contaminant limits
• Radioactivity limits: Gross alpha and beta radiation thresholds
• Physical characteristics: Turbidity, color, odor, taste acceptability
• Monitoring frequency: Product-specific based on risk assessment
• Health surveillance: Disease outbreak investigation, contamination response


Environmental Regulations:
• SIPA permit: Water abstraction license from Ministry of Environment[7]
• AMDAL/UKL-UPL: Environmental impact assessment based on scale
• Wastewater discharge: Effluent quality standards compliance
• Solid waste management: Bottle recycling, production waste disposal
• Groundwater monitoring: Water level, quality tracking preventing depletion
• Source protection: Protection zones preventing contamination
• Sustainability requirements: Aquifer recharge, conservation measures
• Reporting obligations: Annual reports on water usage, environmental impacts


Halal Certification (Optional but Market Standard):
• Issuing authority: MUI (Indonesian Ulema Council)
• Process requirements: Ingredient verification, production process review
• Facility inspection: Segregation from non-halal processes if applicable
• Certificate validity: 2-4 years renewable
• Labeling: Halal logo display on packaging
• Market importance: Expected by Muslim consumers (majority market)
• Export facilitator: Required for many international Muslim markets
• Compliance costs: IDR 5-20 million certification depending on facility scale



BPOM (Badan Pengawas Obat dan Makanan - National Agency of Drug and Food Control) administers product registration and post-market surveillance for AMDK ensuring only compliant products enter market and maintaining ongoing quality through monitoring and enforcement. Registration process requires manufacturers submit comprehensive dossiers including company legal documents (business permits, factory operation licenses, tax registration), product specifications (water source description, treatment processes, quality parameters), laboratory test results from accredited facilities demonstrating compliance with SNI standards, production process description documenting source to final package, packaging specifications including materials and labeling, and quality assurance systems describing testing programs and documentation procedures.[6] BPOM evaluates submissions for completeness and compliance, conducts facility inspections verifying GMP implementation and documentation accuracy, and issues ML (Makanan Lokal - Local Food) number for domestically produced AMDK or MD (Makanan Dalam Negeri - Domestic Food) for products manufactured under license from foreign companies. Registration validity extends 5 years requiring renewal with updated information, compliance documentation, and facility re-inspection demonstrating continued adherence to regulatory requirements. Post-market surveillance includes random sampling from retail outlets testing compliance with registered specifications, investigation of consumer complaints addressing quality concerns or adverse events, periodic facility inspections confirming ongoing GMP compliance, and enforcement actions for non-compliance ranging from warning letters requiring corrective actions to product recalls, facility closure, and criminal prosecution for serious violations endangering public health.


International Standards and Best Practices Framework

International Bottled Water Association (IBWA) Model Code of Practice represents industry-leading standards developed through collaboration among major bottled water producers, technical experts, and regulatory authorities establishing comprehensive framework for manufacturing excellence. IBWA Model Code addresses water source selection and protection including geological surveys, source monitoring, protection zones preventing contamination, and sustainability management ensuring long-term availability; production facility design emphasizing hygienic construction, process flow preventing cross-contamination, equipment specifications with food-grade materials and effective cleaning systems, and environmental controls managing air quality, temperature, humidity in critical areas; HACCP (Hazard Analysis Critical Control Point) implementation systematically identifying biological, chemical, and physical hazards through process analysis, establishing critical control points where hazards prevented or controlled, defining critical limits for each control point, implementing monitoring procedures verifying control, and establishing corrective actions when deviations occur; quality assurance programs including comprehensive testing covering microbiological, chemical, and physical parameters at specified frequencies, laboratory accreditation ensuring analytical competence, statistical process control identifying trends and variations, and product release procedures confirming compliance before distribution; and personnel training ensuring employees understand hygiene requirements, production procedures, quality standards, and their role in maintaining product safety and quality.[5] Compliance with IBWA Model Code demonstrates commitment to excellence, facilitates export to markets recognizing IBWA standards, and provides competitive advantage positioning products as premium quality meeting international expectations.


Codex Alimentarius Commission (joint FAO/WHO program) develops internationally recognized food standards including CODEX STAN 108-1981 Standard for Natural Mineral Waters defining natural mineral waters as microbiologically wholesome water originating in underground water table or deposit, emerging from spring tapped at one or more natural or bore exits, characterized by content of certain mineral salts and their relative proportions and presence of trace elements or other constituents, and having constant composition and stable characteristics. Standard establishes principles distinguishing natural mineral water from other drinking waters including origin from protected underground source preventing contamination, natural mineral composition without artificial addition (though removal of certain constituents like iron, manganese, sulfur compounds permitted), microbiological purity at source requiring no disinfection under normal circumstances, and stable physico-chemical characteristics at source. Codex Standard permits only specified treatments that do not fundamentally change composition including separation of unstable constituents (iron, manganese, sulfur), separation by filtration or decantation of certain undesirable constituents (arsenic, fluoride), total or partial elimination of free carbon dioxide, and addition of carbon dioxide. Prohibited treatments include addition of mineral salts, disinfection treatments unless exceptional microbiological issues require them with disclosure on label, and any treatment modifying essential characteristics distinguishing natural mineral water from ordinary drinking water.[8] Compliance with Codex standards facilitates international trade as many countries reference Codex in national regulations and recognize compliance as meeting minimum safety and quality requirements.


United States Food and Drug Administration (FDA) regulations Title 21 CFR Part 165.110 Bottled Water establish comprehensive framework governing bottled water in US market providing benchmark for international best practices. FDA regulations classify bottled water types including mineral water (containing not less than 250 ppm TDS from source prior to treatment), spring water (collected at point where water flows naturally to earth's surface or through bore hole tapping underground source), purified water (produced by distillation, deionization, reverse osmosis, or other suitable processes and meeting US Pharmacopeia definition), sparkling water (containing carbon dioxide), and artesian water (from well tapping confined aquifer with water level above aquifer top). Quality standards reference EPA (Environmental Protection Agency) National Primary Drinking Water Regulations establishing maximum contaminant levels (MCLs) for numerous parameters with bottled water required to be as safe as tap water and often held to stricter standards.[9] Current Good Manufacturing Practice (CGMP) requirements mandate facilities employ sanitary design and construction, implement process controls ensuring consistent quality, conduct quality control operations including testing programs, maintain records documenting compliance, and employ trained personnel with hygiene qualifications. Labeling regulations require identity statement describing water type, net quantity statement, manufacturer or distributor name and address, ingredient listing including added substances like carbonation or flavoring, and optional nutrition facts panel showing mineral content if significant. FDA conducts inspections verifying CGMP compliance, analyzes product samples testing safety and quality, and takes enforcement actions including warning letters, product detention or seizure, and facility closure for serious violations protecting consumer health and safety.



International Standards Comparison Matrix:




IBWA Model Code of Practice:
• Scope: Voluntary industry standards exceeding regulatory minimums[5]
• HACCP requirement: Mandatory systematic hazard analysis and control
• Testing frequency: More stringent than many regulatory requirements
• Source protection: Comprehensive protection zone requirements
• Quality systems: ISO 9001 quality management system recommended
• Personnel training: Documented training programs for all staff
• Third-party audit: Annual IBWA audits for member certification
• Market recognition: Premium positioning for IBWA certified products
• Indonesian relevance: Benchmark for premium producers and exports
• Compliance costs: USD 5,000-15,000 annual membership and audit fees


Codex Alimentarius STAN 108-1981:
• Scope: International standard for natural mineral waters[8]
• Source definition: Underground origin with natural protection
• Treatment limits: Only specified treatments preserving natural characteristics
• Composition: Constant mineral composition without artificial addition
• Microbiological: Natural purity at source, no routine disinfection
• Labeling: Disclosure of source, analysis, any treatments applied
• Trade facilitation: Widely recognized in international commerce
• Indonesian alignment: SNI 3553 largely harmonized with Codex principles
• Export advantage: Codex compliance supports market access
• Recognition: Over 180 countries reference Codex standards


US FDA Regulations (21 CFR 165.110):
• Scope: Comprehensive US bottled water regulations[9]
• Quality standards: Reference EPA drinking water MCLs with additional requirements
• CGMP: Detailed current good manufacturing practice requirements
• Testing: Specified frequencies and methods for contaminant monitoring
• Labeling: Identity, net quantity, manufacturer, ingredients, nutrition facts
• Categories: Mineral, spring, purified, artesian, sparkling defined
• Enforcement: Inspections, sampling, warning letters, product detention
• Market access: Compliance required for US export
• Indonesian producers: Reference for premium quality and export preparation
• Standards level: Generally stricter than many international requirements


European Directive 2009/54/EC:
• Scope: EU natural mineral water directive
• Recognition: Member states must approve sources meeting criteria
• Characteristics: Mineral content, constant composition, natural purity
• Treatment limits: More restrictive than Codex, limited treatments permitted
• Microbiological: Emphasis on natural purity without treatment
• Labeling: Comprehensive disclosure requirements including analysis
• Market protection: "Natural mineral water" term legally protected in EU
• Quality reputation: EU mineral waters considered premium globally
• Indonesian relevance: Benchmark for premium natural mineral water
• Export potential: EU market access requires directive compliance


ISO Standards for AMDK Industry:
• ISO 9001: Quality management system standard
• ISO 14001: Environmental management system standard
• ISO 17025: Testing laboratory accreditation standard (mandatory Indonesia)
• ISO 22000: Food safety management system standard
• ISO 45001: Occupational health and safety management standard
• Application: Voluntary but increasingly expected for premium brands
• Benefits: Systematic management, continuous improvement, market credibility
• Certification: Third-party audit by accredited certification bodies
• Costs: IDR 50-200 million initial certification, IDR 20-80 million annual surveillance
• ROI: Enhanced efficiency, reduced defects, premium pricing, export facilitation



ISO (International Organization for Standardization) management system standards provide frameworks for systematic management of quality, environmental, food safety, and occupational health applicable to AMDK industry. ISO 9001 Quality Management System establishes requirements for documented processes, management commitment, resource provision, product realization with planning and control, measurement and monitoring, and continual improvement through corrective and preventive actions, enabling organizations systematically manage quality ensuring consistent products meeting customer and regulatory requirements. ISO 22000 Food Safety Management System integrates HACCP principles with prerequisite programs and management system elements specifically designed for food industry including bottled water, requiring systematic hazard analysis identifying biological, chemical, physical hazards, establishment of control measures at critical points, monitoring procedures verifying effectiveness, and emergency preparedness addressing potential contamination events. ISO 17025 Testing Laboratory Accreditation establishes requirements for laboratory competence including technical capabilities, appropriate equipment with calibration and maintenance, validated test methods, quality control procedures ensuring result accuracy, personnel competence with training records, and impartial operations free from commercial pressure, with accreditation by national authorities (KAN - Komite Akreditasi Nasional in Indonesia) providing independent verification of laboratory capabilities.[2] Implementation of ISO management systems demonstrates professional management practices, facilitates continuous improvement through systematic review and action, supports regulatory compliance through documented processes and records, enhances customer confidence through third-party certification, and provides competitive advantages particularly for premium segments and export markets valuing certified quality and safety management systems. Certification requires third-party audit by accredited certification bodies verifying conformance with standard requirements, with initial certification followed by annual surveillance audits and triennial recertification maintaining certificate validity.


Production Technologies and Treatment Processes

AMDK production technology selection depends on water source characteristics, target product positioning, quality requirements, production scale, and investment considerations with treatment process complexity ranging from minimal intervention for premium natural mineral springs to comprehensive multi-barrier treatment for municipal sources or brackish water. Natural mineral water from protected springs typically requires only basic treatment including coarse filtration removing suspended particles above 5-10 microns using sand filters or cartridge filters while preserving natural mineral composition, iron and manganese removal through aeration and filtration if these minerals present at levels causing color or taste issues, and ozonation or UV disinfection providing final microbiological safety barrier without residual chemicals affecting taste, with treatment objective preserving natural water characteristics while ensuring consistent safety and quality.[1] Conversely, demineralized water production from variable quality sources employs extensive treatment including pretreatment (coagulation, sedimentation, multimedia filtration removing turbidity and suspended solids), reverse osmosis utilizing semi-permeable membranes rejecting 95-99% of dissolved salts and minerals, post-treatment (carbon filtration removing any residual organics, UV disinfection ensuring microbiological safety, ozonation providing residual disinfection), and optionally remineralization adding controlled amounts of minerals (calcium, magnesium, potassium) achieving desired TDS and taste profile.


Reverse osmosis (RO) represents dominant technology for demineralized water production utilizing semi-permeable membranes separating pure water from dissolved salts, minerals, and contaminants under applied pressure. RO process begins with feed water pretreatment removing suspended solids, scaling compounds, and chlorine protecting membranes from fouling and damage through multimedia filtration, water softening if hardness high, activated carbon filtration removing chlorine and organics, and antiscalant dosing preventing mineral precipitation on membrane surfaces. High-pressure pumps (10-25 bar for brackish water, 50-80 bar for seawater) drive water through membrane modules containing spiral-wound or hollow-fiber membranes with microscopic pores (0.0001-0.001 microns) passing water molecules while rejecting dissolved solids, producing permeate (purified water) typically containing <10 mg/L TDS and concentrate (brine) containing rejected minerals requiring proper disposal.[10] RO system performance depends on feed water quality, membrane type, operating pressure, temperature, and recovery rate (percentage of feed converted to permeate) with typical recovery 50-75% for brackish groundwater and 35-50% for seawater due to higher salt concentrations limiting recovery without excessive scaling or concentration polarization. Modern RO systems employ energy recovery devices recapturing pressure from concentrate stream reducing energy consumption 30-50%, automated control systems monitoring performance and optimizing operations, and CIP (clean-in-place) systems periodically cleaning membranes removing accumulated foulants restoring flux and rejection.


Disinfection processes ensure microbiological safety preventing pathogen contamination while minimizing disinfection byproduct formation or residual chemical impacts on taste. Ozonation employs ozone gas (O₃) generated from oxygen providing powerful oxidation killing bacteria, viruses, and protozoa, oxidizing iron and manganese facilitating removal, destroying organic compounds reducing taste and odor issues, and leaving no chemical residuals as ozone decomposes to oxygen within minutes. Ozone application requires contact chambers providing 3-5 minutes exposure at concentrations 0.3-0.5 mg/L achieving microbiological inactivation, with ozone generators producing gas from pure oxygen or air through corona discharge or UV radiation. Ultraviolet (UV) disinfection employs UV-C radiation at 254 nanometer wavelength damaging microbial DNA preventing replication, achieving effective inactivation of bacteria, viruses, and protozoa without chemical addition or residual effects.[11] UV systems install quartz sleeves housing UV lamps in flow-through chambers ensuring all water receives adequate dosage (typically 40-80 mJ/cm²) for effective disinfection, with lamp monitoring ensuring adequate UV output and automatic shutdown if intensity falls below minimum effective dose. Combined ozone and UV treatment provides multi-barrier disinfection with complementary mechanisms, ozone providing residual effect during bottling operations while UV ensures final barrier before packaging, with both technologies avoiding chlorination which imparts chemical taste and generates disinfection byproducts (trihalomethanes) undesirable in bottled water.



AMDK Production Process Flow Examples:




Premium Natural Mineral Water (Minimal Treatment):
1. Source water: Protected spring or deep well (stable quality, TDS 100-500 mg/L)[1]
2. Coarse filtration: 20-50 micron cartridge removing particles
3. Fine filtration: 5-10 micron cartridge final particle removal
4. Aeration (if needed): Iron/manganese oxidation for removal
5. Iron/manganese filter: Greensand or similar media if applicable
6. Ozone contact: 0.3-0.5 mg/L for 3-5 minutes disinfection
7. Bottle filling: Aseptic filler, inert atmosphere (nitrogen/CO₂)
8. Capping/sealing: Automated capping, tamper-evident seals
9. Labeling: Product information, batch coding, date stamping
10. Quality check: In-line inspection, batch sampling
• Production capacity: 10,000-30,000 bottles/hour typical
• Water recovery: 98-99% (minimal waste)
• Energy consumption: 0.15-0.25 kWh/m³ produced
• Investment: IDR 50-80 billion for 10,000 bottles/hour facility


Demineralized Water (RO Treatment Process):
1. Feed water: Well, municipal, or surface source (TDS 200-2,000 mg/L typical)
2. Chemical pretreatment: Coagulation/flocculation if high turbidity
3. Multimedia filtration: Sand/anthracite removing suspended solids
4. Carbon filtration: Activated carbon removing chlorine, organics, odor
5. Water softening: Ion exchange if hardness >200 mg/L CaCO₃
6. Antiscalant dosing: Preventing membrane scaling
7. Cartridge filtration: 5 micron final protection for RO membranes
8. Reverse osmosis: High pressure (15-25 bar), 50-75% recovery[10]
9. Remineralization (optional): Calcium, magnesium addition to TDS 50-150 mg/L
10. Post-carbon: Polish filtration removing any tastes
11. UV disinfection: 40-80 mJ/cm² dose ensuring microbiological safety[11]
12. Ozone dosing: 0.2-0.4 mg/L residual disinfection during bottling
13. Bottle filling: Aseptic filler with automated controls
14. Capping/labeling: High-speed automated equipment
15. Packaging: Shrink wrap or cases for distribution
• Production capacity: 10,000-30,000 bottles/hour typical
• Water recovery: 50-75% (concentrate disposal required)
• Energy consumption: 0.5-0.8 kWh/m³ permeate produced
• Investment: IDR 80-150 billion for 10,000 bottles/hour facility


Desalination for Coastal Production (Seawater Source):
1. Seawater intake: Beach wells or offshore intake (TDS 35,000+ mg/L)
2. Pretreatment: Coagulation, sedimentation, multimedia filtration
3. Cartridge filtration: 5 micron nominal removing particles
4. High-pressure RO: 50-80 bar pressure, 35-50% recovery
5. Second-pass RO: Additional RO if very high purity required
6. Remineralization: Adding minerals achieving 50-200 mg/L TDS
7. pH adjustment: Limestone contactors or caustic addition
8. Carbon filtration: Final polish removing any residual tastes
9. UV + Ozone: Dual disinfection ensuring safety
10. Bottling and packaging: Standard aseptic filling
• Production capacity: 5,000-15,000 bottles/hour typical (smaller scale)
• Water recovery: 35-50% (high brine volume)
• Energy consumption: 2.5-4.5 kWh/m³ (very energy intensive)
• Investment: IDR 100-200 billion for 10,000 bottles/hour
• Applications: Islands without freshwater, coastal resorts, export markets


Quality Control Testing Points:
• Source water: Daily turbidity, pH, temperature; weekly microbiology; monthly comprehensive[3]
• Post-filtration: Continuous turbidity, periodic pressure differential monitoring
• RO permeate: Continuous TDS, conductivity; daily microbiological
• Post-disinfection: Continuous ozone residual or UV intensity
• Final product: Hourly microbiological sampling, batch comprehensive analysis
• Packaged product: Random sampling, third-party laboratory confirmation
• Shelf-life: Periodic testing verifying stability through expiration
• Regulatory: Quarterly comprehensive 52-parameter testing per SNI requirements



Bottling and packaging operations employ aseptic technology maintaining microbiological quality achieved through treatment processes, preventing recontamination during filling, capping, and packaging operations. Aseptic filling systems employ sterile filling environment created through HEPA-filtered air maintaining positive pressure preventing ingress of airborne microorganisms, UV lamps providing continuous surface disinfection of critical areas, and automated filling nozzles contacting bottles only during filling minimizing contamination opportunities. Bottle handling begins with incoming bottle inspection removing defective bottles, bottle rinsing with sterile water or ozonated water removing any dust or particles from storage and transport, inversion and air jetting removing rinse water, and transfer to filling position under clean air curtain maintaining sterile environment.[12] Filling operates continuously or intermittently depending on line design, with volumetric or gravity filling ensuring accurate volume, filling under inert atmosphere (nitrogen or carbon dioxide) for products sensitive to oxygen, and immediate capping after filling minimizing exposure. Caps undergo sterilization through UV treatment, hydrogen peroxide spray followed by hot air drying, or ozonated water rinse before application, with cap application torque controlled ensuring proper seal without over-tightening causing damage or under-tightening permitting leakage. Bottle inspection post-filling verifies fill level accuracy, cap application integrity, and absence of foreign materials before labeling, with reject systems automatically removing non-compliant bottles. Final packaging includes batch coding with production date and time enabling traceability, shrink wrapping or case packing for distribution protection, and palletization for warehouse storage and transport.


Market Structure, Investment Requirements, and Business Considerations

Indonesian AMDK market demonstrates substantial scale estimated at IDR 35-40 trillion annual value (USD 2.1-2.4 billion at October 2025 exchange rate) with production volumes exceeding 30 billion liters annually representing per capita consumption approximately 115-120 liters/person/year, significantly below developed Asian markets (Thailand 250+ liters, South Korea 180 liters) indicating substantial growth potential as economic development continues and consumer awareness of water quality increases. Market growth rates average 8-12% annually driven by urbanization concentrating population in cities where piped water access limited or quality uncertain, rising middle class with increased disposable income prioritizing health and convenience, limited piped water coverage with only 20% population accessing PDAM services meeting quality standards, tourism growth supporting hotel and restaurant demand, and hot tropical climate creating consistent hydration demand year-round.[4] Market segmentation spans premium segment (15-20% volume share, 25-30% value share) dominated by natural mineral waters and imported brands commanding IDR 8,000-15,000 per liter retail pricing emphasizing source provenance, mineral content, and health benefits; mid-segment (30-35% volume, 35-40% value) consisting of remineralized waters from established national brands offering quality assurance at moderate pricing IDR 4,000-8,000 per liter; and economy segment (45-50% volume, 30-35% value) comprising basic demineralized water from regional and local brands targeting price-sensitive consumers at IDR 2,000-4,000 per liter with emphasis on safety and affordability over premium positioning.


Market concentration comprise of top 5 producers controlling approximately 65-70% market share though thousands of smaller producers serve local markets. PT Tirta Investama (Danone-Aqua brand) maintains market leadership with estimated 35-40% share through extensive distribution reaching 3+ million retail outlets, strong brand recognition from decades as market pioneer, diverse product portfolio spanning multiple sizes and formats, and continuous investment in source development, production capacity, and marketing. Coca-Cola Amatil Indonesia produces Ades brand capturing 10-12% share leveraging extensive Coca-Cola distribution network, manufacturing efficiency from global supply chain integration, and marketing synergies with beverage portfolio. Nestle Waters markets Aqua Reflections (licensed from Danone) and Le Minerale capturing 8-10% share through strong brand equity, quality positioning, and retail relationships.[4] Otsuka Pharmaceutical manufactures Pocari Sweat isotonic beverage and related water products achieving 3-5% share, while Wings Group produces Vit brand targeting value segments with 3-4% share. Remaining 25-30% share fragments across hundreds of regional brands serving provincial markets and local producers supplying district-level demand, with market entry barriers including capital investment requirements, distribution network development, brand building investments, and regulatory compliance costs limiting consolidation though competition remains intense across all segments.


Investment requirements for AMDK production facilities vary substantially with scale, source type, product positioning, and automation level. Small-scale operation producing 2,000-5,000 bottles/hour serving local district markets requires minimum investment IDR 15-30 billion (USD 900,000-1.8 million) including basic treatment system (multimedia filtration, carbon, UV, simple bottling line), manual or semi-automated bottling equipment, basic quality laboratory with essential testing equipment, small warehouse and office facilities, and one delivery truck for local distribution. Mid-scale facility producing 10,000-15,000 bottles/hour targeting provincial or multi-district markets requires investment IDR 50-100 billion (USD 3.0-6.0 million) including comprehensive treatment (RO system if demineralized, advanced filtration if mineral source), fully automated high-speed bottling line with aseptic filling and integrated capping/labeling, equipped quality laboratory meeting ISO 17025 requirements, warehouse with cold storage capacity, office and staff facilities, and distribution fleet with multiple trucks.[13] Large-scale integrated operation producing 30,000+ bottles/hour serving national market demands investment IDR 150-300 billion (USD 9-18 million) including state-of-art treatment with redundancy and automation, multiple high-speed bottling lines offering format flexibility, advanced quality laboratory with comprehensive analytical capability, extensive warehouse and logistics facilities, corporate offices and technical center, and investment in distribution infrastructure partnering with logistics providers achieving nationwide reach. Additional working capital requirements fund inventory (raw materials, packaging, finished goods), accounts receivable from distributors typically offering 30-60 day payment terms, marketing and promotional expenses, and operational reserves covering 2-3 months operating expenses providing financial stability.



AMDK Business Financial Analysis Example (Mid-Scale Operation):




Facility Specifications:
• Production capacity: 10,000 bottles/hour (330mL bottles typical)
• Operating schedule: 20 hours/day, 6 days/week, 50 weeks/year
• Annual production: 60 million bottles (19.8 million liters)
• Capacity utilization: 75% first year ramping to 90% year 5
• Product type: Demineralized water, remineralized to TDS 80 mg/L
• Market positioning: Mid-segment, provincial brand
• Distribution: Wholesale to distributors, retail chains, hotels/restaurants
• Location: Secondary city with population 500,000-1,000,000


Capital Investment Breakdown:
Total Project Investment: IDR 80 billion (USD 4.85 million)[13]
• Land and building: IDR 15 billion (civil works, utilities, landscaping)
• Water treatment system: IDR 18 billion (RO, filtration, disinfection, remineralization)
• Bottling and packaging line: IDR 22 billion (automated filler, capper, labeler, inspector)
• Quality laboratory: IDR 5 billion (testing equipment, ISO 17025 setup)
• Utilities and support: IDR 8 billion (power, water, compressed air, chillers)
• Office and staff facilities: IDR 3 billion (offices, changing rooms, canteen)
• Initial inventory: IDR 4 billion (bottles, caps, labels, chemicals)
• Licensing and permits: IDR 2 billion (BPOM, industry permits, certifications)
• Contingency reserve: IDR 3 billion (5% buffer for unforeseen costs)


Operating Expenditure (Annual, Steady State 90% Capacity):
Total Annual OPEX: IDR 48.6 billion (USD 2.95 million)
• Raw materials (bottles, caps, labels): IDR 18.9 billion (39% of OPEX)
• Utilities (electricity, water): IDR 8.1 billion (17%)
• Labor (60 employees): IDR 7.2 billion (15%)
• Chemicals (treatment, cleaning): IDR 3.6 billion (7%)
• Maintenance and repairs: IDR 3.2 billion (7%)
• Quality testing (laboratory): IDR 1.8 billion (4%)
• Transportation and logistics: IDR 2.4 billion (5%)
• Marketing and promotion: IDR 1.8 billion (4%)
• Administration and overhead: IDR 1.6 billion (3%)
• Unit production cost: IDR 900 per bottle (USD 0.055 per bottle)


Revenue Structure (Mid-Segment Positioning):
• Wholesale price: IDR 1,800 per bottle (factory gate to distributor)
• Distributor margin: IDR 600-800 per bottle (33-44%)
• Retail price: IDR 2,500-3,000 per bottle (USD 0.15-0.18)
• Annual revenue (90% capacity): IDR 97.2 billion (USD 5.89 million)
• Gross profit: IDR 48.6 billion (50% gross margin)
• EBITDA: IDR 38.0 billion (39% margin after SG&A)
• Payback period: 3.5-4.5 years depending on ramp-up
• ROI: 22-28% internal rate of return over 10-year horizon


Market Penetration Strategy:
• Year 1: Local city and surrounding districts (75% capacity)
• Year 2-3: Expand to province-wide distribution (85% capacity)
• Year 4-5: Regional presence in 2-3 provinces (90% capacity)
• Distribution channels: Wholesalers (40%), modern retail (30%), institutions (20%), direct (10%)
• Brand building: Local marketing, sponsorships, sampling programs
• Quality differentiation: Emphasize ISO certification, testing transparency
• Pricing strategy: Mid-segment value proposition, quality at moderate premium
• Growth options: Additional production lines, product diversification, geographic expansion



Business success factors for AMDK operations include securing reliable water source through groundwater rights, spring acquisition, or municipal supply contracts ensuring adequate volume, consistent quality, and sustainable long-term access; achieving production efficiency through equipment selection balancing automation reducing labor while maintaining flexibility for format changes, preventive maintenance minimizing downtime from equipment failures, and energy efficiency reducing utility costs representing 15-20% of operating expenses; building effective distribution networks partnering with experienced distributors accessing retail outlets, negotiating favorable terms with modern retail chains (Indomaret, Alfamart, hypermarkets), and serving institutional customers (hotels, restaurants, offices) providing stable demand; establishing brand recognition through marketing investments building consumer awareness and preference, consistent quality ensuring customer satisfaction and repeat purchase, and differentiated positioning whether premium natural source, mid-segment quality value, or economy affordability; maintaining regulatory compliance through proper documentation, regular testing, timely renewal of permits and registrations, and proactive engagement with BPOM, Ministry of Industry, and environmental authorities; and managing working capital ensuring adequate cash flow supporting 30-60 day receivables from distributors, maintaining inventory buffers addressing demand fluctuations, and negotiating favorable payment terms with suppliers balancing cash flow needs.[4]


Frequently Asked Questions (FAQ) - Indonesian AMDK Industry


Comprehensive FAQ on AMDK Production, Regulation, and Business Operations:




1. What exactly is AMDK and how does it differ from regular water?
AMDK (Air Minum Dalam Kemasan) is bottled drinking water packaged in sealed containers, processed to meet drinking water quality standards per SNI 3553:2023 (mineral water) or SNI 6241:2015 (demineralized water), safe for direct consumption without boiling, and distributed commercially.[1] It differs from tap water by consistent quality assurance through controlled sourcing and treatment, sealed packaging preventing contamination, convenience for portable consumption, and regulatory oversight through BPOM ensuring safety. AMDK encompasses various types from natural mineral water exploiting underground springs to purified water produced through reverse osmosis, each meeting specific quality standards validated through regular laboratory testing.


2. What are main water source types used for AMDK production in Indonesia?
Indonesian AMDK utilizes four primary sources: (1) Natural mineral springs from protected underground aquifers providing naturally filtered water with stable mineral composition, commanding premium pricing but requiring geological surveys and source protection investments; (2) Deep groundwater wells (50-300m) accessing confined aquifers offering reliable supply and manageable quality for both mineral and demineralized products; (3) Shallow wells (10-50m) accessing unconfined aquifers suitable primarily for demineralized water after RO treatment; (4) Municipal water supply serving as base for RO purification particularly in urban areas.[7] Desalination from seawater represents emerging option for coastal regions without freshwater alternatives though energy-intensive limiting economic viability to specific applications.


3. What is difference between Air Mineral, Air Demineral, and Air Mineral Buatan?
Air Mineral (SNI 3553:2023) is natural mineral water from protected underground source containing naturally occurring minerals (TDS typically 50-1,500 mg/L), requiring minimal treatment preserving natural characteristics, and commanding premium pricing IDR 8,000-15,000/liter emphasizing provenance and health benefits.[3] Air Demineral (SNI 6241:2015) is purified water from any source treated via RO, distillation, or deionization removing minerals (TDS <10 mg/L), targeting economy segment at IDR 2,000-4,000/liter emphasizing purity and affordability.[2] Air Mineral Buatan is remineralized water starting with demineralized base with controlled mineral addition achieving TDS 50-250 mg/L, positioned mid-segment IDR 4,000-8,000/liter balancing quality and value, though labeling must disclose artificial mineral addition distinguishing from natural mineral water.


4. What regulatory approvals and permits required to produce AMDK?
AMDK production requires: (1) Company registration (PT or CV) with Ministry of Law, (2) Factory Operation License (IUI) from district investment board, (3) BPOM Product Registration obtaining ML number through dossier submission, facility inspection, and compliance demonstration valid 5 years, (4) SIPA water abstraction permit from Ministry of Environment for groundwater or spring sources, (5) Environmental permit (AMDAL or UKL-UPL) based on production scale, (6) Halal certification from MUI though optional is market standard, (7) ISO 17025 laboratory accreditation for quality testing or contract with accredited facility, and (8) SNI Product Certification from Ministry of Industry demonstrating standard compliance.[6] Total permitting timeline 6-12 months with costs IDR 50-150 million depending on scale and complexity.


5. What are capital investment requirements for AMDK production facility?
Investment scales with production capacity: Small-scale (2,000-5,000 bottles/hour) requires IDR 15-30 billion including basic treatment, semi-automated bottling, simple laboratory, suitable for local district markets. Mid-scale (10,000-15,000 bottles/hour) requires IDR 50-100 billion including RO treatment system, fully automated bottling line, ISO 17025 laboratory, warehouse facilities, serving provincial markets. Large-scale (30,000+ bottles/hour) demands IDR 150-300 billion including state-of-art treatment with redundancy, multiple high-speed lines, advanced laboratory, extensive warehousing, nationwide distribution infrastructure.[13] Additional working capital 20-30% of capex funds inventory, receivables, and operational reserves. Premium natural mineral water projects require additional IDR 10-30 billion source development including geological surveys, deep drilling, and protection infrastructure.


6. What quality testing required and how frequently?
SNI 3553:2023 and BPOM regulations mandate comprehensive testing: (1) Daily monitoring of operational parameters (turbidity, pH, temperature, chlorine residual), (2) Daily microbiological testing (total coliform, E. coli, heterotrophic plate count) before product release, (3) Weekly testing of critical parameters (iron, manganese, selected chemicals), (4) Monthly comprehensive chemical analysis covering regulated parameters (heavy metals, nitrates, fluoride, major ions), (5) Quarterly full 52-parameter testing including trace contaminants and radionuclides.[3] Testing must be conducted by ISO 17025 accredited laboratory either in-house or contracted. Retain samples from each production batch minimum 6 months enabling investigation if quality issues arise. Documentation requirements include test certificates, batch production records, and corrective action reports available for regulatory inspection.


7. How does reverse osmosis (RO) work and when is it needed?
Reverse osmosis employs semi-permeable membranes with microscopic pores (0.0001-0.001 microns) rejecting 95-99% of dissolved salts, minerals, and contaminants while passing pure water under applied pressure (15-25 bar brackish water, 50-80 bar seawater). RO needed when: (1) Source water contains high TDS (>500 mg/L) or specific contaminants (nitrates, fluoride, hardness) exceeding standards, (2) Producing demineralized water for economy segment regardless of source quality, (3) Source quality variable requiring consistent treatment, (4) Desalinating seawater or brackish water for coastal locations without freshwater.[10] RO produces permeate (purified water) with TDS <10 mg/L suitable for bottling and concentrate (brine) requiring disposal, with typical recovery 50-75% meaning 1.3-2.0 liters feed required per liter product. Investment IDR 12-25 billion for 10 m³/hour RO system with operational costs dominated by energy consumption 0.5-0.8 kWh/m³ and periodic membrane replacement every 3-5 years.


8. What is difference between natural mineral water and remineralized water regarding health benefits?
Natural mineral water (Air Mineral) contains minerals naturally present in source water from geological formations, with composition reflecting aquifer geology creating unique mineral signatures. Minerals in natural waters exist in dissolved ionic forms potentially more bioavailable, with some evidence suggesting better absorption compared to added minerals, though scientific consensus remains limited. Remineralized water (Air Mineral Buatan) adds minerals (typically calcium, magnesium, potassium) to demineralized base achieving desired TDS and taste. Both provide hydration as primary benefit, with mineral content in either case representing modest dietary contribution compared to food sources. Marketing emphasizes natural mineral provenance as premium attribute though regulations prohibit making specific health claims without scientific substantiation approved by BPOM.[6] Consumer choice often driven more by taste preferences, brand trust, and price than demonstrable health differences between natural and remineralized products meeting SNI standards.


9. How long is shelf life of AMDK and what determines expiration date?
AMDK shelf life typically 12-24 months from production date depending on packaging materials, storage conditions, and preservative residual (ozone or chlorine). Expiration determined through accelerated stability testing exposing samples to elevated temperatures monitoring quality parameters (microbiological safety, chemical stability, packaging integrity, organoleptic properties) over time extrapolating to ambient storage conditions. Glass bottles provide best protection with minimal shelf life limitations, PET bottles standard in Indonesia demonstrate good stability 18-24 months though potential for acetaldehyde migration from plastic affecting taste in some applications, while polycarbonate or multilayer pouches may have shorter shelf life. Storage conditions significantly impact shelf life with cool storage (below 25°C) and protection from direct sunlight extending quality preservation, while hot warehouses or vehicle transport in tropical climate accelerate degradation. Properly stored AMDK often remains safe and acceptable beyond expiration though manufacturers set conservative dates ensuring quality throughout distribution chains and consumer possession.


10. What are competitive positioning strategies for new AMDK brand entering market?
Market entry strategies include: (1) Premium natural mineral positioning emphasizing unique source provenance, mineral composition health story, sustainable practices, targeting affluent urban consumers and export markets requiring IDR 10-15 billion marketing investment building brand equity; (2) Regional brand strategy focusing on strong provincial presence, local identity and pride, partnership with regional distributors, competitive pricing IDR 3,000-5,000/liter mid-segment, leveraging lower marketing costs and logistics advantages serving concentrated territory; (3) Private label/contract manufacturing for modern retail chains (Alfamart, Indomaret house brands), hotel chains requiring branded water, or corporations needing promotional products, reducing brand building requirements while ensuring volume; (4) Niche specialization including alkaline water, oxygen-enhanced, sports hydration, or specific health positioning targeting specific consumer segments willing to pay premium for perceived benefits; (5) Value positioning competing on price in economy segment requires operational efficiency, simplified packaging, minimal marketing, and efficient distribution achieving IDR 2,000-3,000 retail price.[4] Success requires differentiation (cannot simply duplicate dominant brands), realistic assessment of distribution challenges (major brands control 60%+ retail access), and sufficient capital (minimum 3-year runway to achieve breakeven given slow brand building and distribution development in competitive market).



Conclusions and Strategic Recommendations

Indonesian AMDK industry represents substantial and growing sector addressing critical water access and quality challenges affecting majority of population lacking reliable piped water services, with market size estimated IDR 35-40 trillion annually (USD 2.1-2.4 billion) growing 8-12% driven by urbanization, rising middle class, and limited municipal water coverage. Industry encompasses diverse product categories from premium natural mineral waters commanding IDR 8,000-15,000 per liter retail pricing exploiting protected underground springs to economy demineralized waters at IDR 2,000-4,000 per liter produced from various sources through reverse osmosis treatment, with mid-segment remineralized products balancing quality and value at IDR 4,000-8,000 per liter.[4] Comprehensive regulatory framework established through Ministry of Industry Regulation 96/2011, mandatory National Standards (SNI 3553:2023 for mineral water, SNI 6241:2015 for demineralized water), Ministry of Health drinking water quality standards, and BPOM product registration ensuring safety, quality consistency, and consumer protection while aligning with international standards including Codex Alimentarius, FDA regulations, European Directive, and IBWA Model Code facilitating export opportunities and technology transfer.


Strategic considerations for prospective AMDK manufacturers include careful water source selection balancing quality, reliability, regulatory compliance, and long-term sustainability with premium natural springs offering brand positioning advantages but requiring substantial development investment and source protection measures, deep groundwater providing reliable mid-tier option with manageable treatment requirements and location flexibility, and municipal sources suitable for demineralized economy products emphasizing purification process excellence; production technology investment scaled appropriately to target market with small-scale operations (2,000-5,000 bottles/hour) requiring IDR 15-30 billion serving local markets, mid-scale facilities (10,000-15,000 bottles/hour) demanding IDR 50-100 billion for provincial coverage, and large-scale plants (30,000+ bottles/hour) necessitating IDR 150-300 billion achieving national distribution;[13] quality management systems implementing HACCP, ISO standards, comprehensive testing programs, and documentation practices ensuring regulatory compliance, consumer safety, and operational excellence; and distribution network development through distributor partnerships, modern retail relationships, institutional sales, and logistics infrastructure determining market access and business viability perhaps even more than production capacity or product quality given competitive landscape dominated by established brands controlling retail access.


Future outlook for Indonesian AMDK sector remains positive with per capita consumption 115-120 liters annually significantly below developed Asian markets (Thailand 250+ liters, South Korea 180 liters) indicating substantial growth potential, economic development and rising incomes enabling consumers to prioritize health and convenience, limited prospects for dramatic piped water coverage expansion in near-term maintaining bottled water demand, climate change potentially increasing water scarcity in certain regions elevating packaged water importance, and regulatory evolution including sustainability initiatives addressing plastic waste through circular economy approaches (bottle deposit schemes, recycled content requirements, reusable format promotion) creating both challenges and opportunities for producers. Industry consolidation likely continues as leading brands leverage scale advantages, distribution networks, and marketing capabilities though regional and local producers will maintain presence serving specific geographic markets or niche segments where localization advantages, community relationships, or specialized products create competitive positions. Success requires differentiated value propositions whether premium natural source provenance, trusted brand quality assurance, value pricing competitiveness, or specialized functional benefits, supported by operational excellence, regulatory compliance, quality consistency, and effective distribution achieving sustainable profitability in dynamic, competitive, but ultimately attractive market addressing fundamental human need for safe, convenient drinking water.



References and Technical Resources

1. Hello Sehat. Kenali Proses Produksi Air Mineral dalam Kemasan - Comprehensive Overview of AMDK Production Process.
https://hellosehat.com/nutrisi/fakta-gizi/proses-produksi-air-mineral-dalam-kemasan/


2. PT. Saraswanti Anugrah Sadhana. SNI Air Minum Dalam Kemasan: Jaminan Keamanan dan Mutu - National Standards Explanation.
https://ags.saraswanti.com/sni-air-minum-dalam-kemasan-jaminan-keamanan-dan-mutu-air-minum-dalam-kemasan/


3. Scribd Document Repository. SNI 3553:2023 Air Mineral - Latest Mineral Water Standard.
https://id.scribd.com/document/891258962/27-SNI-3553-2023-Air-Mineral


4. Firenze University Press. Bottled Water Industry: A Quantitative Study Approach - Academic Research on Market Structure.
https://oajournals.fupress.net/index.php/rea/article/download/13095/12355/20428


5. International Bottled Water Association (IBWA). Bottled Water Code of Practice - Industry Leading Standards.
https://bottledwater.org/wp-content/uploads/attachments/IBWA_Bottled_Water_Code_of_Practice.pdf


6. BPOM RI. Penjelasan Badan POM RI tentang Air Mineral - Regulatory Authority Statement on Mineral Water Quality.
https://www.pom.go.id/penjelasan-publik/penjelasan-badan-pom-ri-tentang-air-mineral-yang-diberitakan-tidak-aman-dikonsumsi-karena-mengandung-zat-besi


7. Ministry of Industry (Kemenperin). Peraturan Menteri Perindustrian Nomor 47 Tahun 2020 tentang Air Mineral.
https://bbkkp.kemenperin.go.id/storage/files/page/2020-Permenperin-Nomor-47-Tahun-2020-Air-Mineral.pdf


8. FAO/WHO Codex Alimentarius. CODEX STAN 108-1981 - Standard for Natural Mineral Waters.
https://www.fao.org/fao-who-codexalimentarius/codex-texts/list-standards/en/


9. University of California Food Safety. Bottled Water Regulation and the FDA - US Regulatory Framework.
https://ucfoodsafety.ucdavis.edu/sites/g/files/dgvnsk7366/files/inline-files/141578.pdf


10. SlideShare Educational Resource. SNI 01-3553-2006 Air Minum Dalam Kemasan - Previous Standard Reference for RO Treatment.
https://www.slideshare.net/slideshow/sni-01-35532006air-minum-dalam-kemasan/37229992


11. US Environmental Protection Agency (EPA). Water Health Series: Bottled Water Basics - Disinfection Technologies Comparative Analysis.
https://www.epa.gov/sites/default/files/2015-11/documents/2005_09_14_faq_fs_healthseries_bottledwater.pdf


12. Dubai Food Safety Conference. A Bottled Water Plant Operation: A Key Issue on Quality - Operational Best Practices for Aseptic Filling.
https://www.foodsafetydubai.com/resources/contentfiles/prev-conference/abottledwaterplantoperation_akeyissueonsafetyandquality.pdf


13. Scribd Document Repository. Standar SNI AMDK di Indonesia - Comprehensive Standards Documentation and Investment Requirements.
https://id.scribd.com/document/621021603/Sertifikasi-AMDK


14. Government Regulation Repository. Peraturan Menteri Perindustrian Nomor 62 Tahun 2024 - Latest Industrial Regulations.
https://peraturan.bpk.go.id/Download/368635/2024pmperin062.pdf


15. World Health Organization (WHO). Guidelines for Drinking-water Quality - International Health Standards Applicable to AMDK.
https://www.who.int/publications/i/item/9789241549950




SUPRA International


AMDK Industry Technical Advisory and Implementation Services

SUPRA International provides comprehensive technical advisory and implementation support services for bottled drinking water (AMDK) industry including feasibility studies evaluating water sources, treatment technologies, and market positioning; regulatory compliance assistance navigating BPOM product registration, Ministry of Industry permits, SNI certification, halal certification, and environmental licensing; treatment system design and engineering for reverse osmosis, filtration, disinfection, and remineralization processes optimized for Indonesian conditions; quality management system development implementing HACCP, ISO standards, laboratory setup and accreditation; production facility design addressing GMP requirements, process flow, equipment selection, and utility systems; and operational support including staff training, troubleshooting, process optimization, and continuous improvement programs for established manufacturers, new market entrants, and investors evaluating AMDK opportunities across Indonesian provinces and specialized segments.


Planning AMDK production facility or seeking regulatory compliance support?
Contact SUPRA International to discuss feasibility assessment, water source evaluation, treatment technology selection, regulatory compliance roadmap, quality system implementation, facility design and engineering, equipment procurement support, and complete project development from concept through operations for Indonesian bottled drinking water business initiatives



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If you face challenges in water, waste, or energy, whether it is system reliability, regulatory compliance, efficiency, or cost control, SUPRA is here to support you. When you connect with us, our experts will have a detailed discussion to understand your specific needs and determine which phase of the full-lifecycle delivery model fits your project best.