Which composite products are exempt from a CHED at the GB border — and when a private attestation replaces an export health certificate

Which composite products are exempt from a CHED at the GB border — and when a private attestation replaces an export health certificate

A shelf-stable chocolate bar with milk powder can clear without a CHED. A chilled quiche can't. The split is the meat-and-dairy content rule.

That single distinction sits behind most of the over-documentation I see on composite consignments. A composite product is any foodstuff that combines processed products of animal origin (POAO) — meat, dairy, egg, fishery, honey — with products of plant origin, where the plant element isn't just there to carry the animal element. Think chocolate (milk powder + cocoa), filled pasta, sauces, soups, biscuits, ready meals. Under the Border Target Operating Model (BTOM), GB sorts these into risk categories, and the controls that follow — a Common Health Entry Document (CHED) raised in IPAFFS, an export health certificate (EHC) signed by an official vet, a physical check at a Border Control Post (BCP), or none of the above — depend on the recipe and how the product is stored, not on the SKU or the label. This piece walks through which composites are exempt from SPS official controls, where the composite product exemption comes from, and when a private attestation does the job an EHC would otherwise do.

A note before we start: this is practical guidance, not regulated advice, and the rules genuinely move. Treat everything below as a way to ask the right question about your own product, then confirm the current position for your specific commodity code and route — or ask us.

What counts as a composite product at the GB border?

A composite product is a food that combines processed POAO with plant products, where the animal element is integral to the recipe — not a garnish or a trace. Per GOV.UK's guidance on importing composite products, the classification turns on what's actually in the product and how it's processed, which is why two foods that look similar on a shelf can sit in completely different control categories.

The word "processed" matters. Raw or chilled POAO — fresh meat, raw milk, unprocessed egg — isn't a composite question at all; it's straightforward POAO and carries full SPS controls in its own right. A composite is built from POAO that has already been processed (heat-treated, cured, fermented, dried) and then combined with plant ingredients. The combination is what creates the composite category, and the combination is what the exemption rules are written against.

Three things about a composite drive its treatment at the border:

• Does it contain meat (or meat products)? Any meat content is the hard line. A composite containing meat does not benefit from the headline exemption, full stop.
• What POAO does it contain other than meat — processed dairy, processed egg, processed fishery, honey? These are treated more leniently than meat, but not identically to each other.
• Is it shelf-stable (ambient-stable) or does it need refrigeration/freezing? A shelf-stable composite that needs no temperature control during transport and storage is the strongest candidate for exemption. A chilled or frozen composite is not.

Hold those three tests in your head; the rest of the piece is essentially the decision tree they form.

Which composite products are exempt from SPS official controls?

Composite products with no meat content, that contain only processed dairy, egg, fishery or honey, and that are shelf-stable at ambient temperature are exempt from SPS official controls at the GB border. They need no CHED, no IPAFFS pre-notification and no export health certificate — but they do require a private attestation kept by the importer.

This is the official controls derogation in practice. It isn't a loophole and it isn't a softening of standards; it's a derogation written into the rules because a fully processed, ambient-stable, meat-free composite carries a low SPS risk. The published criteria — the meat test, the shelf-stability test, and the qualifying POAO list — are what decide whether your product qualifies.

The headline conditions for the exempt composite products route are, broadly:

1. No meat or meat products of any kind in the recipe.
2. Shelf-stable at ambient temperature — the product does not need refrigeration or freezing to be safely transported and stored.
3. The only POAO present are processed dairy, egg, fishery products, gelatine, collagen, honey or similar — all of which must themselves have been produced to the required standards.

Get all three and you're generally looking at the composite product exemption. Miss any one — add a meat ingredient, or the product needs chilling — and you fall back into official controls and the CHED-P route.

A practical example. A boxed, ambient long-life custard made with milk powder: no meat, shelf-stable, processed dairy only. That's a textbook exempt composite — private attestation territory. Now reformulate the same brand's premium line into a chilled fresh-custard pot: still no meat, but it now needs refrigeration. Shelf-stability is gone, the exemption goes with it, and you're into CHED-P and pre-notification. Same brand, same shelf, different control regime — because the classification follows the recipe and the storage condition, not the product name.

What is a private attestation, and how is it different from an export health certificate?

A private attestation is a self-declaration the importer (or the business responsible for the consignment) draws up and keeps, stating that the composite meets the exemption conditions. No official vet signs it and no IPAFFS pre-notification is raised. An export health certificate, by contrast, is an official document signed by a certifying officer or vet in the country of export.

This is the line Tier A readers most often get wrong under time pressure: a private attestation is not a weaker EHC. The two documents do different jobs. For an exempt composite, the EHC was never the right document — the product sits outside official certification entirely, and the attestation is the correct, sufficient record. Treating the attestation as a "lite" certificate and chasing a vet signature you don't need is how exempt consignments get over-documented and delayed.

What the attestation does:

• It is a commercial document the importer holds, not a government-issued certificate.
• It states the qualifying conditions are met — no meat, shelf-stable, qualifying processed POAO only.
• It must exist and be retained, and be producible if asked. "Exempt" doesn't mean "no paperwork"; it means this paperwork instead of a CHED and an EHC.

So when does a private attestation replace an EHC? When the composite meets the exemption conditions in full. At that point the EHC and the CHED simply aren't the relevant documents — the attestation is. The error in the other direction is just as costly: assuming a composite is exempt, skipping both the attestation and the CHED, and discovering at the BCP that a meat or chilled element pulled the product back into controls.

When does a composite still need a CHED-P at the GB border?

A composite product needs a CHED-P — a Common Health Entry Document for products of animal origin, raised in IPAFFS before arrival — when it contains meat, when it is not shelf-stable (chilled or frozen), or when its POAO content otherwise keeps it inside SPS official controls. In those cases the consignment also needs an export health certificate and may be selected for checks at a BCP.

Put plainly, the CHED-P route is the default and the exemption is the carve-out. If your composite has any meat content, it's in controls regardless of how stable or processed it is. If it needs refrigeration, it's in controls even with no meat. The exemption is genuinely narrow, which is exactly why it's worth checking against your real recipe rather than assuming either way.

The other variable is BTOM risk categorisation. BTOM sorts SPS goods into risk categories that determine the frequency and intensity of checks. A composite you classified before the current rules landed may now route through a different control — or out of controls entirely — than your records assume. If your last classification predates the current BTOM position, that's a re-check worth running now, because a wrong assumption surfaces at the worst possible moment: at the border, with the consignment already moving.

What documents and steps does each route actually need?

Whether your composite is exempt or in controls, the route determines a short, specific list of what you need. Getting the route right first means you raise the right documents — and don't raise the ones you don't.

Exempt composite (no meat, shelf-stable, qualifying processed POAO):

• A private attestation, drawn up and retained by the importer.
• Correct commodity code classification on your customs declaration in CDS — exemption from SPS controls does not exempt the goods from a customs entry.
• Standard commercial documentation (invoice, packing list).
• No CHED, no IPAFFS pre-notification, no EHC.

Composite in SPS controls (contains meat, or is chilled/frozen, or otherwise in-scope):

• An export health certificate signed in the country of export.
• A CHED-P raised in IPAFFS before the goods arrive, linked to the EHC.
• Presentation at a BCP if selected for documentary, identity or physical checks.
• The correct commodity code on the customs declaration, plus any duty or relief that applies.
• Awareness that perishable holds compound by the hour — for a chilled composite, a missing or mismatched CHED isn't an admin problem, it's a spoilage clock.

The shared thread is the commodity code. SPS treatment and customs treatment are decided separately but read off related information about the product, so a sloppy classification can both misroute your SPS controls and land you on the wrong duty. Getting the composition documented accurately once — meat content, processing, storage condition, POAO percentages — feeds every downstream decision.

A worked example: triaging a real composite consignment

Say you're an ops lead and a new line is landing next month: a branded ambient sauce containing cream powder and a hard cheese, no meat, in retail jars, stored and shipped at room temperature. Here's the triage I'd run.

Step one — meat test. No meat, no meat products. It clears the first and hardest gate. (If there were even a small cured-meat ingredient, the analysis would stop here: CHED-P route.)

Step two — shelf-stability test. The product is ambient-stable retail stock, no refrigeration in transport or storage. It clears the second gate.

Step three — POAO test. The animal content is processed dairy only (cream powder, hard cheese), produced to standard. Processed dairy is on the qualifying list.

All three gates clear, so this looks like an exempt composite: private attestation, no CHED, no EHC. The job now isn't to raise an IPAFFS pre-notification — it's to make sure the attestation exists, is correct, and is retained, and that the commodity code on the CDS declaration is right. Before any of that, I'd confirm the current published conditions for this exact composition and route, because the criteria do change and the cost of being wrong sits at the border.

Now change one variable. The brand later adds a chilled fresh-pesto variant with the same cheese. No meat still — but it's chilled. Shelf-stability gone, gate two fails, and that variant needs an EHC and a CHED-P even though its sister product doesn't. Same factory, same cheese, two regimes. That's the whole point: every reformulation is a re-classification trigger. Change the storage condition or add an animal ingredient and the answer can flip.

How does this interact with labelling and customs?

Exemption from SPS official controls only settles the SPS question. It doesn't touch your customs declaration — the goods still need a correct commodity code and a CDS entry — and it doesn't touch labelling. Food information rules (FIC), allergen declarations and any market-specific requirements apply to an exempt composite exactly as they apply to anything else.

It's worth saying clearly because "exempt" is a slippery word. An exempt composite is exempt from one specific thing: SPS official controls at the border. It is not exempt from customs, from accurate classification, from duty, or from the labelling rules that govern what you can sell and how. I've seen importers relax across the board on the strength of an SPS exemption and trip over a commodity-code or allergen issue that had nothing to do with SPS. Keep the exemption in its lane.

Get the classification right before the consignment moves

The composite rules reward getting the question right early. Three tests — meat, shelf-stability, qualifying POAO — decide whether you need a private attestation or a CHED-P, an EHC and a BCP slot. The exemption is real and legitimate, but it's narrow, and it follows the recipe, not the brand. Re-check it whenever you reformulate, and whenever the rules move.

Borders are complicated. We aren't. If you've got a composite landing soon and you're not certain which route it takes, the Falsum Helpdesk triages live customs and SPS questions — including "is this one exempt?" before you raise a document you may not need.

Something held, or moving soon? The Falsum Helpdesk triages live customs & SPS issues: support.falsum.co.uk. Tell us the goods and the route — we'll tell you exactly what you need.

This article is practical guidance, not regulated advice. Rules on composite products change; confirm the current position for your specific commodity code and route with the official GOV.UK guidance, or ask us.

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