NEWS | Industry Updates
EVA publishes guidance on refurbishment
The EVA has published new industry guidance encouraging operators to repair, refurbish and upgrade vending and professional coffee machines, while warning that significant modifications can create new regulatory and legal responsibilities. The guidance for members is intended to support circular- economy objectives by reducing unnecessary waste and extending the useful life of equipment. However, the document stresses that older machines should not remain in service indefinitely if their energy efficiency, environmental performance or regulatory compliance no longer meet current European expectations. Lifecycle management may involve routine maintenance, repairs,
refurbishment, functional upgrades, redeployment or resale. These activities can help operators protect their investments and reduce environmental impacts, provided that machine safety, performance and compliance are preserved. The new guidance document distinguishes between several types of intervention. Repair involves returning a faulty machine to its intended working condition, while refurbishment restores a used machine to its original functionality. Upgrades may improve a machine’s software, hardware, capacity or appearance, provided the changes remain within the scope of its original design and testing. Remanufacturing by contrast, involves changes that affect the machine’s safety, performance, purpose or type.
Routine servicing is generally not considered a change to a machine’s legal status. Examples include cleaning, hygiene maintenance, replacing components with suitable spare parts and carrying out repairs in line with the manufacturer’s documentation. Installing compatible peripherals, such as payment systems or telemetry devices, may also be acceptable when the equipment is properly marked and installed according to instructions. Refurbishment and limited upgrades can similarly remain covered by the original manufacturer’s conformity framework. Operators must ensure that safety functions are not altered, electrical and mechanical compatibility is maintained, food-safety requirements continue to be met and energy and environmental performance are preserved. The main concern arises when an intervention becomes a ‘substantial modification.’ The EVA thus recommends assessing such changes individually according to their impact on the machine’s intended function and risk profile. A modification may be considered substantial if it introduces new risks, significantly increases existing risks, changes safety functions or alters the machine’s intended use. Potentially substantial changes may include redesigning a cooling unit, changing the control architecture, making major mechanical alterations or combining machines. Where such changes require a new conformity assessment, the company carrying them out may assume the responsibilities of a manufacturer. Product identification, technical documentation and CE conformity information must then clearly identify the responsible economic operator. In these cases legal responsibility may shift from the original manufacturer to the refurbisher once a machine has been materially altered. The EVA also recommends maintaining detailed records of
refurbishment work, using certified and compatible components and ensuring that machines returned to the market comply with European legislation. It also advises operators to seek technical or conformity-assessment expertise when the effects of a modification are unclear. The new guidance is not intended to discourage repair or refurbishment. Instead, it aims to ensure that lifecycle extension supports consumer safety, follows regulatory compliance, provides fair competition and overall the responsible development of a circular economy. The new guidance, published for EVA members and entitled “Industry Guidance on the Lifecycle Management” can be found after login on the EVA website.
Industry urged to contact the MPs on high-caffeine energy drinks ban
The Department of Health & Social Care (DHSC) has confirmed plans to ban the sale of high-caffeine energy drinks (over 150mg/ litre, excluding tea and coffee) to under-16 year-olds in England and from all vending machines, regardless of location, from 6 April 2027 (subject to Parliamentary approval). The Vending & Automated Retail Association (AVA) has expressed its “extreme disappointment” that the Government rejected evidence showing most vending machines are inaccessible to children, as well as alternative approaches such as age verification. The decision is based largely on enforcement simplicity rather than evidence of significant underage
purchases through vending, the AVA said. The association is urging its members to assess the potential impact on their businesses, including affected machines, product ranges and alternative products. As MPs return from the summer recess,
the AVA will continue to engage with them and challenge the lack of vending-specific evidence as the next stage of the legislation is introduced. Members are strongly encouraged to contact their local MPs to explain the impact on their business and livelihoods. Having their local MPs informed and aware of the impact on local businesses is essential when it comes to their votes in the House.
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