📦 How to Start a Labor-Only Moving Company in Tennessee

Written By David Wagner

At-a-Glance Compliance Snapshot

  • Labor-only = no truck/transport. You supply crews to load/unload or move items on-site. You’re not a “for-hire motor carrier.” Legal Information InstituteTennessee State GovernmentJustia Law

  • No intrastate motor-carrier authority needed for labor-only operators (since authority applies to carriers transporting property by motor vehicle). If you ever add a truck and haul household goods, you must obtain Intrastate Authority and insurance filings (Forms E & H) through the TN Dept. of Revenue. Tennessee State GovernmentJustia Law

  • Sales tax: Charges to handle a customer’s own property (pure labor) are not subject to TN sales tax per a TN DOR letter ruling; you may still owe Business Tax/local business licensing based on receipts. Tennessee State Government

  • Local business licensing & Business Tax:

  • Workers’ comp: Required if you have 5+ employees (non-construction). Tennessee State Government

  • Unemployment insurance: Employers must register with TN Dept. of Labor to determine UI liability. Tennessee State Government

  • Consumer protection: Advertising and practices must not be unfair or deceptive under the Tennessee Consumer Protection Act (TCPA). Justia LawTennessee State Government

1) What Counts as “Labor-Only” in Tennessee?

You’re selling labor services only (loading, unloading, in-home rearranges, on-site moves). You do not transport goods on public highways. Because the state’s “for-hire motor carrier” rules cover transportation by motor vehicle, labor-only crews are outside that scope. If you add a truck later, you become a carrier and trigger authority/insurance filings. Justia LawTennessee State Government

2) Do Labor-Only Movers Need Intrastate Authority or a PUC Permit?

No—not when you do no transport. Tennessee’s Intrastate Authority program is for “for-hire motor carriers…on public highways,” with insurance filings Form E (liability) and Form H (cargo for HHG). Labor-only services don’t meet that definition. If you ever haul, apply via TNTAP and file the required insurance forms before operating. Tennessee State Government

Tennessee also has household-goods mover rules (estimates, claims handling, bill-of-lading disclosures) administered under Safety & Homeland Security regulations for carriers in intrastate commerce. They’re a useful template for your paperwork, but they apply to motor carriers—not pure labor-only services. Legal Information Institute

3) Business Formation & Core Registrations

  • Choose an LLC (common for liability separation).

  • EIN (IRS) for banking/payroll.

  • Local Business License & Business Tax thresholds (per jurisdiction):

    • < $3,000: no license.

    • $3,000–$100,000: Minimal Activity License from county/city clerk ($15, renew annually; no state Business Tax filing).

    • ≥ $100,000: Standard Business License and Business Tax filing. Tennessee State Government+1

4) Taxes for Labor-Only Movers (Tennessee-Specific)

  • Sales & Use Tax: Pure labor to move/handle the customer’s own tangible personal property is not taxable under TN sales tax (per TN DOR Letter Ruling 11-36). If you rent equipment/trucks as part of your service, those charges can change the taxability—keep them separate. Tennessee State Government

  • Business Tax (gross receipts): Classified by your dominant activity (service provider, typically Class 3). Licensing thresholds and rates are administered by TN DOR and local clerks. Tennessee State Government+1

5) Employment & Insurance

  • Workers’ Compensation: Mandatory at 5+ employees (non-construction). Many labor-only crews hit this quickly—plan accordingly. Tennessee State Government

  • Unemployment Insurance (UI): Register with TN Dept. of Labor; the state determines liability and assigns an employer account number. Tennessee State Government

  • General Liability (recommended): Covers property damage and third-party injuries during loading/unloading.

  • Occupational Accident / Voluntary MedPay (optional): Gap protection for small crews if you’re under the WC threshold.

6) Paperwork to Use (Tailored for Labor-Only)

While carrier-specific “bills of lading” are aimed at transporting movers, they’re a good model. For labor-only, use a Service Agreement that includes:

  • Scope: “Labor-only, no truck/transport provided.”

  • Locations, date/time windows, hourly or flat rates, minimums.

  • Customer prep responsibilities (parking, building rules, elevator reservations).

  • Liability/valuation terms for handling only, and claims process timelines (borrowing timing discipline from TN mover rules on claims can help). Legal Information Institute

  • Photo inventory language and an acknowledgment that fragile/self-packed items are handled at limited liability.

7) Honest Advertising & Consumer Protection

All marketing and customer communications must avoid unfair or deceptive acts under the TCPA (e.g., don’t imply you provide a truck; state “labor-only”). List clear rates, minimums, travel/time charges, and what is not included. The AG’s Consumer Affairs division accepts complaints—keep your paperwork tight. Justia LawTennessee State Government

8) Operational Tips that Win in Tennessee

  • List on rental-friendly marketplaces (U-Haul labor platforms, etc.) and Google Business Profile—DIY renters are your core customer.

  • Partner with storage facilities and apartment communities (especially in Davidson, Williamson, Knox, Hamilton counties).

  • Use crew checklists and job-site photos to prevent disputes; mirror the spirit of TN’s estimate/claims rules on timelines and transparency even though you’re labor-only. Legal Information Institute

9) Tennessee Market Landscape (Why Labor-Only Works Here)

  • Tennessee’s population hit ~7.23M (July 1, 2024), up ~79,000 year-over-year—net migration is the primary driver (domestic + international). That sustained in-migration keeps DIY moves and storage demand high. Tennessee State Data Center+1

  • 2025 updates from the Tennessee State Data Center show counties around Nashville (Davidson/Williamson)among the fastest-growing; net in-migration this decade exceeds 325,000 statewide. Tennessee State Data Center

10) Quick Compliance Checklist (Labor-Only, Intrastate)

  1. Form LLC with TN SOS; file Annual Report yearly. Tennessee Secretary of StateTennessee Secretary of State

  2. Get EIN (IRS).

  3. Register for local business licensing per receipts; add Business Tax if ≥ $100k. Tennessee State Government

  4. Confirm sales tax position (labor-only not taxable) and keep rentals separate. Tennessee State Government

  5. If 5+ employees, secure workers’ comp; register for UI. Tennessee State Government+1

  6. Use a labor-only service agreement with clear disclosures (no truck, rates, liability, claims timelines). (Best-practice reference from intrastate HHG carrier rules.) Legal Information Institute

  7. Keep ads TCPA-compliant; avoid any suggestion of transport. Justia Law

  8. If you ever add a truck/haul, apply for Intrastate Authority and file Forms E & H before transporting. Tennessee State Government

Source Links (Prioritizing Official TN Sites)

David Wagner
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