Use Classes and Change of Use

Funeral directors, laundrettes and dry cleaners: use class

7 min readBy PlanScope Editorial Team

All three of these uses were in the old shops class and now sit in Class E. What changes is not the classification but the plant, extraction and permitting that come with them.

The funeral director use class question has a short answer and a longer consequence. Before September 2020 the direction of funerals was expressly listed in the old shops class, alongside the washing or cleaning of clothes on the premises and the reception of goods to be washed or cleaned. When the Use Classes Order was amended, that content moved into the new Class E, so funeral directors, laundrettes and dry cleaning shops now sit in the commercial, business and service class. Moving into a vacant Class E unit is therefore not a change of use at all. The work is in the plant, the extraction and the permits.

Where these service uses sit after 2020

Class E covers retail sale of goods other than hot food, food and drink consumed mostly on the premises, financial and professional services, other services appropriate in a commercial, business or service locality, indoor sport and fitness, medical and health services, creches and day nurseries, and offices, research and light industry.

A funeral director's premises, a laundrette and a dry cleaning shop each fall within that list as services appropriate to provide in a commercial or service locality. So does a hairdresser, a post office counter and a travel agency, all of which were in the old shops class too.

Two qualifications matter more than the classification:

  • A condition on an earlier permission restricting the unit to a specific use overrides the flexibility of the class. A 2011 permission conditioned to retail use only still limits the unit
  • An Article 4 direction can remove permitted development rights, including the right to change from Class E to residential under Class MA, and several authorities have made directions covering shopping frontages

Check both before assuming there is nothing to apply for. The planning history of the unit takes ten minutes to look up and settles the question.

Funeral directors and the chapel of rest

A chapel of rest, a preparation room and a garage for a hearse are normally ancillary to the primary use of the premises as a funeral director, and ancillary elements do not need separate consent. Scale is the test. A chapel used for services attended by substantial congregations starts to look like a use in its own right, and a crematorium is a separate matter altogether, outside every class.

The planning issues that actually arise are practical ones. Arrivals and departures need to happen with dignity and without blocking the footway, which means off-street or clearly identified frontage space for a hearse and following cars. Refrigeration plant runs continuously and its noise reaches the flats above. And officers will ask about the frontage, because a funeral director's window is necessarily not an active retail display.

Preparation rooms bring in other regulators. Environmental health has an interest in drainage and waste, and human tissue handling is licensed separately from planning. Neither is a reason for refusal, though both belong in the covering statement so the officer knows they have been thought about.

Laundrettes, humidity and extraction

A laundrette is the extraction problem in this group. Tumble dryers discharge warm, moist, lint-laden air, and if that discharge is routed to a low-level grille it condenses on the neighbouring shopfront and on passers-by.

What works is a duct taken to roof level with a termination away from openable windows, adequate make-up air, a lint filtration arrangement that someone will actually clean, and fan selection with the noise level at the nearest residential window calculated rather than assumed. Where the unit is in a building with flats above, the riser route is usually the constraint, and it is worth establishing whether there is one before signing the lease.

A Ventilation and Extraction Statement covering the duct route, the termination height, the fan and its attenuation, and the maintenance regime answers most of what an environmental health officer will ask. Long opening hours are common in this sector and they need to be requested explicitly, because a condition restricting hours to 08:00 to 18:00 will make the business unviable.

Dry cleaning solvents and the permit you may need

Dry cleaning that uses organic solvents is regulated for emissions separately from planning. In England, dry cleaning installations using solvents are Part B installations under the environmental permitting regime, permitted and inspected by the local authority rather than by the Environment Agency. That permit is a distinct application with its own fee and its own conditions on machine type, enclosure, leak testing and record keeping.

Two consequences for a planning application. First, say in the planning statement that the permit will be obtained, and do not offer planning conditions duplicating its controls, because a condition that replicates another regime fails the necessity test. Second, machine selection affects the planning case: modern closed-circuit machines with integral carbon adsorption have very different emission and odour characteristics from older equipment, and the officer will want to know which is proposed.

Historic dry cleaning premises carry a contamination legacy. Chlorinated solvents migrate through floor slabs into underlying soil and groundwater, and they are persistent and mobile. Where a former dry cleaners is being converted to housing, expect the authority to require a Land Contamination assessment with vapour risk addressed, prepared by a suitably qualified person.

Hours, deliveries and hearse parking

Servicing is where these uses differ from a shop. Laundrettes take deliveries of chemicals and, if they run a service wash, bulk linen. Dry cleaners take solvent deliveries subject to carriage rules. Funeral directors take deliveries at unpredictable hours by the nature of the work.

Set out the servicing arrangement plainly: vehicle type, frequency, time of day, where it stops, and how long for. On a narrow parade with no rear access, that is the difference between approval and a highways objection. A short Transport Statement is worth preparing where the parade already has a loading problem.

Illustrative example: a 75 m² mid-parade unit converted from a former card shop to a laundrette, with a 250 mm duct in an existing riser to a roof terminal 2.5 m above the eaves, an acoustic enclosure to the extract fan, and opening hours of 07:00 to 21:00 daily. Details here are illustrative only.

Frontage policies in a shopping parade

Local plans commonly protect primary shopping frontages by resisting non-retail uses at ground floor level, and some set a maximum proportion of non-retail frontage in a defined parade. The difficulty is that Class E already permits movement between retail and services without any application, so those policies can only bite where a condition, an Article 4 direction or a genuine change out of Class E is involved.

Where a policy does apply, the arguments that work are about activity and appearance rather than about the label. A window display, an active interior visible from the street, evening use and a reason for passers-by to stop all support a frontage. A blanked-out window with vinyl graphics does not, which is why officers push back on it.

Security shutters follow the same logic. Solid external roller shutters over a shopfront normally need planning permission and are routinely resisted in conservation areas and on protected frontages. Open-grille shutters set behind the glass line are the usual compromise. Uses that sit outside Class E, such as a hot food takeaway, face a different test again, as our note on hot food takeaway as a sui generis use explains.

Conditions to expect on plant and extraction

Where permission is needed, the conditions are predictable and worth pre-empting in the submission:

  1. Plant and extraction to be installed in accordance with approved details, and retained
  2. A rating level limit for plant noise at the nearest noise sensitive facade, usually expressed against the background
  3. Odour control equipment to be maintained in accordance with a submitted schedule
  4. Opening hours, and separate delivery and servicing hours
  5. No external flues, ducts or condensers other than those approved
  6. Waste storage and collection arrangements

Offer the first three yourself, with the supporting detail. A Noise Impact Assessment for the plant, done properly at application stage, avoids the condition that requires a scheme to be approved later and holds up fit-out.

Evidence on the existing lawful use

Everything above depends on knowing what the unit lawfully is. Assemble the planning history from the authority's online register, the rating list description, the lease and its permitted user clause, and dated photographs of the frontage. Where the unit has been vacant for years and the previous use is unclear, a lawful development certificate for the existing use settles it before you spend money on fit-out.

Browse the PlanScope report library to see which documents a change of use in a parade is likely to need.

This is general guidance rather than legal advice. Check the position with your local planning authority or a qualified professional before relying on it. PlanScope provides AI-assisted draft reports for planning applications. Reports should be reviewed before submission. We do not guarantee planning approval.

Frequently asked questions

What use class is a funeral director in?

Class E. The direction of funerals was expressly listed in the old shops class, and that content moved into the commercial, business and service class when the Use Classes Order was amended in 2020. A chapel of rest and a hearse garage are normally ancillary to that use rather than separate uses.

Do I need planning permission to open a laundrette in a former shop?

Not for the change of use, if the unit is lawfully in Class E, because both uses fall within that class. You will usually need permission for the external extract duct and any plant, and the environmental health team will want the duct route, termination height, fan noise and maintenance regime set out.

Do dry cleaners need an environmental permit?

Dry cleaning installations using organic solvents are Part B installations under the environmental permitting regime in England, permitted and inspected by the local authority. That is a separate application from planning, with conditions on machine type, enclosure, leak testing and records. Do not offer planning conditions that duplicate it.

Can a council refuse a service use on a protected shopping frontage?

Only where it has a mechanism. Class E permits movement between retail and services without an application, so frontage policies bite only where a condition on an earlier permission restricts the use, an Article 4 direction applies, or the proposal moves out of Class E altogether.

What contamination risk comes with a former dry cleaners?

Chlorinated solvents used in dry cleaning are persistent and mobile, and can migrate through floor slabs into soil and groundwater. Where such premises are converted to residential use, expect the authority to require a contamination assessment addressing vapour risk, prepared by a suitably qualified and experienced person.

Sources and further reading

use classesclass echange of useextractiondry cleaninghigh street

This article is general guidance about the planning system in England and, where stated, the rest of the UK. It is not legal or professional advice. Check your local planning authority’s validation requirements and take professional advice for your specific site.

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