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Somewhere in your plant today, a batch will fail a check and be written off. On the production report it will appear as a line of lost product and a number in riyals.
What the report will not show is the water. The water that grew the feed, the water that cleaned the line, the water that was desalinated, pumped and chilled so that the batch could exist at all, and is now leaving the building in a skip.
In Saudi Arabia that water has never been cheap. It is about to become visible.
The harvest the Kingdom chose to give up
In 1992 Saudi Arabia harvested more than four million tonnes of wheat and exported almost two and a half million, according to US Department of Agriculture data. For a desert state it was an extraordinary achievement, built on generous support prices and on water pumped from deep aquifers that had filled over many thousands of years and were not refilling.
Then the Kingdom did something very few countries have ever done. It decided that the water mattered more than the harvest. A government decree of 2008 phased out domestic wheat production by 2016. The US Department of Agriculture’s office in Riyadh recorded the reason plainly: “a strong concern over the depletion of the country’s scarce water reserves, as the wheat crop is 100 percent irrigated.” It called the policy “a drastic departure” from a strategy of self sufficiency pursued for decades.
It was not painless. Farmers, the USDA reported, had borrowed heavily to grow wheat, and lobbied for a reversal. When wheat did return in 2019, in a limited form, it returned for a water reason too. The government was cutting back alfalfa and other green fodder, and, as the USDA’s 2019 report put it, “wheat uses much less water than alfalfa.” Since November 2018 large fodder farms on the sedimentary shelf, explicitly including dairy companies growing their own feed, have been required to stop. According to the Ministry of Environment, Water and Agriculture’s account of a Saudi Water Week panel in July, the water used for fodder fell from 16.6 billion cubic metres to 6.5 billion between 2015 and 2025. The next steps are already scheduled: perennial fodder across the sedimentary shelf from 16 November this year, and domestic alfalfa from the 2027/2028 season.
That is the precedent every food manufacturer in the Kingdom should keep in view. When the state has had to choose between a food and its water, it has chosen the water. And it has held its nerve while an industry adjusted.
The water nobody could see
The late Professor Tony Allan of King’s College London and SOAS spent much of his career on exactly this problem, and gave it a name: virtual water. “The Middle East as a region ran out of water in the 1970s,” he wrote in 1997. “The news of this important economic fact has been little exposed.”
His insight was that the water hides in the food. “The production of every tonne of a food commodity such as wheat,” he wrote, “requires a water input of about 1000 tonnes.” A region that imports food imports water, quietly. He was candid about why the politicians of the 1990s avoided the subject: “To draw attention to the water gap and the food gap could be politically suicidal.”
Allan’s logic, followed to the end, says the Gulf should grow as little as it can and import the rest. That is the serious objection to everything that follows, and it deserves a serious answer.
The answer is the last six years. A pandemic, a war in Ukraine and the disruption of Red Sea shipping taught every government in the region that a supply chain is only as secure as its most distant port. In 2020 Mariam Al Mheiri, then the UAE’s Minister of State for Food Security, told an FAO regional meeting that “a complete overhaul needs to be done”, and urged governments “to really look into their regulations to try to enhance the growth of more sustainable domestic production.” This May, the Kingdom’s Deputy Minister for Water, Dr Abdulaziz Alshaibani, told a United Nations water conference in Dushanbe that water challenges are increasingly linked to climate risks, economic development and food security, according to the Saudi Press Agency.
Saudi Arabia has not chosen between Allan and his critics. It produces 131 per cent of its own dairy needs, 121 per cent of its dates and 103 per cent of its table eggs, according to the General Authority for Statistics. In 2023 it made half of the water in its distribution networks from the sea. The settlement it has reached is to produce, but to count the water. And the place where that settlement is now being written into law is no longer the farm. It is the factory.
The rules have walked from the field to the factory gate
The Water Law of 2020, issued by Royal Decree M/159, reads in places as though it had food manufacturers in mind. Using any water resource other than seawater requires a licence. Every use of water is to be “effectively monitored and measured”, and users must allow it. Article 38 requires “all government and private sectors” to use water conserving fittings “and recycle gray water, in accordance with the Ministry’s regulations”. Article 23 draws a hard line for the industry: tertiary treated wastewater “shall not be used for drinking, household purposes, or in food industries”.
Article 36 contains a clause that deserves a place in every export plan. The Ministry, it says, is to determine, with the relevant agencies, which water consuming agricultural and animal products and their derivatives may not be exported. For a dairy sector producing nearly a third more than the Kingdom consumes, that is not a footnote. The power has not, to my knowledge, been used for dairy, but it exists. Penalties under the law run to suspension for up to a year, revocation of a licence, and a fine of up to SAR 20 million for each violation.
The newer instrument is the one to watch. In August, the official gazette Umm Al Qura published the Minister’s decision approving an updated Executive Regulation for monitoring compliance with water efficiency and rationalisation standards, first issued in 2025 and now due to take effect on 21 March 2027. It covers the urban, agricultural and industrial sectors. According to Saudi press reports of its text, industrial users must keep to the water quantities set for each industry, keep to their licensed uses, follow a set order of priority for their sources, and comply with whatever is decided on allocating the water footprint of industrial products. Failing to keep to an allocated industrial water footprint is listed as a violation.
I have not found any published decision allocating those footprints. When one is issued, a plant’s water is likely to be judged not only by what passes through its meter, but by what it takes to make a unit of product.
Industry already feels the price. In the Kingdom’s 2023 water accounts, industry consumed roughly one litre in seven of the water used in Saudi Arabia, yet accounted for 61.4 per cent of spending on water. And the calendar is tightening around it. The Council of Ministers has named 2027 the Year of Water, and Riyadh hosts the World Water Forum the same year.
Why water rules may reach your waste first
Now put the food waste numbers next to the water.
When the Saudi Grains Organization, now the General Food Security Authority, measured the Kingdom’s food loss and waste, it found that 33.1 per cent of food was lost or wasted between farm and fork. The Authority’s own baseline study put that at about four million tonnes and SAR 40 billion a year. Last September the Authority reported real progress: the index had fallen to 27.9 per cent, a reduction of 16 per cent, on the way to halving food loss and waste by 2030.
A peer reviewed study published in June estimated the water inside that waste. The authors calculated that the Kingdom’s food loss and waste carries around 2.14 billion cubic metres of blue water, meaning the surface and groundwater used to produce it, as opposed to rainfall. That is equivalent to about 62 per cent of the Kingdom’s domestic water demand. Meat made up 13 per cent of the waste by weight, but 53 per cent of its water footprint.
Read that again. On that estimate, the water inside the food the Kingdom wastes is equivalent to more than half of its domestic water demand, every year.
The food waste rules, by contrast, are still light for manufacturers. The Waste Management Law of 2021 requires waste producers to reduce, reuse and separate what can be recovered, and establishes extended producer responsibility, with the detail left to regulations. Under restaurant requirements issued in April 2025, restaurants and kitchens larger than 400 square metres must contract with a licensed food preservation association to redistribute their surplus. The National Center for Waste Management plans to divert 82 per cent of waste from landfill by 2035. But I have found no rule that yet requires a food manufacturer to measure its food loss against a national target, report it publicly or donate its surplus, as larger restaurants must now do.
That is the gap, and it is the whole argument of this piece. The food waste regime is still largely voluntary for manufacturers. The water regime is binding, measured, and heading toward allocation by product. In my view, if the footprint is allocated per unit of product, and for a manufacturer the only unit that pays is the one that is sold, every tonne written off raises the water footprint of every tonne that is not.
The water regulator may reach your waste bin before the food waste regulator does.
The people already building for it
None of this is foreign to the region. In the east of the Kingdom, the Al Ahsa Oasis was inscribed on the UNESCO World Heritage List in 2018. UNESCO describes a landscape of “gardens, canals, springs, wells and a drainage lake”, and notes that “with its 2.5 million date palms, it is the largest oasis in the world.” It is an entire landscape organised around moving scarce water to where it was needed and draining it away where it was not. Managing water as the limiting input is not a discipline Saudi producers need to import.
Some of the Kingdom’s largest producers are already publishing the numbers. SADAFCO reported using 3.30 litres of water for every litre of product in 2023, and has set a target of zero wastewater discharge to the municipal system from its Jeddah milk and ice cream plant by 2027. Almarai reports that 20 per cent of its water was recycled or reused in 2025.
And a new generation of companies is building for precisely the gap between water and waste. Uvera, a Saudi startup founded at KAUST by Dr Asrar Damdam, uses ultraviolet light and vacuum sealing to extend the shelf life of fresh food without chemicals. A 2023 peer reviewed study, co written by its founder, found the treatment extended the shelf life of beef, chicken and salmon by about two thirds. In July it closed a seed round whose backers include Morgan Stanley Inclusive & Sustainable Ventures and LAB7, Aramco’s venture building arm.
In recent weeks I have come across two more, one on each side of the ledger.
On the food side, RBT Collective, founded by Hachem Mahfoud, rescues surplus food through smart fridges and is a founding partner in Terrazo, Expo City Dubai’s food rescue programme. In July it was among the first six businesses granted Expo City Dubai’s new Expo Green Licence.
On the water side, MRA Solutions, a Canadian cleantech company established in 2002, has brought its BioClarus system to the UAE for the first time, and LexDesk360, where I am Managing Partner, is supporting its growth across the Middle East. BioClarus treats water using electricity rather than dosed chemicals. In a field trial in the UAE this September, on raw car wash wastewater analysed by an accredited Dubai laboratory, suspended solids fell by more than 92 per cent, emulsified oil and grease by 71 per cent and ammoniacal nitrogen by 93 per cent. It barely changed the organic load, which fell by 10 per cent measured as biochemical oxygen demand and by 4 per cent as chemical oxygen demand, and that is the measure that matters most for food plant effluent. It does not remove dissolved salts either, and is designed to work alongside reverse osmosis rather than replace it.
Car wash water is itself grey water under the Water Law’s definition, and recycling grey water, in accordance with the Ministry’s regulations, is what Article 38 asks for. Process effluent from a food plant is a different and harder stream, and whether any technology treats it well enough for reuse is a question for a site pilot, not an article.
The law sets the boundary too. Article 23 bars tertiary treated wastewater from use in food industries. Whether a food plant may reuse its own treated water for cooling, landscaping or other uses that never touch the product depends on the Ministry’s regulations and on food safety rules, and should be confirmed before any design is fixed.
Four questions to ask before March 2027
The call to action is simple to state and hard to do: redesign the plant as though water were the scarcest input it has, because in Saudi Arabia it is.
Start by asking whether you know your water per saleable tonne, not per site. A plant that knows only its monthly bill cannot answer the question a footprint allocation would ask. Metering by line, by cleaning cycle and by product is the only way to know where the water goes, and the Water Law already requires every use to be monitored and measured, and users to allow it.
Then ask what your write offs cost in litres as well as riyals. Every batch lost to spoilage, overproduction or a short shelf life carries the water of everything upstream of it. The study published in June shows that meat, only 13 per cent of the waste by weight, carries more than half of its water footprint. Extending shelf life, rescuing surplus and designing out overproduction are water measures as much as food measures.
Ask whether your plant separates its water streams, and on which side of the legal line each one sits. Article 38 points toward recycling grey water, and Article 23 sets a boundary for food industries. A plant designed today can separate its streams and reuse what the rules allow. Retrofitting that separation later is likely to cost considerably more.
Finally, ask whether your export plans account for Article 36, and whether you are taking part in the consultations. The footprint allocation for industrial products has not yet been written. A sector that arrives with its own measured data will help to shape it. A sector that arrives without it will be allocated a number by someone else.
Each of these turns on the final text of the regulations and on the facts of the plant, and needs local advice.
The point
Saudi Arabia has already taken one of the hardest food decisions any country has taken, and it took it for water. It gave up a harvest it had proved it could grow.
The second decision is smaller and quieter, and it falls to each manufacturer rather than to the state. It is the decision to treat a wasted tonne of food as a wasted volume of water, and to redesign the plant around that fact before a regulation does it for them.
The producers who make it now will find a footprint allocation a formality. For everyone else, it may be the first real audit of their waste.
The Signal
The water inside the waste. A peer reviewed study by Alzahrani and Tawfik, published in Water in June 2026, estimates that food loss and waste in Saudi Arabia carries a combined blue and green water footprint of about 7.3 billion cubic metres, of which about 2.14 billion is blue water. On the authors’ estimate, that blue water is equivalent to about 62 per cent of the Kingdom’s domestic water demand. Meat is 13 per cent of food loss and waste by weight and 53 per cent of its water footprint. The study applies global average water footprint coefficients regardless of where the food was grown, so much of that water was used abroad, and dairy is not among the commodities it covers. It is academic work, not an official statistic.
The efficiency regulation has a date. The updated Executive Regulation for monitoring compliance with water efficiency and rationalisation standards takes effect on 21 March 2027. According to Saudi press reports of its text, it requires industry to adhere to the quantities set for each industry, to licensed uses and to source priorities, and to comply with decisions on allocating the water footprint of industrial products. I had not found any published allocation decision at the time of writing.
Fodder is on a fixed timetable. Perennial fodder is to end across the sedimentary shelf from 16 November 2026, as reported by Argaam, and the USDA reports a scheduled prohibition of domestic alfalfa from the 2027/2028 production year. Farms over 100 hectares, including dairy companies growing their own feed, have been barred from green fodder there since 3 November 2018.
Well licences have a new deadline. The deadline for licensing the use of existing wells has been extended by a year, to 5 Safar 1449H (9 July 2027), according to the Saudi Press Agency. The extension does not cover bottled water factories or large agricultural companies.
Food loss and waste is falling. The national index fell from a baseline of 33.1 per cent to 27.9 per cent, the General Food Security Authority announced on 29 September 2025. The national aim is to halve food loss and waste by 2030, in line with Sustainable Development Goal 12.3.
2027 is the Year of Water. The Council of Ministers has designated 2027 the Year of Water, and Riyadh hosts the 11th World Water Forum the same year.
The Question
If the water footprint of your plant were allocated per tonne of saleable product tomorrow, how much of it would you be spending on product you throw away?
Sources and Further Reading
Ministry of Environment, Water and Agriculture, Saudi Water Reforms Boost Food Security, 1 July 2026
Testhub Laboratories LLC, Dubai, analysis reports on raw and treated car wash wastewater, 24 to 28 September 2026, supplied by MRA Solutions (on file with the author)
Positions described are current as at 30 September 2026 and are general commentary, not legal, technical or investment advice. Translations from Arabic are the author’s own. The description of the 2026 water efficiency regulation draws on Saudi press reports of its text; readers should consult the text published in Umm Al Qura before relying on it. Figures attributed to companies are the companies’ own published or supplied figures and have not been independently verified. The water footprint estimate is from a peer reviewed academic study, not an official statistic. No company or individual named is accused of any wrongdoing. The BioClarus results reported here come from laboratory analyses supplied by MRA Solutions, relate to one car wash wastewater trial only, and would need to be confirmed by a pilot on any other site or effluent. LexDesk360, where the author is Managing Partner UAE, is supporting BioClarus’ growth across the Middle East. This article is written in a personal capacity.
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