Vending machines and self-service equipment

• Regulation (EU) 2023/1230 — Machinery
• Directive 2014/35/EU — Low Voltage
• Regulation (EC) No 1935/2004 — food contact
• Regulation (EC) No 852/2004 — food hygiene
• Directive 2014/32/EU where payment is by weight or measure

Who has to appoint one

Manufacturers outside the Union placing vending and self-service equipment on the EU market. The operator of the machine is separately a food business operator where food or drink is dispensed, and must be registered nationally.

Thresholds and exemptions

None for the machine. Food hygiene obligations attach to the operator rather than the manufacturer, but the machine must be designed to allow compliance.

What must appear on the label

CE marking, manufacturer and EU representative details, type and serial number, year of construction, electrical ratings, and the food contact indication for the parts contacting product. Where a payment terminal is integrated, its own conformity applies.

Marketplace fields

Operators and leasing companies require the declaration of conformity and the hygienic design documentation before purchase, because their own food business registration depends on it.

Documentation you must hold

EU declaration of conformity, technical file with the machinery risk assessment covering entrapment, burns and electrical hazards, food contact declarations of compliance for all wetted parts, hygienic design documentation, and WEEE and packaging registrations.

Standards and testing

EN 60335-2-75 for commercial dispensing appliances and vending machines, EMC testing, migration testing for food contact components including tubing and mixing bowls, and where applicable metrology testing for measured dispensing.

Language requirements

Installation, operation and cleaning instructions in the language of the member state where the machine is put into service, since the cleaning regime is a food safety control.

When it applies

Before placing on the market.

How long records are kept

Ten years.

What happens if you do not comply

Withdrawal and prohibition of use. Food safety authorities can order a machine taken out of service immediately where hygiene design or cleaning access is inadequate, which is a commercial loss for the operator and a warranty dispute for the supplier.

Who enforces it

Market surveillance authorities, food safety authorities, metrology authorities where measured dispensing applies, and WEEE registers.

Where the boundary lies

The manufacturer's obligations and the operator's food business obligations are separate but interdependent: a machine that cannot be cleaned to the required standard makes compliance impossible for the operator, and that is a design defect rather than an operational failure.

Questions we are asked

Does a coffee vending machine need food contact documentation?

Yes, for every part contacting water, milk or product, with migration data at the temperatures reached in use.

Who registers as a food business, us or the operator?

The operator, who places the food on the market. The manufacturer's duty is to supply a machine that permits hygienic operation and to document it.