Food hygiene at vending machines: obligations in Germany, Austria and Switzerland

Anyone selling snacks, drinks, eggs, meat or hot food via a vending machine is a food business operator. The same basic obligations apply as for a shop, just without staff on site. The machine therefore has to do much of what sales staff would otherwise handle: keep goods at the right temperature, stay clean, display mandatory information and report faults. This guide summarises what applies in Germany, Austria and Switzerland and how to put it into practice.

The common basis in the EU

In Germany and Austria, the EU Hygiene Regulation (EC) No 852/2004 applies directly. Chapter III of its Annex II contains specific rules for vending machines. The machine must be sited, designed, constructed and kept clean and in good repair so that food is not contaminated, in particular by animals and pests. Surfaces in contact with food must be in sound condition and easy to clean. The machine also needs suitable facilities to maintain and monitor the right temperature.

The general obligations for all food businesses also apply: the cold chain must not be interrupted, anyone handling food must be trained, and the business needs a self-monitoring system based on HACCP principles. How extensive this system has to be depends on the risk. For packaged goods that do not need refrigeration, the authorities generally do not require separate HACCP documentation; for fresh produce, chilled goods and hot food they do.

Registration with the authorities

Germany

You register the machine with the food control authority responsible for the machine’s location. This also applies if your business is already registered elsewhere. New locations and new product ranges must be reported as well.

Austria

Registration under the EU Hygiene Regulation is made to the provincial governor (Landeshauptmann), in practice to the food inspectorate of the federal state (Section 10 LMSVG). The authority also uses data from the trade register. Sales via vending machines are generally covered by the unregulated retail trade licence (freies Handelsgewerbe).

Switzerland

In Switzerland, food businesses notify their activity to the cantonal enforcement authority, usually the cantonal food inspectorate (Art. 20 LGV). For pure trading in packaged goods, self-monitoring mainly covers safety, traceability and documentation. Anyone handling unpackaged goods additionally needs good manufacturing practice and a HACCP-based concept (Art. 75 LGV).

Temperatures and cold chain

In Germany there is no general statutory maximum temperature for all chilled goods. What counts is the manufacturer’s storage instruction on the packaging, and the machine is set according to the most sensitive product in the range. If there is no manufacturer instruction, the authorities refer to DIN 10508. Binding values exist for certain foods of animal origin such as minced meat. German food control authorities give the following guide values:

For frozen food, the German regulation on quick-frozen foods requires −18 °C or colder, with brief deviations of no more than 3 °C (Section 2 TLMV). In Austria, the guideline for retail businesses gives similar values, for example a maximum of 4 °C for poultry and 7 °C for meat. In Switzerland, the cantonal food inspectorates set maximum temperatures, also −18 °C for frozen food.

Important in day-to-day operation: an unstaffed machine has to report a fault itself. When buying, look for temperature monitoring with an alarm, and decide in advance what happens to the goods if the cooling fails. Many models in our range show sales, stock and faults in real time in the cloud, for example our Micro markets and Frozen food vending machines.

Labelling and allergens

For prepacked goods, all mandatory information under the Food Information Regulation (FIC) is on the packaging. Unlike in online retail, it does not have to be shown before purchase at a vending machine. It is sufficient for it to be on the product when it is dispensed (Art. 14(3) FIC).

For unpackaged or freshly prepared goods, such as pizza, fries or coffee specialities, allergens must always be declared (Art. 44 FIC). In Germany this can be done via a sign on the machine, a notice or electronically, for example in the order menu on the touchscreen (Section 4 LMIDV). For goods you pack yourself for sale in the machine, the mandatory information may be shown on a sign on or next to the machine.

In Austria, the Allergen Information Regulation governs the declaration; in Switzerland, Art. 5 of the Food Information Ordinance (LIV). As nobody can give verbal information at a vending machine, the information must be provided in writing on the machine or on the display in both countries. In Switzerland, the origin of meat and fish must also be stated for unpackaged goods (Art. 39 LGV).

Staff and training

Anyone placing highly perishable food on the market in Germany needs demonstrable expertise in food hygiene (Section 4 LMHV). This does not apply if only packaged food is sold. Anyone who comes into contact with unpackaged food such as meat, dairy products, egg products, ice cream or delicatessen salads when restocking also needs an initial briefing by the public health office under Section 43 of the Infection Protection Act. After that, the employer gives a briefing every two years and documents it. In Austria and Switzerland, staff training is also one of the business’s obligations.

Use-by date and best-before date

Goods past their use-by date are deemed unsafe and must no longer be sold (Art. 24 FIC). An expired best-before date is not a sales ban, but you then have to check the goods and point out that the date has passed, which is hardly practicable at a vending machine. Remove such goods beforehand and restock on a “first in, first out” basis: older goods go to the front, new goods to the back.

Special case: milk and raw milk vending machines

In Germany, raw milk may only be supplied at the dairy farm, obtained on the day of supply or the day before, after prior notification and with the notice “Raw milk, boil before consumption” (Section 17 Tier-LMHV). In Austria, the Raw Milk Regulation requires the same notice, and sales are permitted on the day of milking and the two following days. In Switzerland, the machine must state that raw milk must be heated to at least 70 °C before consumption. Industry guidance recommends emptying and cleaning the tank completely before refilling.

Hygiene plan for the vending machine

• Location out of direct sunlight, protected from moisture, dust and pests
• Check the temperature every working day or monitor it remotely, and document it
• Cleaning plan with responsibilities, intervals and cleaning agents, including the delivery compartment, lift and door seals
• Check incoming goods, and check use-by and best-before dates at every restocking
• Display allergens and mandatory information for unpackaged goods on the machine or on the display
• Define the procedure for a cooling failure
• Document the training and briefings of the people who restock

Which registrations a vending machine needs otherwise is explained in our guide Setting up a vending machine. For direct marketers, our guide is also worth a look: Vending machines for farm shops. We will advise you on choosing the right machine Monday to Friday from 10 am to 6 pm on +49 176 63463646 or by email to kontakt@vendspot.shop.

As of: October 2026. This overview does not replace legal advice in individual cases.