Circular Economy Statements: who needs one and what it covers

A Circular Economy Statement is a London requirement, not a national one. It is expected for applications referable to the Mayor under the London Plan waste and circular economy policy, and it asks a different question from the rest of the sustainability pack. Instead of how much carbon or energy the building uses, it asks what happens to the materials: where they come from, how long they last, whether the building can be changed rather than demolished, and what can be recovered when it eventually comes down. Outside London there is no equivalent requirement, and saying so clearly saves clients a document they do not need.

Which applications need a statement

Referability is set by the Town and Country Planning (Mayor of London) Order 2008. Schemes that reach the Mayor's thresholds, which capture larger residential developments, tall buildings above stated heights depending on location and certain other categories, are expected to submit a statement with the application.

Some boroughs ask for a version of the document below those thresholds through their local plan policies or validation lists. Check the borough's list rather than assuming the Mayor's thresholds are the boundary.

The statement is submitted at application stage and followed by a report after completion, so treat it as a two stage obligation from the beginning. A Circular Economy Statement written as a one-off document at validation is the version that causes trouble three years later.

Designing for longevity, adaptability and disassembly

The first substantive section deals with how long the building will last and how easily it can change.

Longevity covers the design life of the structure, the envelope and the services, and the maintenance regime that keeps them going. Give figures for the structural frame and the facade, and say which components are expected to be replaced within the building's life.

Adaptability is about future use. Floor to ceiling heights that allow a change from one use class to another, a structural grid that permits subdivision, riser capacity with spare provision, and loading capacity above the minimum for the current use. These are design decisions made early and impossible to retrofit, so the statement should point at drawings rather than intentions.

Disassembly is about connections. Bolted rather than welded steel, mechanically fixed rather than adhered finishes, screeds separated from slabs, services that can be withdrawn without breaking out structure. Where the design team has made those choices, name them and show the details. Where it has not, the statement should say so honestly rather than describing the ambition.

Material selection and reused content

This section needs a materials strategy with quantities, not a list of aspirations.

Cover the proportion of material by mass or value that is reused, that contains recycled content, and that is responsibly sourced under a recognised certification scheme. Identify where reused components are actually specified, such as steel sections from a donor building, reclaimed brick, or crushed demolition arisings used as fill.

Reuse claims get tested. If the statement claims reclaimed brick for a facade, the reviewer will ask where the brick is coming from and whether the supply is committed. A claim with no source behind it is worse than no claim, because it undermines the parts of the document that are sound.

Material passports are the mechanism for recording what has gone into the building so that a future owner can recover it. They are increasingly asked for, and the practical question at planning stage is who compiles the passport, in what format, and where it is lodged. Answer those three, and the commitment becomes real.

Pre-redevelopment audits and demolition waste

Where an existing building is being removed, the audit comes first. A Pre-redevelopment Audit records what is on the site, its condition, and what can be reused in place, reused elsewhere or recycled.

Do it before demolition is designed, not afterwards. An audit carried out once the demolition contract is let discovers opportunities that can no longer be taken, and the statement then describes a recovery strategy nobody can deliver.

The audit should cover structure, envelope, internal fabric, fittings and services, with quantities and a destination for each category. It also picks up hazardous material, which is a separate regulatory question with its own cost and programme consequences.

Retention deserves testing here as well as in the carbon work. The circular economy argument for keeping a structure is usually stronger than the argument for recycling it well, and the Mayor's policies push in that direction.

Targets and how they are reported

The guidance sets diversion benchmarks for demolition, excavation and construction waste, and expects performance against them to be reported. Take the current percentages from the guidance itself rather than from an earlier scheme, because these have been revised.

What the reviewer looks for is the mechanism behind the number. Segregation on site, a waste management contractor with reporting capability, and a nominated person who collects the data. A benchmark quoted without a mechanism is a statement of hope.

Record the assumptions in the same way as any other technical document.

• The gross internal area and the unit numbers, matching every other document in the application.
• The tonnage estimates for demolition, excavation and construction waste, and how they were derived.
• The diversion route assumed for each stream, and whether recovery includes energy recovery.
• The contractual mechanism by which the targets will be passed down.

A Site Waste Management Plan is the operational document that carries much of this through construction, even though the statutory regulations requiring one were revoked, because contractors and councils continue to use the format.

The post-completion report

The London regime asks for a report after the building is finished, comparing what was delivered against what was committed. It is normally secured through the section 106 agreement rather than by condition.

Plan for it at procurement. The data needed, waste transfer records, actual material quantities, recycled content certificates, has to be collected as the work proceeds. Reconstructing it afterwards from invoices is expensive and incomplete.

Name the party responsible in the obligation. On schemes where the developer sells the completed building, the duty needs to sit somewhere that survives the sale, and that is a drafting question rather than a technical one.

Where it overlaps with whole life carbon

The two documents share inputs and are read together, so they need to agree.

The Whole Life Carbon Assessment takes the material quantities, the reused content and the end of life assumptions from the same strategy. Reused steel claimed in one document and absent from the other is the contradiction reviewers find first, and it costs credibility across both.

Agree a single controlled set of figures at the start: floor areas, storey heights, structural system, material quantities, reference study period, demolition tonnages. Issue it as one sheet and require both consultants to work from it.

The division of labour is reasonably clean once that is settled. Carbon counts emissions. The circular economy statement deals with material flows, adaptability and recovery. The overlap is the material schedule, and that is where the coordination effort belongs.

This is general guidance, not legal advice. Check the current London Plan guidance and your borough's validation requirements before relying on it.

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