Circular economy statements and what they require

A Circular Economy Statement is a document about material flows: what the existing site contains, what the new building will be made of, how much of it can be reused or recycled at the end of its life, and what happens to the waste in between. In London it is required for applications referable to the Mayor, under the London Plan policy on reducing waste and supporting the circular economy, and the Greater London Authority publishes guidance that sets out both the content and the reporting format.

Outside London there is no national requirement. Some authorities ask for one through local plan policy or a validation checklist, often on major applications, and the content follows the London template because that is the only detailed guidance in the field.

What the statement has to demonstrate

The guidance asks applicants to show how circular economy principles have shaped the design, rather than to describe the principles and then present a conventional building.

Five design approaches carry the argument:

• Building in layers, so that elements with different lifespans can be replaced independently.
• Designing out waste at source, through standardised dimensions, off-site manufacture and reduced offcuts.
• Designing for longevity, with materials and details chosen for a long service life.
• Designing for adaptability and flexibility, so the building can change use without demolition.
• Designing for disassembly, with mechanical fixings in place of adhesives and bonded assemblies where practical.

Each needs evidence in the drawings. A statement that claims design for disassembly while the structure is a bonded composite deck will not survive review.

The bill of materials

The bill of materials is the part that takes time. It lists the materials in the proposed building by type and by mass, and it identifies the proportion that is reused or recycled content.

At planning stage the design is incomplete, so the bill is built from the elemental quantities that exist, with assumptions for the rest. Say which is which. A quantity taken from a structural engineer's schedule and a quantity assumed from a benchmark are different kinds of number, and presenting them identically invites a reviewer to distrust both.

The same quantities feed the carbon work. Where a Whole Life Carbon Assessment is being prepared, build one material schedule and use it for both documents. Two schedules produced independently will disagree, and the disagreement will be found.

Waste, and the numbers that get quoted

The statement sets out targets for construction, demolition and excavation waste, covering how much is diverted from landfill and how much is beneficially used. The London guidance publishes benchmark figures, and they are revised, so take the current values from the guidance rather than from an earlier statement.

Three distinctions matter when writing this section.

Excavation waste is not construction waste. Arisings from a basement dig are usually the largest single mass on a project, and moving them off site to be used elsewhere counts differently from recycling a broken concrete slab.

Diversion from landfill is not the same as reuse. Sending material for energy recovery diverts it from landfill and sits low in the waste hierarchy. Reusing an element in situ sits at the top. Report against the hierarchy rather than a single headline percentage.

And a target is not a mechanism. Where a figure is committed to, say how it will be achieved and how it will be reported after completion, because post-construction reporting is part of the requirement in London.

The existing building comes first

The strongest circular economy case is usually the one that keeps what is already there. Retention and refurbishment avoid the material flows entirely, and reviewers now expect the option to have been tested rather than dismissed.

That test needs evidence about the existing building. A Pre-redevelopment Audit records the structure, fabric, services and fittings, identifies what could be retained in place, what could be reused on site and what could be recovered for use elsewhere, and flags hazardous materials that constrain the options.

Do the audit before the design is fixed. An audit produced after a demolition scheme has been drawn is a compliance exercise, and it reads like one.

Where retention is not viable, say so with reasons that relate to the building rather than to the development appraisal alone. Structural capacity, floor to ceiling heights, grid spacing, contamination and the ability to meet current performance standards are arguments a reviewer can engage with.

Where it sits among the waste documents

Three documents get confused, and submitting the wrong one wastes a validation cycle.

A Site Waste Management Plan is a construction phase document. The statutory regime that once required one in England was revoked, so it now appears through planning condition or contract rather than through regulation, and it still carries the same content.

A Waste Management Strategy is about bins, bin stores, drag distances and refuse vehicle access. Councils have detailed standards for this, and the refuse team's comments are a common cause of late amendments.

Writing it so it holds up

Structure the statement around the guidance headings, in the order the guidance uses, so the reviewer can find each element. Put the bill of materials, the waste calculations and the assumptions in appendices with the sources named.

Then check three things before submission.

Consistency with the rest of the application. The demolition described in the circular economy statement, the demolition in the construction plan and the demolition in the carbon assessment must be the same demolition.

Commitments that can be conditioned. Vague aspirations cannot be secured, and a council that cannot secure a commitment will either impose its own wording or refuse to give the point any weight.

Post-completion reporting. Where the requirement includes reporting after construction, say who will do it and when.

Illustrative example. A mixed use scheme proposes full demolition of a 1970s concrete frame office. The audit finds the frame sound and the floor to ceiling heights workable for residential use on the upper floors. Retaining the frame and re-cladding changes the bill of materials substantially and removes most of the demolition waste from the calculation. This example is illustrative only.

One honest caveat

Circular economy reporting is young, and the data behind recycled content claims is uneven. A manufacturer's stated recycled content is often a national average rather than a figure for the batch delivered to your site, and end of life recovery rates are projections about markets decades away.

That does not make the exercise pointless. It does mean a statement should be candid about which numbers are measured and which are assumed, and a Circular Economy Statement drafted by PlanScope flags the inputs that have to be confirmed before submission.

This is general guidance, not legal advice. Check the adopted policy and validation requirements with your local planning authority before scoping the work.

PlanScope provides AI-assisted draft reports for planning applications. Reports should be reviewed before submission. We do not guarantee planning approval.