Before you begin setting up a bottle/sachet water production factory here in Nigeria, you should first download the National Agency for Food and Drug Administration and Control (NAFDAC) Guidelines for Establishment of Packaged Water Plant in Nigeria and also, Guidelines for Registration of Food and Water on their website or any other online platform. The basic steps to get NAFDAC number for your factory produced bottle/sachet water in Nigeria, is contained in these guidelines. However, if after going through the guidelines, you are still not clear on any issue, it is best to visit the NAFDAC office nearest to you for better explanation of the guidelines and requirements needed for their approval and subsequent issuing of NAFDAC number for your produced bottle or sachet water.
Based on experience and a few research, below are the summary of a few steps they will advise you to take for a smooth application process.
Step 1: REGISTER YOUR BUSINESS WITH THE CAC
Get your business registered with the Corporate Affairs Commission (CAC) wherever you are in Nigeria. A Business Name Registration (Enterprise) might do, but Incorporation (Ltd) is ideal. You can register an Enterprise i.e. Business Name online yourself, however, the services of a lawyer, accountant or company secretary registered with the CAC is a must for Incorporation. Your CAC Certificate should be out in a week or two for Enterprises and maximum of sixty (60) days for company Incorporation. This gives your water production factory legal identity.
Step 2: REGISTER YOUR TRADEMARK
The next of the basic steps to get NAFDAC number for your factory produced bottle/sachet water in Nigeria is the processing of product trademark. With your CAC certificate, you go to the Federal Ministry of Industry, Trade and Investment to get your water product trademarked. The product could be the same as your full company name, similar to the water production factory name or a different name altogether e.g. Space-Tech Scientifique Water or Space-Tech Water or XYZ Water. What is important is that your company gets associated with the registered product trademark.
There are different trademark registration categories for respective products and sectors, hence choose the specific Class Specification of Goods/Services else you will have issues with the NAFDAC registration. Water products come under Class 32. As a result of verification procedures, your trademark certificate takes a bit of time to become ready, but a preliminary notification should be out within two (2) months if the trademark is uncontested.
Step 3: SETTING UP THE BOTTLE/SACHET WATER FACTORY
Stage A. PRE-PRODUCTION/ADVISORY INSPECTION
Say, you’ve picked out an ideal location to site your bottle/sachet water production factory and you want to rush everything through structure-wise. Well, before you start building or equipping the acquired space, it is best practice to apply for a Pre-Production/Advisory Inspection by NAFDAC to ascertain if the location meets the requirements for setting up a bottle/sachet water producing factory.
Yes, you’d visited NAFDAC office at the onset, and you’re better informed about the don’ts for site location. An onsite inspection allows NAFDAC inspectors give firsthand evaluation of the acceptability of your site in addition to technical advice about distance of your borehole to the septic tank, the direction flow of section units such as where your Cloak room, Raw Material store etc should be, as well as vital nuggets of other information.
You can skip this step if you know what you are doing but it is advisable you don’t as evidence of Pre-Production Inspection is required for the registration process.
Stage B. CONSTRUCTION AND EQUIPPING
Once your site is adequate, you can now rush through your building construction or demarcations as the case may be. The direction of flow of respective sections should be Cloakroom, Packaging material store, Raw material store, Production section, Finished products store, making sure there are insect-proof nets on all windows and the doors are self closing. If you are going to produce sachet and bottle water, two distinct sections should be provided for each product. Also remember to label all the equipment and rooms/areas accordingly, as well as provide adequate convenience rooms away from the production section(s) but easily accessible from there.
Where there is unavailability of municipal water, drill your borehole (150ft deep or more), run the plumbing, do a raw water laboratory analyses, install the water treatment plants and water producing equipment, making sure you follow all the regulatory guidelines specified, put the necessary safety equipment in place, test run the various setups and smile as you fix the few glitches that crop up. Still interested in setting up a water production factory?
Step 4: NAFDAC REGISTRATION
Stage A. BEFORE APPLICATION FOR PRODUCTION INSPECTION
Your water production factory is fully setup and all you need is for NAFDAC to come certify your production facility and bless you with the almighty NAFDAC number. Well, before you can apply for Production inspection, you’d need to have the following in place:
- Production staff, which must include a Production Manager with appropriate science-based qualifications and experience.
- Food Handlers Certificate for all your staff (production and non production), which is given by a hospital after general medical check-ups and laboratory tests to ascertain the health status and fitness of each personnel to handle food meant for public consumption.
- Evidence of retainership agreement between your factory and a medical facility for health related issues
- Evidence of recent fumigation of factory premises from a certified fumigation company as well as a partnership agreement for fumigation purposes between your factory and the company.
- Comprehensive laboratory analyses report for your raw water i.e. borehole or municipal water before undergoing treatment and your treated water (after treatment from your installed water treatment plant). This should be done by a qualified Institute of Public Analyst of Nigeria (IPAN) laboratory.
- Quality assurance agreement between your factory and an IPAN laboratory for subsequent analyses of batches of produced sachet or bottle water, this is if you do not have an In-house Quality Assurance Department.
- Standard Operating Procedures (SOP) for production, Quality Control, in and out-premises sanitation, equipment maintenance, product distribution and recall, hygiene and others, written in appropriate format and signed by the Production Manager.
- Company organogram identifying key personnel, their names, designation and qualification.
- Letters of Appointment for your key personnel together with their letters of acceptance.
- Credentials of key personnel, particularly the Production Manager.
- Detailed flowchart of your factory’s water production process showing water source, treatment process and production steps.
- A list of all equipment, suppliers name and contact details.
- Geological survey of borehole where applicable showing terrain characteristic, depth of drill etc.
- Copies of detailed labels for intended bottle or sachet water products based on the trademark registered. The labels should show the name of product, full address/contact of factory, volume capacity, batch number, date of manufacture, expiration date and logo.
Copies of these documents together with the CAC certificate, proof of Trademark registration and respective evidence of statutory fee payment to NAFDAC (for production inspection of factory and laboratory analyses of produced water samples after inspection) are filed and submitted with the application for production inspection to the designated NAFDAC office in your state of residence.
Stage B. PRODUCTION INSPECTION BY NAFDAC INSPECTORS
Once you’ve submitted all the required documents to NAFDAC and they find no discrepancies or mistakes, a date is fixed for Production Inspection and you’ll get notified about it.
On the appointed date, be ready with your original documents and four copies of same documents for the inspectors and your production manager. Your production staff should be well acquainted with the respective SOPs and your water factory should be in prepared condition. The Production Manager is the main representative on this day as he/she will be the person to take the inspectors around and answer most of the questions especially the technical aspects. NAFDAC inspectors are generally friendly, but since they have a duty to safeguard public health and maintain strict standards, they might come out sounding harsh during their assessments and questioning.
They will verify the authenticity of the documents you filed by going through the original copies you’d made available. Then inspect your interior and labelled room areas for proper furnishing, fittings and equipping, your exterior surroundings, borehole and distance to septic tank, raw water source, water tanks and treatment plants, production equipment, production processes and SOPs.
If your facility and processes meets NAFDAC specifications, samples of your raw water, produced bottle water and sachet water are taken for analyses in NAFDAC’s laboratories. If the samples gotten from your bottle/sachet water factory pass NAFDAC laboratory tests, they’ll issue you a notification and you can expect your number within two months.
Whereby there are observed discrepancies in your facility, installations or production process, a Compliance Directive (CD) will be issued to you listing all the observed items that do not meet regulations and remedial action expected to be carried out. You are expected to resolve all issues listed in the CD and respond via a letter notifying NAFDAC about your actions as well as write an application for Re-inspection (with attendant payment of Production Re-inspection fees).
If your facility satisfies all requirements after re-inspection, samples of your raw water and treated water produced in the respective packs are then taken for laboratory analyses. In the event that the water samples, particularly the packaged treated water fails the NAFDAC laboratory tests, you will get notified and you’d have to troubleshoot the water treatment process in your facility, identify where the problem comes from (after another laboratory test by your IPAN laboratory partner) and fix your treatment process to satisfy all regulatory requirements. Until your water production facility meets all NAFDAC requirements, they will not issue you a number and you cannot produce for public consumption.
After you get your NAFDAC number and have started production, you must maintain required production standards at all times because occasionally, NAFDAC inspectors will come around unannounced to check on your water producing facility, and they will not hesitate to enforce disciplinary actions if your standards fall below regulations.
The above outline processes are a summary of the basic steps to get NAFDAC number for your factory produced bottle/sachet water in Nigeria.
Check out samples of cleaning and sanitation standard operating procedures (SOP) for sachet water production and packaging factories