Thursday, November 23, 2017 | Today's Vending Industry News
It's Time For OCS To Preempt Government Labeling Regulation

by Matt Greenwald
Posted On: 4/7/2014

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TAGS: vending, office coffee service, coffee brewing, vending, OCS technical service, coffee equipment service, vending service, Matt Greenwald, FDA vending rules, Section 4205, Affordable Care Act

While the Food and Drug Administration works to finalize the rules and regulations required by Section 4205 of the Obama administration's Affordable Care Act, which mandates that nutritional information be visible to consumers before they make their selections, we might pause and consider the wider implications. Conforming to these new rules is estimated to cost the vending industry $30 million to make the necessary modifications to vending machines in the field today.

Though these new guidelines do not apply to the OCS sector, you don't need to be an alarmist to see that coffee service -- and other providers of beverage and food services -- are in the line of fire. No one expected a law designed for fast food chains to be extended to vending operators. OCS must work proactively to develop its own set of rules before the government does.

The reasoning behind the new vending regulation seems to be that glassfront merchandisers necessarily display their selections with only the front of the package visible, so consumers can't read the nutritional information (especially the caloric content) printed on the back. The FDA seems to believe that consumers may choose healthier options when making their purchase if they can read this information and, if they do, it will combat the nation's obesity problem which is said to cost our healthcare system an estimated $180 billion annually.

Coffee being the country's second most prevalent beverage, it's only a matter of time before someone starts working to extend that reasoning into the total workplace refreshment service business. Although office refreshment product packages generally can be picked up and examined from all sides, many questions might be raised about "serving sizes" of items in bulk packaging and so on.

OCS professionals can only benefit by taking this matter into their own hands by becoming proactive. Government intervention would create excessive and unnecessary expenses. The industry is more qualified than any government agency to police its business.

Does coffee even have caloric content? It does, although it's minimal. Black coffee contains 2 to 10 calories per cup, so that's obviously not the issue. What needs immediate attention is everything else on your list of product offerings: dairy and nondairy creamers, sugar and flavorings all add calories to the cup, often quite a few of them.

I am sure that vending operators will seek the assistance of snack and candy manufacturers, bottlers and other beverage distributors and the rest of the product supply community in developing packaging solutions that display the required consumer information. Coffee service operators need to explain to their suppliers that the challenge to the hot beverage industry is not restricted to OCS, and is not only the operator's problem. It is the supplier's problem, too.


Today's extensive and diverse choices of single-cup brewing methods -- cups through capsules, pods, cartridges, packs and packets to discs -- are generally not labeled for individual sale and do not provide the information that would be required to comply with regulations parallel to the ones imposed on vending. So we need to know what the manufacturers of single-serve options are doing to proactively comply, to take on their share of the responsibility, to participate in a voluntary industry movement before it stops being voluntary. It certainly will be to their advantage to do so.

What variances for caloric data would be acceptable to a government regulator? How is responsibility to be apportioned between supplier and operator? Black coffee has the least amount of calories; if you add sugar, chocolate, vanilla (French or any other kind) the calories rise. As we give the consumer more ways to customize a drink, the difficulty in determining the actual caloric content of the resulting concoction is considerable.

And what about allergens, caffeine content, artificial sweeteners, acidity and the like? Might we be held liable if a certain blend is more acidic than another and so upsets someone's delicate gastrointestinal system?

Let's start the dialogue.

Matt Greenwald MATT GREENWALD is the director of vending and OCS at Betson Enterprises (Carlstadt, NJ). Greenwald is a 20-year veteran of the commercial coffee equipment industry, where he's worked for roasters, distributors and manufacturers. Prior to joining Betson, he was vice-president of a national organization that provides installation, repair and maintenance services to some of the world's largest retailers, equipment manufacturers and coffee companies.