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, can be found after login on the EVA website here