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                                                                       Exhibit 8



                       [Letterhead of Robinson & Cole LLP]


                                                          February 27, 1998

Sparkling Spring Water Group Limited
One Landmark Square
Stamford, CT  06901

Ladies and Gentleman:

         You have requested our opinion concerning the material anticipated
United States federal income tax consequences of the exchange of outstanding
11-1/2% Senior Subordinated Notes due 2007 originally issued by Sparkling
Spring Water Group Limited ("Sparkling Spring"), for 11-1/2% Senior Subordinated
Notes due 2007 of Sparkling Spring which were registered under the Securities
Act of 1933, as amended, pursuant to the Registration Statement on Form F-4
filed herewith (the "Registration Statement").

         The facts upon which we relied to issue the opinion are presented in
the Registration Statement. Based on such facts, it is our opinion that the
material anticipated federal income tax consequences are accurately set forth
under the heading "Certain Federal Income Tax Consequences" in the Registration
Statement. We express no opinion as to any other matter not discussed therein.
For example, this opinion does not purport to discuss all possible United States
federal income tax consequences attributable to the exchange, nor does it
present the applicability and effect of any state, local or foreign law.
Additionally, any change in the facts from those set forth in the Registration
Statement may impact our opinion.

         The basis for our opinion rests in provisions of the Internal Revenue
Code of 1986, as amended (the "Code"), regulations promulgated thereunder, and
administrative rulings and judicial decisions now in effect, all of which are
subject to change (possibly with retroactive effect) or different
interpretations.

         We issue this opinion to you solely for use in connection with the
Registration Statement, not for any other purpose, and we consent to the filing
of this opinion as an exhibit to the Registration Statement.

                                      Very truly yours,

                                      ROBINSON & COLE LLP


                                      By: /s/ Richard W. Tomeo
                                          -------------------------------
                                              Richard W. Tomeo, a partner