Compliance
Ecodesign Energy Efficiency Class (EU 2019/2024)
Term from the vending glossary
The Ecodesign Energy Efficiency Class under Regulation (EU) 2019/2024 classifies refrigerated direct-sales appliances (cooled vending machines) using a calculated Energy Efficiency Index (EEI) that relates the appliance's standardised annual energy consumption to a category-specific reference value. Since March 2023, new units may only be placed on the market if their EEI does not exceed the statutory maximum of 55.
How the EEI is calculated
The regulation applies exclusively to refrigerating appliances with direct sales function (category RVA, Refrigerating Appliances with a Direct Sales Function) — that is, cooled vending machines and refrigerated display cases with integrated sales mechanism. Non-refrigerated vending machines do not fall under this regulation. The Energy Efficiency Index is calculated by dividing the measured annual energy consumption (AEC, Annual Energy Consumption in kWh) by a device-specific standard annual energy consumption (SAECref), multiplied by 100. An EEI of 80 means concretely: the appliance consumes 20 per cent less energy than the reference unit in the same appliance category.
Phased implementation: Two compliance phases
The requirements came into force in two stages:
- 1 March 2021 (Stage 1): EEI maximum value 100 for all newly placed cooled vending machines (ice cream cabinets: 80)
- 1 September 2023 (Stage 2): EEI maximum value 80 for all newly placed cooled vending machines (ice cream cabinets: 50; excluding cooled drum vending machines)
Units that were lawfully placed on the market before the respective date may continue to operate. The replacement obligation only arises upon purchase of a new unit.
What this means for operators
An older unit with EEI close to 100 and a new unit compliant since 1 September 2023 with EEI 80 differ by definition in at least 20 per cent energy consumption for the same appliance category and reference consumption (SAECref) — how much this translates to in absolute kWh and euros per year depends on appliance size, location and electricity cost, and can only be calculated using the specific SAECref value shown on the CE Declaration of Conformity.
Documentation requirement at purchase: Manufacturers must retain technical documentation and EEI evidence for ten years. Operators should request the CE Declaration of Conformity showing the EEI value when purchasing an appliance, as this proves compliance with the stage requirements.
Sources & further reading
- Verordnung (EU) 2019/2024 der Kommission vom 1. Oktober 2019 zur Festlegung von Ökodesign-Anforderungen an Kühlgeräte mit Direktverkaufsfunktion
- Bundesverband der Deutschen Vending-Automatenwirtschaft (BDV)
- Commission Regulation (EU) 2019/2024 — consolidated text (EEI thresholds, Annex II Tables 1 & 2)
