What is a lower-tier holder? I define that according to eBay rules about approved grading companies, i.e., PCGS, NGC, ANACS, and ICG. These companies have detailed databases listing certification values and also are considered by the numismatic community to be top-tier because of grading consistency.
I agree with eBay on coins in lesser-tier holders being treated as raw. These include several generations of PCI-holdered coins as well as those slabbed by Numistrust, Hallmark Grading Service, National Numismatic Certification, Precise Grading Authenticators, and others listed increasingly as lots in online auctions by Proxibid, HiBid, Liveauctioneers, and other venues.
Top auction houses such as Great Collections do not allow these lesser-holdered coins on their site, for good reason: They may use the Shelton 1-70 scale but often overlook scratches, damage, cleaning, artificial coloring, and other flaws that would earn a details grade at the major slabbing companies.
To be honest, I seldom bid on any of these off brands. When I do, I ignore what is on the label.
Increasingly, online auctioneers often use PCGS/NGC sight-unseen values for coins in these lesser holders. These coins sometimes are so flawed, they qualify only as silver melt.
Later PCI holders often overlook flaws and artificial coloring, as in this example: Grading coins in lower-tier holders | Coin Update
