Can a lunch van be treated as a canteen?

There is a lunch van which parks outside the office block and sells sandwiches etc. to our company’s staff, plus other workers in the same building. The company wants to use this to offer a free meal up to a set amount (initially £4.95), one day per week, for all employees at its main site, plus any colleagues visiting from its other sites.
Given the provisions of EIM21671: Note that the exemption applies to meals provided in any canteen. The canteen does not necessarily have to be on the employer’s premises, or restricted to the employees of one employer.
For example, on an industrial estate there may be a single canteen serving the employees of all employers on the estate. Meals provided in that canteen are within the exemption as long as they are available to all employees of the employers concerned. can this be treated as a shared canteen, and therefore not a BIK?

Hi Donna Lawrence
The forum can only give general advice and cannot comment on a scenario, such as this, as we may not be in possession of all the relevant information.
The business will initially have to establish if it meets the criteria for the exemption.
Please see guidance at: Expenses and benefits: meals for employees and directors: Overview.
Thank you.
 

Thanks for your response. I had already referred to the guidance you mentioned and wanted further clarification.