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European Vending & Coffee Service Association

EVA

The European Vending & Coffee Service Association (EVA) is a not-for-profit organisation, established in Brussels since 1994.

Lobbying Activity

Response to Circular Economy Act

5 Nov 2025

Please find attached comments on behalf of the European Vending & Coffee Service Association (EVA).
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Response to Revised EU energy labelling for refrigerating appliances with a direct sales function

20 Jun 2025

Please find attached comments on behalf of the European Vending & Coffee Service Association (EVA).
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Response to Revised ecodesign requirements for refrigerating appliances with a direct sales function

20 Jun 2025

Please find attached comments on behalf of the European Vending & Coffee Service Association (EVA).
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Meeting with Philip Tod (Head of Unit Economic and Financial Affairs)

17 Jun 2025 · Possible simplification and/or efficiency improvements of the Regulation (EU) No 1210/2010. Commission action to be organised in the framework of the Pericles programme for enhancing detection of unfit euro coins.

Response to Verification of suppliers and other operational aspects for the functioning of product database - EPREL

20 Nov 2023

Thank you for the opportunity to provide feedback on the updated operational functioning of EPREL. Please find below a few comments on behalf of the European Vending & Coffee Service Association (EVA). The EVA agrees that only suppliers, having successfully completed the verification process, may register product models in EPREL. The EVA currently sees a number of declarations of refrigerated vending machines on EPREL made by unverified suppliers, which are confusing and creates unfair business competition for compliant machine manufacturers. It could be assumed that there may be a correlation between unverified suppliers and incorrectly completed declarations. Further to this, incorrect entries on EPREL are already being used by public organisations to select the best performing machines, whether the supplier is correctly verified or not. We welcome measures to remove unverified suppliers from EPREL as per Article 7. Suppliers should have already by now been verified and as such a 6-month transition period will in our view only serve to continue this unfair competition longer than necessary before they are eventually removed from the database. We welcome also that under Article 19 inappropriate or fraudulent use of EPREL may be addressed. However we find the wording in the Article very vague with little concrete action to address this. The EVA has raised numerous examples of incorrectly declared EPREL entries, including incorrect use of energy calculation standards or machine categories for refrigerated vending machines, and yet machines are still permitted to remain on EPREL. Action needs to be taken quicker, on misleading or incorrect information that appears on the database. Article 19 does not go far enough in our view to ensure sound and reliable declarations. While not solely or directly related to the operation of EPREL, the product labeling system, at least with regard to refrigerated vending machines, still has some shortcomings. Specifically, the lack of a 'Temperature class' is missing from the label for our products, so it is impossible to evaluate the performance of different vending machines without also having to read the product information sheet. This also leads to incorrect entries on EPREL being sometimes difficult to spot, especially for non-technical procurement personnel determining tenders.
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Response to Payment services – revision of EU rules (Directive)

24 Oct 2023

Please find attached some comments on behalf of the European Vending & Coffee Service Association (EVA).
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Response to Payment services – revision of EU rules (new Regulation)

24 Oct 2023

Please find attached some comments on behalf of the European Vending & Coffee Service Association (EVA).
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Response to Promoting sustainability in consumer after-sales

25 May 2023

Please find attached comments on behalf of the European Vending & Coffee Service Association (EVA).
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Response to Review of the requirements for packaging and feasibility of measures to prevent packaging waste

19 Apr 2023

Please find attached the position of the European Vending & Coffee Service Association (EVA) on the proposal for a Packaging & Packaging Waste Regulation (PPWR). Please also fine in the link below a joint letter signed by more than 120 European Associations calling for the internal market legal basis to be maintained: https://www.vending-europe.eu/ppwr-over-120-industry-associations-call-for-safeguarding-internal-market-legal-basis/
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Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans) and Bundesverband der Deutschen Vending Automatenwirtschaft e.V.

10 Feb 2023 · Proposal for the Packaging and Packaging Waste Regulation and implications to products sold through vending machines

Response to Evaluation of the 2012 Directive on waste from electrical and electronic equipment

3 Nov 2022

Please find attached comments on behalf of the European Vending & Coffee Service Association (EVA).
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Response to Regulation correcting energy labelling regulations for air conditioners, displays, light sources, refrigerating products

8 Aug 2022

Please find below some comments on the proposed corrections to EU 2019/2018 on behalf of the European Vending & Coffee Service Association (EVA). ANNEX V In point 2(b) of Annex IV of Delegated Regulation (EU) 2019/2018, the first indent is replaced by the following: “— Edaily is the energy consumption of the refrigerating appliance with a direct sales function over 24 hours, expressed in kWh/24h, rounded to three decimal places and measured according to the temperature conditions of Table 4 for the relevant temperature class.”. We have no comments on this textual change which clarifies the energy consumption is calculated according to the relevant (refrigerated vending machine) temperature class. Context of the Delegated Act “Annex IX does not set a verification tolerance for temperatures, implying that the tolerance is zero. This concept needs to be made explicit, by specifying in Annex IV(2)(b) that the E daily (the energy consumption of the refrigerating appliance with a direct sales function over 24 hours) is measured according to the temperature conditions of Table 4 in the same Annex.” The context for the change is that there should be no tolerance for temperatures and this needs to be made explicit. From our reading of EU 2019/2018 Annex IX, the Edaily tolerance for market surveillance purposes is 10% which as part of this calculation would include the temperature conditions. While we therefore have no comments on the text of the proposed technical amendment itself, we do think that the actual stated context or reasons for the change may need clarified.
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Response to Sustainable Products Initiative

1 Jun 2022

Please find attached comments on behalf of the European Vending & Coffee Service Association (EVA) on the proposed Ecodesign for Sustainable Products Regulation.
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Response to Promoting sustainability in consumer after-sales

4 Apr 2022

Please find attached a letter outlining comments on behalf of the European Vending & Coffee Service Association (EVA).
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Response to Waste Framework review to reduce waste and the environmental impact of waste management

21 Feb 2022

Please find attached some comments on behalf of the European Vending & Coffee Service Association (EVA).
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Response to Review of ecodesign requirements for standby and off mode electric power consumption

1 Feb 2022

Please find attached some comments on behalf of the European Vending & Coffee Service Association (EVA). Thank you for your consideration of them.
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Response to Revision of the Machinery Directive

30 Jul 2021

Please find attached some comments on the proposal from the European Vending & Coffee Service Association (EVA).
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Response to Setting of nutrient profiles

29 Jan 2021

Please find attached comments by the European Vending & Coffee Service Association (EVA).
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Response to Energy labelling omnibus amendment of 2019 regulations

3 Nov 2020

The European Vending & Coffee Service Association (EVA) would like to make the following comments with respect to the proposed amendments: Amendments to EU 2019/2018 Article 2, point 21 is replaced by the following: ‘21.‘corner, curved and carousel cabinet’ means a refrigerating appliance with a direct sales function used to achieve geometrical continuity between two linear cabinets that are at an angle to each other and/or that form a curve. A corner, curved and carousel cabinet does not have a recognisable longitudinal axis or length since it consists only of a filling shape (wedge or similar) and is not designed to function as a stand-alone refrigerated unit. The two ends of the corner cabinet are inclined at an angle between 30 ° and 90 °;’; We are concerned for the potential of confusion over the term ‘carousel cabinet’ when read across product categories. Both the standard for measuring energy consumption at refrigerated vending machines EN 50597, as well as common industry practice is to refer to drum vending machines as ‘carousel vending machines’ interchangeably. While EN 50597 does not define ‘carousel’ precisely, in order to avoid any ambiguity or confusion we propose to delete ‘carousel' from this amended definition and define circular supermarket retail display cabinets completely separately. In Annex III, Point 1.2, paragraph VIII, the first indent under the first item is replaced by the following: ‘- the temperature at the top: the maximum measured product temperature of the compartment(s) wit chilled operating temperatures, in degrees Celcius (°C) and rounded to the first decimal place, as set out in Table 4;’; Rounding to the first decimal place would impact temperature declarations of Category 4 and 6 refrigerated vending machines, which previously had to round to the nearest whole integer or full number which provided an inaccurate view of the actual temperature. We note that split temperature machines with this change could now state e.g. 7.5 degrees on the energy label and provide a more accurate information about their temperature performance. However we are unsure how this change to one decimal point could (indirectly) impact on other aspects of the Regulation i.e. tolerances. In addition, “In Annex III, Point 1.2, paragraph VIII, the first indent under the first item is replaced by the following:” should also include “the first indent under the second item” to ensure the amendment covers refrigerated vending machines. Minor typo – “wit” to “with”
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Response to Ecodesign omnibus amendment of 2019 regulations

3 Nov 2020

The European Vending & Coffee Service Association (EVA) would like to make the following comments with respect to the proposed amendment: Amendments to EU 2019/2024 Article 2, point 21 is replaced by the following: ‘21.‘corner, curved and carousel cabinet’ means a refrigerating appliance with a direct sales function used to achieve geometrical continuity between two linear cabinets that are at an angle to each other and/or that form a curve. A corner, curved and carousel cabinet does not have a recognisable longitudinal axis or length since it consists only of a filling shape (wedge or similar) and is not designed to function as a stand-alone refrigerated unit. The two ends of the corner cabinet are inclined at an angle between 30 ° and 90 °;’; We are concerned for the potential of confusion over the term ‘carousel cabinet’ when read across product categories. Both the standard for measuring energy consumption at refrigerated vending machines EN 50597, as well as common vending industry practice is to refer to drum vending machines as ‘carousel vending machines’ interchangeably. While EN 50597 does not define ‘carousel’ precisely, in order to avoid any ambiguity or confusion we propose to delete ‘carousel' from this amended definition and define circular supermarket retail display cabinets completely separately.
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Response to Farm to Fork Strategy

11 Mar 2020

Please find in the document attached comments from the European Vending & Coffee Service Association (EVA) on the Farm to Fork Strategy Roadmap.
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Response to Ecodesign for refrigerating appliances with a direct sales function

21 Dec 2018

Please find attached EVA comments on the draft Ecodesign Regulation.
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Response to Energy labelling for refrigerating appliances with a direct sales function

14 Dec 2018

Please find attached comments on the draft Regulation on behalf of the European Vending & Coffee Service Association (EVA).
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Response to Reducing marine litter: action on single use plastics and fishing gear

17 Jul 2018

The EVA recognises the concerns regarding the presence of used plastic items unnecessarily discarded in the environment and the importance of appropriately addressing this issue. However, the EVA is deeply concerned that the measures contained in the draft Directive would have a significant and unfair impact on the vending industry, where the business is essentially contained within 'closed sites' in workplaces, where plastic collection is currently facilitated. More importantly, due to the fact that the single use products used in the vending industry are specifically and technically designed for this usage - and there are no alternatives to these products - we consider the only realistic response is to request the exclusion of products designed for vending from the scope of the draft Directive. We have furthermore concerns about the process surrounding the earlier consultation ahead of the publication of the Directive proposal, and how the Commission is observing its better regulation principles. Moreover we understand that the choice of outside consultants for the consultation process may lead to questions surrounding a potential conflict of interest, and as such we would call on the Commission to carry out a more thorough consultation and impact assessment before presenting new proposals. More details of our position can be found in the attached complete response.
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