Circular Economy Statement: the reporting structure

A Circular Economy Statement is a quantified document with a narrative attached, and most weak ones get that the wrong way round. The circular economy statement structure that officers can actually assess runs from principles, through a measured material baseline, to targets and a commitment to report what happened after completion.

The requirement is largest in London, where the London Plan asks referable schemes for one and the Greater London Authority publishes guidance on what it should contain. Outside London it appears in local plan policies and validation lists in growing numbers, usually for major development. Check the adopted policy, because the content expected varies more than the name suggests.

Principles the statement has to address

Start by saying which circular economy principles the scheme applies and how. The usual set covers building in layers so that short lived elements can be replaced without disturbing long lived ones, designing out waste at source, designing for longevity and adaptability, designing for disassembly, and managing waste as a resource.

Write each as a design decision rather than an aspiration. "The structural grid is set at a spacing that allows a future change from office to residential without moving columns" is a principle applied. "The scheme supports circular economy objectives" is not.

A Circular Economy Statement that opens with three pages of definitions and reaches the building on page four tends to be read quickly and believed slowly.

Baseline material quantities and how they are estimated

The quantified core is a material baseline, broken down by building element and expressed by mass. Substructure, superstructure, envelope, internal finishes, fittings and external works each get a line.

At planning stage these come from an elemental quantity take-off against the design, not from a final bill of quantities that does not exist yet. Say which it is. Say what was estimated by rate and what was measured. A statement that presents planning stage estimates to three decimal places invites the officer to ask questions you cannot answer.

Two ratios do most of the work: recycled content as a proportion of the material by mass, and reused content as a proportion by mass. Both need a stated method, because a figure that counts recycled steel scrap at the mill is measuring something very different from one that counts salvaged brick.

Set the baseline against a reference case so the reader can see what the design is being compared with. Without a reference, a percentage is a number without a meaning.

Design for longevity, adaptability and disassembly

This is the section that separates a real statement from a compliance exercise.

Longevity is about expected service life by element and the maintenance regime that delivers it. Adaptability is about what the building can become: floor to ceiling heights that allow a change of use, loadings that allow a heavier future use, riser capacity, and a core position that suits more than one plan type. Disassembly is about how the elements come apart, which means mechanical fixings in place of adhesives and chemical anchors, accessible connections, and avoiding composite build-ups that cannot be separated at end of life.

Material passports come up here. A passport records what a component is, where it came from and how to take it out, and the planning stage commitment is usually to produce them for defined elements rather than to have them already.

Be honest about what is not adaptable. A basement car park is a basement car park.

Put a table in this section with one row per major element, giving the expected service life, the connection type, and whether the element can be removed without damaging what it is fixed to. That single table does more than several pages of prose, and it is the thing a reviewer will read first.

Where the scheme is residential, adaptability also covers the flats themselves. Layouts that allow a one bedroom flat to become a two bedroom flat without moving drainage, and party wall constructions that allow a knock-through, are the sort of measure that answers the principle rather than restating it.

Reuse of existing structure and materials

Retention beats reuse, and reuse beats recycling. Where a building is being demolished, the statement has to explain why, and that explanation now sits alongside whole life carbon arguments about the emissions already embodied in what is there.

The evidence base for reuse is a survey of what exists. A Pre-redevelopment Audit records the materials and components in the existing building, their condition, their quantity and whether there is a realistic route to reuse them on site, elsewhere, or through a reclamation market. Doing that audit before demolition rather than during it is the difference between a reuse strategy and a salvage anecdote. The companion piece on the circular economy statement and the pre-redevelopment audit covers how the two documents fit together.

Where reuse is proposed, say who is responsible for storage, testing and certification. Reclaimed structural steel needs a testing regime before it can be reused structurally, and a statement that skips that will be read as optimistic.

Waste targets and reporting metrics

The measurable commitments usually cover demolition waste, excavation waste, construction waste and, for some schemes, operational municipal waste from the completed building.

Each target should be expressed as a diversion rate from landfill or a recovery rate, with the tonnage it applies to and the method of measurement. Where the local guidance publishes benchmark figures, use those figures rather than inventing your own, and check the current version of that guidance because benchmarks are revised.

Waste on site is then managed through a plan that names responsibilities, segregation arrangements and the reporting route. A Site Waste Management Plan is the natural home for that detail, and the statement should reference it instead of duplicating it.

Avoid presenting a target you have no mechanism to deliver. A diversion rate that depends on a segregation facility the contractor does not have is a condition waiting to fail.

Excavation waste deserves its own paragraph on any scheme with a basement or significant level changes, because it dominates the tonnage and it behaves differently from the rest. Material that can be reused on site for landscaping or level formation never becomes waste at all, and saying so, with a volume, is worth more than a headline diversion percentage.

Municipal waste from the completed building is the part most often forgotten. Bin store capacity, segregation into the streams the council collects, and the route from store to collection point are all design decisions that belong on a drawing rather than in a sentence.

Post-completion reporting commitments

Most authorities that require a statement also require a post-construction report comparing what was achieved with what was promised, secured by condition or by a planning obligation.

Say in the statement what will be reported, who will produce it, and when. Twelve months after practical completion is a common trigger for operational waste data. The construction waste figures come earlier, from the contractor's returns.

This is the part applicants skip and the part that makes the regime mean anything. A statement that commits to reporting, with named metrics matching the ones in the baseline, is a statement someone intends to honour.

Where the statement overlaps with whole life carbon

The two documents share inputs and answer different questions. A Whole Life Carbon Assessment converts material quantities into emissions across the life cycle modules, including the benefits and loads beyond the system boundary that reuse and recycling produce. The circular economy statement works in mass and in design decisions.

Run them from the same quantity model. Where they disagree on the quantity of concrete in the frame, one of them is wrong, and the officer will find it.

The sensible sequence is to fix the quantity take-off once, feed both assessments from it, and cross-reference rather than repeat. That also makes it obvious when a design change during planning has invalidated both.

PlanScope drafts the narrative sections, the policy framing and the reporting commitments from your project inputs, and the quantity take-off and carbon modelling remain work for the design team and a qualified assessor. 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.