Competence for a circular economy statement

There is no statutory competence standard for a circular economy statement, which is the first thing to understand if you are wondering who writes a circular economy statement. No licence, no chartered title, no register. What there is instead is a document that commits the development to measurable material outcomes, reported again after construction, and those commitments are only as good as the design team that made them.

That reporting stage is what changes the competence question. A statement written by someone who will not be on the project at completion creates obligations that nobody owns.

Circular economy statements are a London requirement. The London Plan asks for one on applications referable to the Mayor, and the Greater London Authority publishes guidance setting out the structure, the benchmarks and the templates. Outside London some authorities ask for similar material within a sustainability statement, but the formal regime with its post-construction report is a London one.

What the statement has to commit to

A Circular Economy Statement is a commitment document rather than an assessment. It has to say what the development will do, in numbers, across the whole life of the building.

The content falls into recognisable parts. How the scheme retains existing structures or justifies not doing so. How materials are specified for recycled and reused content. How the building is designed so components can be maintained, replaced and eventually recovered. What happens to demolition, excavation and construction waste by weight. And how the operational building manages waste once occupied.

The GLA guidance sets benchmark recycling and reuse figures for demolition, excavation and construction waste, and expects applicants to state their own targets against them. Check the current version of the guidance for the figures, because they have been revised and the templates change with them.

Retention is where the argument usually is. A statement that opens with demolition of a sound frame and no analysis of reuse will get a hard response from a GLA case officer, and the answer has to be an options appraisal rather than an assertion that retention was unviable.

Pre-redevelopment audit evidence behind it

You cannot write credible material commitments without knowing what is on site. A Pre-redevelopment Audit records the existing building by element and material: frame type, floor construction, facade build-up, internal fit-out, services, and the quantities of each.

That audit does three jobs. It establishes the baseline for reuse claims, it identifies hazardous materials that will constrain how carefully elements can be taken apart, and it gives the quantity surveyor something to price.

Audits are usually prepared by a demolition surveyor, a specialist consultant or an engineer with refurbishment experience, often alongside the asbestos survey because the access requirements overlap. Where the building is to be partly retained, get the audit done before the structural scheme is fixed, since the discovery of a reusable frame changes the design rather than the paperwork.

The common failure is an audit done too late to influence anything, produced after demolition is already in the programme.

Design team disciplines involved

Five sets of hands normally touch the statement, and the trouble starts when one of them has not been asked.

• The architect, who owns the layered design approach, the disassembly strategy and the material palette.
• The structural engineer, who decides what can be retained and what reused material can be relied on.
• The services engineer, who deals with plant replacement cycles and accessible routing.
• The quantity surveyor, who produces the bill of materials and prices the specification changes.
• A sustainability consultant or circular economy specialist, who assembles the statement, runs the calculations and completes the authority's templates.

The lead author is usually the sustainability consultant, and that is sensible as long as the commitments are signed off by whoever has to deliver them. A target for recycled content in concrete that the structural engineer has not seen will not survive the first value engineering exercise.

Where the project also needs a Whole Life Carbon Assessment, the two documents share inputs. The bill of materials, the retention assumptions and the replacement cycles should be identical in both, and a reviewer comparing them will notice if they are not. They answer different questions, so neither substitutes for the other.

Reporting templates and the authority's format

The GLA publishes spreadsheet templates to be submitted with the statement, and the data in them is what gets compared across schemes. Filling those in is technical work rather than drafting work, and it is the part most often underestimated.

Two practical points. The templates expect quantities by weight and by element, which means the cost plan and the structural quantities have to be available at application stage rather than at technical design. And authorities outside the GLA regime sometimes ask for the same information in their own format, so ask what format they want before you start.

A statement submitted without the completed templates will usually be treated as incomplete at validation, which costs weeks.

Post-construction reporting obligations

This is the part that distinguishes the circular economy statement from most planning documents. The regime does not end at permission. A report after completion sets out what was actually achieved against what was committed, using the same templates.

Three things follow from that.

The commitments need to be deliverable by the contractor who will be appointed, not by the design team that drafted them. Build the targets into the employer's requirements and the preliminaries, with the reporting duty passed down to the demolition and construction packages.

Someone has to hold the data through construction. Waste transfer notes, material delivery records and recycled content declarations are the evidence, and they are collected weekly or not at all.

And the reporting obligation is usually secured by condition or planning obligation, so failing to report is a breach rather than an oversight. Check the wording of the condition on your own permission for the timing, since it is the condition rather than the guidance that binds you.

Where specialist consultancy is needed

Most schemes can produce a defensible statement with the design team plus one specialist to assemble it. Bring in deeper expertise in three situations.

Where substantial retention is proposed and the structural reuse case needs testing, including material testing of existing concrete or steel. Where the scheme involves reclaimed structural components from elsewhere, which raises certification and insurance questions that a general consultant will not answer. And where the authority has queried an earlier submission, because responding to a GLA officer's comments is a different exercise from writing the original.

Professional review is worth having even where it is not required. The directory of reviewers on PlanScope's professional directory exists for exactly this: a drafted statement checked and signed by someone with the relevant discipline before it goes in. Nobody is required to sign a circular economy statement, but an unsigned document with no named author invites the question of who stands behind it, which is the same problem described in why every planning report needs a named author and date.

Keeping commitments deliverable

The test of a good statement is whether the post-construction report can be written without embarrassment. Four habits make that likely.

1. Set targets the contractor can hit on this site, with this demolition method, in this market, rather than copying benchmarks from a published exemplar.
2. Write the reporting duty into the building contract at the same time as the planning condition is discharged.
3. Keep one person responsible for the material data from application through to completion.
4. Record the departures honestly as they happen, with the reason, rather than reconstructing them two years later.

The honest uncertainty here is enforcement. Reporting obligations of this kind are new enough that practice on what happens after a missed target is still developing, and authorities differ in how closely they chase the report. That is not a reason to make commitments you cannot keep, since the condition is on your permission either way.

Browse all 66 report types on PlanScope if you want to see how the circular economy statement sits alongside the carbon and waste documents for the same scheme.

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. For specialist technical reports, qualified professional input may be required.