Use Classes and Change of Use

General industrial or storage: the B2 and B8 line

7 min readBy PlanScope Editorial Team

Packing, assembly and finishing on a distribution site can tip the use into Class B2. How the boundary is judged, what evidence each class attracts, and the permitted changes.

Whether a unit is b2 or b8 use class turns on what happens inside it, not on what the building looks like or what the marketing particulars call it. Class B2 covers use for an industrial process. Class B8 covers use as a storage or distribution centre. A steel-framed shed with dock levellers can be either, and the classification decides what evidence a planning application needs, what conditions the council imposes, and in some cases whether permission is needed at all.

The line matters most on sites where an occupier has drifted across it without anyone applying for anything.

What Class B2 general industrial covers

The Town and Country Planning (Use Classes) Order 1987, as amended, defines Class B2 as use for the carrying on of an industrial process other than one falling within Class E. The Order's definition of an industrial process is wide: making an article, altering, repairing, ornamenting, finishing, cleaning, washing, packing, canning, adapting for sale, breaking up or demolishing, or getting, dressing or treating minerals.

Two things follow. First, packing and adapting for sale are industrial processes, which matters enormously on distribution sites. Second, a process that could be carried on in a residential area without detriment to amenity falls within Class E instead, so the test for B2 is partly about the effect of the activity rather than its description alone.

In practice, B2 is where noise, vibration, fumes, dust, odour, shift working and heavy vehicle movement live. A council that grants a B2 permission is accepting all of those in principle, subject to conditions.

What Class B8 storage and distribution covers

Class B8 is use as a storage or distribution centre, including open air storage. The activity is the holding and onward movement of goods.

That covers a good deal more than racking. Order picking, consolidation, cross-docking, returns handling and vehicle loading are all part of a distribution operation. Self-storage sits awkwardly within it and is treated differently by different authorities, which is why the question in self-storage: use class and council requirements comes up so often.

What B8 does not cover is manufacture. And the moment goods are altered rather than moved, the question becomes one of degree.

Processing and packing on a distribution site

This is the real boundary, and it is decided on the planning unit and the primary use rather than on a percentage of floor area.

The approach follows the planning unit analysis set out in Burdle: identify the unit of occupation, then ask whether the activity in question is ancillary to the primary use or amounts to a separate main use. Shrink-wrapping pallets for despatch is ancillary to storage. Assembling components into a finished product, roasting coffee, cutting and sewing textiles, or spraying and finishing goods before despatch is an industrial process, and where it occupies a distinct part of the unit on a continuing basis it is capable of being a separate main use in its own right.

Signs that a council will treat the operation as B2 rather than B8:

  • Raw materials arrive and a different product leaves.
  • Plant is installed for a process rather than for handling.
  • Extraction, effluent, compressed air or three-phase power has been provided for the activity.
  • The activity runs on its own shift pattern.
  • The floor area given over to it is substantial and permanently laid out.

Where you are advising an occupier, the safe route is a lawful development certificate for the proposed use, because it is the only formal way to confirm that the activity is lawful. The general approach to defining the unit is set out in the planning unit and how councils decide what they assess.

Why the classification changes the environmental evidence

A B8 application is usually assessed on transport, amenity and hours. A B2 application attracts the environmental health officer, and the supporting documents change accordingly.

Issue Typical B8 requirement Typical B2 requirement
Noise Vehicle movements and yard activity assessed Process and plant noise assessed, often to BS 4142
Air and odour Rarely raised unless plant is proposed Extraction, emissions and odour often assessed
Hours Conditioned for deliveries Conditioned for operation as well as deliveries
Waste Servicing and storage area Process waste streams and any permit interface
Permits Uncommon Environmental permit may be required separately

Where a process is proposed, an assessment under BS 4142 for industrial and commercial sound is the usual starting point, and a Noise Impact Assessment prepared by a suitably qualified acoustician is what councils expect. Extraction and odour control on food or finishing processes will bring a separate request.

The environmental permitting regime runs alongside planning rather than within it. A permit does not grant planning permission and a permission does not grant a permit, and the two are determined by different bodies on different tests.

Trip generation differences between the two

The vehicle profiles are not comparable. A distribution unit generates fewer, larger, more predictable movements weighted to the trunk road network. A general industrial unit generates more staff trips across shift changes, more light goods movements, and a different peak.

That has consequences for the transport evidence. A trip generation chapter that uses distribution rates for what is in substance a manufacturing operation will understate the staff peak and overstate the articulated vehicle count. Where the use is uncertain, run both and present the worst case for each junction rather than choosing one.

For a smaller unit, a Transport Statement will usually cover it. Larger schemes cross the thresholds into a full assessment, and the highway authority will want to know which use class the trip rates were drawn from.

Permitted changes between them and their limits

Part 3 of Schedule 2 to the General Permitted Development Order 2015 allows certain changes involving these classes without a planning application, subject to conditions and floorspace limits. The scope has been amended repeatedly, including by the 2020 reform that replaced the old business class with Class E, so read the current text of the Order rather than an older summary.

Points that catch people out:

  1. A floorspace limit applies to some of the permitted changes. Exceed it and the right is lost for the whole building, not just the excess.
  2. The right depends on the lawful use immediately before the change, which has to be evidenced rather than assumed.
  3. Some changes carry a condition restricting later reversion, so the flexibility is not symmetrical.
  4. An article 4 direction can remove the right entirely in a defined area.
  5. Any operational development, including new plant, extraction or yard alterations, still needs its own permission.

Where the right applies, record the position in writing at the time of the change. Proving a permitted change five years later without contemporaneous evidence is far harder than it sounds.

Evidence of the lawful use on an older estate

On an industrial estate built in the 1970s, the lawful use is often a matter of history rather than of any surviving permission. Establishing it is a document exercise.

Start with the planning history for the unit and the estate, including the original permission and any conditions restricting use. Conditions are the usual trap: a permission granted for B8 with a condition tying occupation to storage and distribution overrides the general flexibility of the Order, and the Order cannot be used to escape it.

Then assemble the occupation evidence. Leases and licences, rating records, utility accounts, staff records, photographs and statutory declarations from people with direct knowledge. Where the use has been continuous and unchallenged for the relevant period, a certificate of lawfulness for an existing use is the formal route to confirm it.

Set the conclusion out in the Planning Statement with the evidence appended rather than asserted, because a case officer who cannot see the underlying documents will default to the most restrictive reading of the history.

This is general guidance, not 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. To see which reports an industrial or distribution scheme is likely to need, enter your postcode on PlanScope.

Frequently asked questions

Is packing an industrial process?

The Use Classes Order includes packing and adapting for sale within its definition of an industrial process, so it can fall within Class B2. Whether it does depends on the planning unit and whether the activity is ancillary to storage or amounts to a separate main use. Shrink-wrapping pallets for despatch is normally ancillary. A permanently laid out packing line running its own shift may not be.

Can I change a warehouse to a factory without planning permission?

Sometimes, under Part 3 of Schedule 2 to the General Permitted Development Order 2015, but the scope has been amended repeatedly and floorspace limits apply to some changes. The right also depends on the lawful use immediately before the change and can be removed by an article 4 direction or by a condition on the original permission. Read the current text before relying on it.

Does an environmental permit replace planning permission?

No. Environmental permitting and planning are separate regimes decided by different bodies against different tests. A permit does not authorise the development and a planning permission does not authorise the emissions. Where a process needs both, apply for them in parallel and make sure the assumptions in the planning evidence match those in the permit application.

How do I prove the lawful use of an old industrial unit?

Assemble the planning history first, including any condition restricting the use, because a condition overrides the general flexibility of the Order. Then gather occupation evidence such as leases, rating records, utility accounts, photographs and statutory declarations. Where the use has been continuous and unchallenged for the relevant period, apply for a certificate of lawfulness for an existing use.

Which use class generates more traffic?

They generate different traffic rather than more or less. Distribution produces fewer but larger vehicle movements weighted to the trunk road network. General industrial produces more staff trips across shift changes and more light goods movements, with a different peak. Using distribution trip rates for what is in substance a manufacturing operation understates the staff peak.

Sources and further reading

use classesb2b8industrialchange of uselawful development

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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