Circular economy statements: what the assessor checks
A reviewer traces every figure in a circular economy statement back to an audit or a drawing. What the targets measure and what counts as evidence.
Circular economy statement requirements bite in London first. Policy SI 7 of the London Plan 2021 requires referable applications to submit a Circular Economy Statement, and the Greater London Authority publishes guidance setting out what it must contain and how it is assessed. Outside London there is no equivalent national requirement, although a growing number of authorities ask for the same material under local plan sustainability policies.
The assessment is more forensic than most applicants expect. A reviewer is checking whether the numbers in the statement can be traced back to a drawing, a specification or an audit, and whether the commitments survive into a condition. Aspiration on its own scores nothing.
Which schemes are caught
Referability is set by the Town and Country Planning (Mayor of London) Order 2008, which captures schemes by size, height and location. The categories most architects meet are large residential schemes, tall buildings above the stated heights in and outside central London, and development on Green Belt or Metropolitan Open Land above the area thresholds.
Two practical points follow. A scheme that starts below the threshold and grows through design development becomes referable mid process, and the statement then has to be produced against a design that is already fixed. And a scheme that is not referable may still be asked for the same content by a borough applying its own local plan policy, in which case the Mayor's guidance is the obvious benchmark to work to.
The Circular Economy Statement sits alongside the whole life carbon work rather than inside it, and the two are assessed by different criteria even though they draw on the same bill of materials.
What the targets actually measure
The policy sets targets for the proportion of construction, demolition and excavation waste that is reused, recycled or recovered rather than sent to landfill. Read the current version of Policy SI 7 and the Mayor's guidance for the exact figures, because they are revised and a statement quoting an outdated target is an easy mark against it.
What trips people up is the denominator. Three separate streams are reported and they behave differently.
| Stream | What it covers | Where the difficulty lies |
|---|---|---|
| Demolition waste | Material arising from taking down existing structures | Requires an audit before demolition, not an estimate afterwards |
| Excavation waste | Soil and material from groundworks, usually the largest tonnage by far | Reuse on site depends on ground conditions and basement design |
| Construction waste | Offcuts, packaging and surplus from the new build | Driven by procurement and off site manufacture decisions |
Excavation waste dominates the tonnage on any scheme with a basement, so a statement that reports a strong overall percentage on the back of soil reuse while sending everything else to landfill will be read carefully. Report the streams separately and show the workings.
Recycled content in new materials is the other number. It is reported by value or by mass depending on the guidance version, and a statement that switches between the two without saying so loses credibility quickly.
Evidence for design for disassembly
This is where most statements are thin. The reviewer wants evidence that the building can be taken apart and its components recovered, not a paragraph saying that it has been designed with disassembly in mind.
What counts as evidence:
- Drawings or details showing mechanical fixings in place of adhesives and wet trades at specified junctions, with the junctions named.
- A structural strategy that separates the long life frame from shorter life fit out, with the floor to floor height and loading capacity stated so that future change of use is physically possible.
- Standardised grids and component sizes, with the dimensional coordination shown.
- A schedule of the elements intended for reuse at end of life, with the expected service life of each and the method of removal.
- Material passports or an equivalent record, and a commitment to maintain it, secured rather than promised.
Adaptability evidence is judged in the same way. A claim that the residential floorplate can become offices means very little unless the structural grid, riser provision, floor to ceiling height and means of escape have been checked against that use and the check is shown.
Off site manufacture usually helps the score, because volumetric and panelised systems are designed to be assembled and can be designed to be disassembled. The carbon side of that decision is more mixed, as our note on modern methods of construction and the carbon case sets out.
The link to the pre-redevelopment audit
The demolition figures in the statement have to come from somewhere, and that somewhere is a survey of the existing building carried out before anything is taken down.
A Pre-redevelopment Audit records what is on the site: the structure, the fabric, the fit out, the services and the external works, quantified by material type and assessed for reuse potential. Done properly it identifies the elements worth retaining in place, the components worth recovering for reuse elsewhere, and the material that can only be recycled.
Three things make an audit useful rather than decorative. It happens early enough to change the design, which means before the demolition contractor is appointed. It records quantities rather than descriptions. And it distinguishes between reuse in the same function, reuse in a lower function and recycling, because those are different outcomes and the statement reports them differently.
Retention of the existing structure is the strongest circular economy argument available, and it is increasingly the first question a reviewer asks. If the scheme demolishes a sound frame, the statement needs to explain why, and that explanation will be read next to the whole life carbon numbers.
Reporting after completion
The commitment does not end at determination. The Mayor's guidance requires a post completion report confirming what was actually achieved against the targets in the approved statement, submitted within a defined period after completion, and boroughs secure it by condition or obligation.
That changes how the statement should be written. Every target in it becomes something a contractor has to evidence with waste transfer notes and delivery records two or three years later. Targets that were written to impress the reviewer become targets that have to be met on site by people who never read the document.
Two habits help. Write each commitment so that the evidence that will prove it is named in the same sentence. And put the reporting obligation into the contractor's scope at tender rather than discovering it during handover.
Gaps a reviewer finds first
The recurring findings are unglamorous.
- Percentages with no tonnages behind them, so the reviewer cannot tell what the figures are a percentage of.
- Demolition figures estimated from floor area rather than taken from an audit.
- Design for disassembly described in general terms with no detail referenced.
- Excavation strategy silent on whether soil is reused on site, taken to another site or landfilled.
- Commitments phrased as intentions, using words like explore and consider, which cannot be conditioned.
- Inconsistency between the statement, the design and access statement and the whole life carbon assessment on the same material quantities.
The sixth is the most damaging because it suggests none of the documents were checked against the others. Reviewers do compare them.
Keeping it consistent with the carbon work
The Whole Life Carbon Assessment and the circular economy statement use the same quantities and the same assumptions about service life, so they should be produced from one model rather than by two teams working separately. Councils expect a suitably qualified author for the carbon assessment and professional review is strongly advised.
Where the two point in different directions, say so rather than hiding it. Retaining an existing concrete frame may cut upfront carbon while limiting future adaptability. A demountable steel frame may perform well at end of life and worse today. A reviewer who sees the trade set out and resolved will accept a reasoned answer. One who sees two documents making incompatible claims will not.
The infrastructure a scheme has to build carries material quantities of its own, and those are easy to leave out of both assessments, as our note on carbon in the infrastructure a scheme has to build explains.
Check the current London Plan guidance before you start, because the reporting template and the benchmarks are updated and a statement written to last year's version invites an avoidable comment.
Browse all 66 PlanScope report types to see which documents your scheme is likely to need.
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.
Frequently asked questions
Which applications need a Circular Economy Statement?
In London, applications referable to the Mayor under the Town and Country Planning (Mayor of London) Order 2008 must submit one under Policy SI 7 of the London Plan 2021. Outside London there is no national requirement, although some boroughs and authorities ask for the same content under local plan sustainability policies.
What is the difference between a circular economy statement and a whole life carbon assessment?
The carbon assessment measures emissions across the life of the building, reported by module. The circular economy statement measures material flows: how much waste arises, how much is reused or recycled, how much recycled content goes in and whether the building can be taken apart. They share quantities but are assessed against different criteria.
When should the pre-redevelopment audit be carried out?
Before the demolition contractor is appointed and early enough to change the design. The audit quantifies the existing structure, fabric, fit out and services by material type and assesses reuse potential. Figures estimated from floor area rather than taken from an audit are the most common weakness a reviewer identifies.
What counts as evidence of design for disassembly?
Named junction details showing mechanical fixings rather than adhesives, a structural strategy separating long life frame from short life fit out, standardised grids with dimensional coordination shown, a schedule of elements intended for reuse with removal methods, and a maintained material record. General statements of intent are not evidence.
Is there a reporting obligation after completion?
Yes. The Mayor's guidance requires a post completion report confirming what was achieved against the approved targets, and boroughs secure it by condition or planning obligation. That means every target in the statement has to be evidenced later with waste transfer notes and delivery records, so put the obligation into the contractor's scope at tender.
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.