Guide
Upper tier or lower tier waste carrier: which are you?
Updated
Almost every argument about waste carrier registration is really an argument about the tier. The rule underneath it is short, and there is one exception that does most of the damage.
The one-line rule
The waste duty of care code of practice puts it in a single sentence: "An upper tier registration allows a person or organisation to transport other people's waste, while lower tier registrations are primarily for organisations carrying their own waste" (gov.uk). Everything else is detail hanging off that.
Register in the lower tier if you
- Transport waste you produced yourself, provided it is not construction or demolition waste.
- Are a charity or voluntary organisation.
- Are a waste collection, disposal or regulation authority acting inside your own area.
- Are a carrier, broker or dealer handling only animal by-products, waste from a mine or quarry, or waste from agricultural premises.
Register in the upper tier if you
- Transport construction or demolition waste, even if you produced it yourself.
- Transport waste created by someone else, for example a scrap collector taking waste from people's houses.
- Are a broker or dealer, unless you fall into one of the narrow lower tier categories above.
Both lists are taken from Natural Resources Wales's 'Choosing upper or lower tier' guidance, read on 15 August 2026. The tier tests come from the Waste (England and Wales) Regulations 2011, which apply in both nations; NRW registers Welsh businesses and the Environment Agency registers English ones.
The construction waste trap, in plain English
NRW's worked examples make the trap obvious once you see them side by side. An electrician or plumber carrying away pipe offcuts is lower tier. The same electrician or plumber carrying away a sink or a bath is upper tier, because that is construction and demolition waste. A gardener taking away shrubs is lower tier; the same gardener taking away construction waste is upper tier. A fencing contractor carrying away a fence they removed is upper tier, because fences count as construction waste.
One more line worth reading twice
NRW's table has a row for "lower tier waste carrier organisations" carrying construction and demolition waste, and a row for "lower tier registrants by virtue of waste types" carrying anything other than agricultural, mines and quarries or animal by-product waste. The second is upper tier. In other words, the lower tier is defined by what you carry, and it stops applying the moment you carry something else.
Registration numbers tell you the tier at a glance. The waste duty of care code says an upper tier carrier's registration number starts CBDU.