Circular Economy Statement and the pre-redevelopment audit
A Circular Economy Statement without a pre-redevelopment audit behind it is a set of intentions. The audit is what turns reuse targets into a schedule of actual material on an actual site.
A Circular Economy Statement explains how a development keeps materials in use: what is retained, what is reused, what is recycled, and how the building can be taken apart at the end of its life. The document that makes it credible is the Pre-redevelopment Audit, a survey of the existing building that records what is actually there. Without it, the statement is a list of intentions with nothing underneath, and reviewers spot that within a page.
The requirement began in London, where the London Plan asks applications referable to the Mayor to submit a statement and the Greater London Authority publishes guidance on what it should contain. Boroughs have since applied similar requirements to smaller schemes, and authorities elsewhere increasingly ask for the same material under sustainable construction or waste policies. Check the adopted plan and the validation list, because the scope varies far more than the subject matter does.
What the statement is asked to demonstrate
The structure that most authorities expect runs from the top of the waste hierarchy downwards.
Retention comes first. The question a reviewer asks before any other is why the existing building is being demolished at all, and a statement that does not answer it starts on the back foot. Where substructure, frame or facade can be retained, that is the largest single move available and it should be quantified.
Then reuse of components, either on site or through reclamation. Then recycling by material stream. Then recovery, with disposal to landfill as the residual figure. Alongside that sits the forward-looking half of the document: how the new building is designed so that its own materials can be recovered, which is where design for disassembly, adaptability and material passports come in.
The statement should also say who is accountable for delivering each commitment and at which stage, because a target with no owner does not survive value engineering.
The audit as the evidence base
A pre-redevelopment audit walks the building and records it. Structure and substructure, envelope and cladding, internal walls, floor finishes, ceilings, doors and ironmongery, sanitaryware, mechanical and electrical plant, lifts, and external works.
For each element the audit records quantity, material, condition, an assessment of reuse potential and the constraint that would prevent it. Hazardous materials are identified separately, because asbestos, ground gas protection and treated timber determine what can safely be reclaimed and what has to be handled under its own regime.
Timing decides how useful the audit is. Carried out before the design is fixed, it feeds retention decisions and can change the scheme. Carried out after the demolition package is let, it is an inventory of things about to be destroyed. The cost difference between the two is trivial and the outcome difference is not.
Access is the practical obstacle. A tenanted building cannot be opened up, and an audit based on drawings and visual inspection alone should say so and flag which assumptions need confirming through intrusive survey before work starts.
Reuse potential is a market question as much as a technical one. Steel sections, raised access floors, ironmongery, brick where lime mortar allows clean recovery, structural timber and mechanical plant with remaining service life all have routes to reclamation. Suspended ceiling tiles, most partition systems and bonded floor finishes generally do not, and claiming otherwise damages the rest of the document.
Record the route as well as the item. A component destined for reuse on the same site is a design decision. And a component destined for reuse elsewhere needs a receiving party, a storage arrangement and a programme, because the demolition contractor will not hold material indefinitely while a buyer is found.
Setting targets you can defend
Numeric targets belong in the statement, and they should come from the current guidance document your authority relies on rather than from another project's report. Take them from the source, name the source and give the version, because these figures have been revised.
Express targets by material stream and by weight or volume, and state the measurement method. A single headline diversion percentage tells a reviewer very little, and it is easy to hit by crushing concrete on site and calling it recycled aggregate.
Three commitments carry more weight than a table of percentages: a stated quantity of material retained in place, a named set of components going to reuse with a route identified, and a recycled content requirement written into the specification rather than into the planning statement. Reviewers have seen enough aspirational tables to discount them.
Where a target cannot be met, say so and give the reason. A statement acknowledging that a steel frame cannot be retained because of floor to ceiling heights is more persuasive than one claiming everything is possible.
Design for disassembly, in the details
Disassembly commitments fail when they live only in prose. The reviewer is looking for evidence in the drawings.
- Mechanical fixings in preference to adhesives and wet joints where the connection will need to be broken.
- Layered construction so that services, finishes and structure can be separated without destroying each other.
- Accessible fixings and junctions rather than buried ones.
- Standard component sizes and repeated grid dimensions, which make future reuse plausible.
- A material passport or bill of materials recording what is in the building and where, handed over at completion.
Realism matters here. A bill of materials at planning stage will be incomplete, and saying which elements it covers and which are indicative is better than presenting a spuriously precise schedule. The level of detail achievable before a contractor is appointed is limited, and reviewers know it.
Monitoring and the condition
Authorities normally secure the statement by condition and frequently require a post completion report setting out what was actually achieved against each target, submitted within a defined period after practical completion.
Read that condition before it is imposed. A condition requiring compliance with every figure in a document written eighteen months before the contractor was appointed can be difficult to discharge, and it is far easier to agree measurable wording at decision stage than to vary it afterwards.
On site, the reporting mechanism is usually the Site Waste Management Plan and the contractor's waste transfer records, which give the weights by stream that the post completion report needs. Set the reporting categories at planning stage so they match, because reconciling a target expressed in percentages against records kept in tonnes by carrier is an avoidable argument.
Keeping it consistent with the carbon work
The Whole Life Carbon Assessment and the circular economy work should be produced from one material schedule. Retention and reuse decisions move the upfront embodied carbon figure, and the end of life modules are where disassembly assumptions land.
Reviewers compare the two documents. Where the carbon assessment assumes a concrete frame and the circular economy statement describes a demountable steel one, both lose credibility. Where the two share quantities and assumptions, each strengthens the other.
Both are technical documents that councils usually expect a suitably qualified author to prepare, so use an AI-assisted draft for structure and policy framing and have the quantities and the audit produced by the survey team. Enter your postcode on PlanScope to see which sustainability documents a redevelopment on your site is likely to need.
PlanScope provides AI-assisted draft reports for planning applications. Reports should be reviewed before submission. We do not guarantee planning approval. For specialist technical reports, qualified professional input may be required.
Frequently asked questions
Which schemes need a Circular Economy Statement?
The requirement originates in London Plan policy and applies to applications referable to the Mayor, with the Greater London Authority publishing guidance on content. Boroughs have extended similar requirements to smaller schemes through local plans and supplementary documents, and authorities outside London increasingly ask for equivalent material. Check the validation list and the adopted plan before scoping the work.
What is a pre-redevelopment audit?
A survey of an existing building before demolition or strip out that records what it is made of and what condition those materials are in, so that reuse and recycling can be planned rather than improvised. It covers structure, envelope, internal fabric, services and fittings, and it identifies items with reuse value as well as hazardous material needing separate handling.
When should the audit be carried out?
Before the design is fixed, which in practice means at or before planning stage. An audit produced after the demolition contractor is appointed can only describe what is about to be lost. Carrying it out early lets retained elements influence the design, which is where most of the carbon and cost saving actually sits.
Do circular economy commitments get conditioned?
Usually. Authorities secure the statement through a condition requiring the development to be carried out in accordance with it, and often require a post completion report confirming what was achieved against the targets. Draft your commitments knowing they will be measured, and avoid absolute wording you cannot verify on site.
How does this relate to whole life carbon work?
They overlap and should be produced together. Whole life carbon assessment quantifies emissions across the modules of a building's life, and circular economy measures such as retention, reuse and design for disassembly are among the levers that reduce them. Using one material schedule for both keeps the two documents consistent, which reviewers check.
Sources and further reading
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.