Circular economy statements: reuse targets and evidence
Diversion from landfill, recycling and reuse are three different numbers, and statements that report only the first are answering the easy question. How to build the evidence instead.
A circular economy statement has to show what happens to the materials already on the site, what the new building is made of, and what happens to all of it at the end. It is a London Plan requirement rather than a national one, so the circular economy statement content expected of you depends first on whether the scheme is referable to the Mayor or falls within a borough policy that has adopted the same approach.
Outside London the same thinking appears under different labels, usually inside a sustainability statement or as a condition requiring a materials and waste strategy. The structure below works for both.
What the statement has to demonstrate
Four things, in roughly this order.
That the existing building and the existing materials on site have been assessed for retention and reuse before demolition was proposed. That the new building has been designed to use fewer materials, with recycled and reused content where practical. That the building can be adapted, maintained and eventually taken apart without destroying the components. And that the waste arising during demolition and construction will be measured, diverted from landfill and reported.
The Greater London Authority's guidance sets out the format, including headline targets for diverting demolition, excavation and construction waste from landfill, and a reporting template completed at planning stage and again after construction. The targets and the template are updated, so work from the current published guidance rather than a version carried over from a previous project.
A Circular Economy Statement drafted to that structure is a starting point. The numbers in it have to come from the design team and the demolition contractor.
The pre-redevelopment audit as the starting point
You cannot commit to reusing materials you have not counted. The pre-redevelopment audit is the survey that establishes what exists: the structure, the facade, the internal fit-out, the services, the external works, and the quantities and condition of each.
A useful audit records, for each material stream, the estimated quantity, the condition, whether it can be reused in place, reused elsewhere on site, reused off site, recycled or only disposed of, and any contamination or hazardous content that limits the options. Steel sections, bricks, precast units, raised floors, doors, sanitaryware and external paving are the streams that most often find a second use.
It runs alongside the asbestos and hazardous materials survey rather than replacing it, and the sequencing matters because a material identified as reusable may be ruled out once the hazardous materials survey is complete. A Pre-redevelopment Audit prepared early enough to influence the design is worth several times one prepared to satisfy a condition.
Do the audit before the demolition strategy is fixed. An audit that arrives after the demolition contractor has priced a full clearance changes nothing.
Targets for reuse, recycling and diversion
Three different measures get confused with one another, and a statement that mixes them up invites a request for clarification.
| Measure | What it counts | Common pitfall |
|---|---|---|
| Diversion from landfill | Waste sent anywhere other than landfill, including energy recovery | Treated as if it were recycling |
| Recycling rate | Waste reprocessed into new material | Includes downcycling such as crushing concrete to fill |
| Reuse rate | Components used again in their existing form | Usually the smallest number, and the hardest to achieve |
Diversion figures are high across the industry because crushing concrete for site fill counts. Reuse figures are low. A statement that reports a very high diversion rate and says nothing about reuse is answering the easy question.
Set targets you can evidence. A target to retain the existing substructure and reuse the crushed arisings as sub-base is verifiable. A target described as maximising reuse where feasible is not, and an officer will ask what it means.
Design for disassembly and adaptability
This section is where statements get thin, because it asks about a building that does not exist yet.
Concrete answers exist. Bolted rather than welded steel connections. Mechanical fixings rather than adhesives on facade panels. Services run in accessible zones rather than cast into structure. Floor to floor heights and structural grids that accommodate a change of use later. Raised floors and demountable partitions. A material passport or a component schedule handed over at completion so a future team knows what is in the building.
Say which of these the scheme adopts and which it rejects, with the reason. A statement that lists every principle and commits to none reads as a template.
Adaptability also connects to the wider design case. Where a scheme proposes a structural frame with generous floor to ceiling heights to permit future conversion, that argument sits naturally alongside the carbon case for offsite manufacture set out in our note on modern methods of construction and the carbon case.
Reporting format and the summary table
Officers read the summary table first. It should give, on one page, the total floor area, the existing building's fate, the headline waste quantities by stream, the diversion, recycling and reuse figures, the recycled content of new materials, and the commitments carried into conditions.
Everything else supports that page. Keep the methodology short, state the assumptions, and put the detailed quantity tables in an appendix.
Two numbers should reconcile with other documents. The demolition arisings should match the pre-redevelopment audit. The material quantities should match the bill used for the carbon work.
Links to the whole life carbon assessment
The two documents share data and answer different questions. The carbon assessment asks what the emissions are across the life cycle. The circular economy statement asks what happens to the materials.
Run them off one quantity take-off. Where a Whole Life Carbon Assessment reports module A1 to A3 emissions from a given tonnage of concrete, the circular economy statement should show the same tonnage, and the end of life modules should reflect the same reuse and recycling assumptions the circular economy statement claims.
Inconsistency between the two is the most common reason a reviewer sends both back. It is also the easiest thing to avoid, because it is a coordination problem rather than a technical one. Both documents benefit from a suitably qualified author, and professional review before submission is strongly advised.
Conditions and end of project reporting
Expect the commitments to be conditioned. Typical wording requires a post construction report demonstrating the targets were met, submitted within a set period of practical completion, with evidence from waste transfer documentation.
That has two consequences. Only commit to targets the contractor can evidence, because the condition will be checked against waste transfer notes rather than intentions. And write the reporting requirement into the contractor's scope at tender, since a contractor appointed without it will charge to add it later.
Where the scheme is phased, agree with the authority whether reporting is per phase or for the whole development. Getting that decided at the point the condition is drafted avoids an argument three years later, and the same coordination logic applies to phased energy infrastructure, as our piece on energy masterplanning for a phased site sets out.
This is general guidance, not legal advice. Check the position with your local planning authority or a qualified professional before relying on it.
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Frequently asked questions
Is a circular economy statement required outside London?
Not as a national requirement. It is a London Plan policy applying to referable applications, with some boroughs adopting the same approach. Outside London the equivalent material usually sits inside a sustainability statement or is secured by a condition requiring a materials and waste strategy. The structure and evidence expected are broadly the same.
What is the difference between diversion, recycling and reuse?
Diversion counts waste sent anywhere other than landfill, including energy recovery, so the figure is usually high. Recycling counts waste reprocessed into new material, which includes downcycling such as crushing concrete for fill. Reuse counts components used again in their existing form, which is the smallest and hardest number to achieve and the one reviewers look for.
When should the pre-redevelopment audit be carried out?
Before the demolition strategy is fixed, so its findings can influence what is retained and how the building is taken apart. An audit produced after a demolition contractor has priced full clearance changes nothing. It runs alongside the asbestos and hazardous materials survey, because a material identified as reusable may be ruled out once that survey is complete.
How do the circular economy statement and the carbon assessment relate?
They share data and answer different questions. Run both from a single quantity take-off so the tonnages reported for concrete, steel and other materials match, and so the end of life assumptions in the carbon assessment reflect the reuse and recycling claimed in the circular economy statement. Inconsistency between the two is the usual reason both are returned.
What do the conditions usually require?
A post construction report demonstrating the targets were met, submitted within a set period after practical completion, evidenced by waste transfer documentation. Only commit to targets the contractor can evidence, and write the reporting obligation into the contractor's scope at tender rather than adding it afterwards. Agree phase by phase reporting on phased schemes when the condition is drafted.
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.