Who prepares a circular economy statement
A circular economy statement stands or falls on quantified material data. This looks at which member of the design team should lead it, where the tonnages come from, and who carries the post-completion reporting duty.
A circular economy statement is a quantity surveyor's document wearing a sustainability cover. The circular economy statement author who gets it accepted is whoever holds the material quantities: usually the cost consultant or the design team's sustainability lead, working from the architect's drawings and the structural engineer's schedules. A sustainability consultant can assemble and argue it. Nobody can write it without the numbers, and that is the reason so many first submissions come back with the same comment from the case officer.
The requirement bites hardest in London, where the London Plan asks for a Circular Economy Statement on referable applications and the Greater London Authority publishes guidance setting out the headings and the reporting duties. Outside London the same thinking arrives through local plan policy on waste, resource efficiency and sustainable construction, usually with less prescription about format.
What the statement has to commit to
This is not a statement of intent. It commits the applicant to measurable outcomes, and the commitments carry through to conditions and to post-completion reporting.
The substance is four questions. How much material is coming in, and how much of it is recycled or reused content. How much of the existing building and its materials are being retained or reclaimed rather than demolished. Where the demolition and construction waste is going, split by route. And what happens to the building at the end of its life, which is where design for disassembly comes in.
Each of those needs a number with a unit and a method behind it. A sentence saying the scheme will maximise reuse is worth nothing to the officer assessing it.
Material quantities and the data behind them
The quantities come from the same place as a cost plan: measured areas, element schedules and specification clauses. On a scheme at planning stage the information is incomplete, so the honest approach is to state the basis of the estimate, flag what is assumed, and commit to updating at the next design stage.
Three sources do most of the work.
- The architect's area schedule and demolition drawings, which fix what is going and what is staying.
- The structural engineer's frame and substructure schedules, which carry the heavy tonnages.
- The specification, which carries recycled content percentages for concrete, steel, insulation and plasterboard.
Where a figure is not yet known, say so and say when it will be known. Drafting software that quietly fills gaps does more harm than a visible flag, which is why PlanScope marks a missing site fact as to be confirmed rather than guessing a tonnage.
Reuse, recycling and disposal routes
Reporting a single diversion-from-landfill percentage is the old habit, and it hides the thing policy now cares about: the hierarchy. Reuse on site sits above reuse off site, which sits above recycling, which sits above energy recovery, which sits above landfill.
So the table in the statement should split waste streams by material and by route, with the destination type named. Crushing concrete for site fill is reuse. Sending the same concrete to an aggregate recycler is recycling. The distinction matters and officers do read for it.
| Stream | Preferred route | What the statement must show |
|---|---|---|
| Existing structure | Retain in situ | Structural appraisal of retention options and why they were rejected |
| Reclaimable elements | Reuse on site or off site | Pre-redevelopment audit identifying items, quantities and condition |
| Inert demolition arisings | Reuse as fill, then recycling | Tonnage, processing location, end use |
| Packaging and offcuts | Segregated recycling | Site waste procedures and the contractor's targets |
A Pre-redevelopment Audit is the natural evidence base for the top two rows, and it costs less before the demolition contractor is appointed than after.
Design for disassembly and adaptability
The end-of-life question is the one design teams find most awkward, because it asks them to design for a building they will never see taken apart. The practical answers are specific. Mechanical fixings rather than adhesives and wet trades. Bolted rather than welded connections where the structural case allows. Services in accessible zones. Floor-to-floor heights that would let a residential floorplate take a different use later. Standard component sizes.
Adaptability sits next to this and is easier to evidence, because it shows up in the plans. A ground floor with a 4 metre clear height and a separate entrance can change use without demolition. One with a 2.4 metre ceiling cannot.
But there is an honest tension here. Design for disassembly can add cost and sometimes carbon, and the statement should say where a trade-off was made rather than pretend every choice pointed the same way.
Reporting after practical completion
The commitment does not end at decision. Where the statement is secured by condition or by a section 106 obligation, the applicant has to report actual outcomes after completion: material quantities as built, waste tonnages by route, and the reasons for any departure from the commitments.
That has two consequences for who writes it. First, the author needs to understand what the main contractor will actually be able to record, because a commitment the site team cannot measure will not be reported. Second, somebody has to still be engaged at completion. A consultant appointed for a planning stage deliverable and demobilised at decision leaves a gap that the developer fills at its own cost.
An illustrative example
Illustrative only: a 120 unit scheme on a cleared industrial site, with a retained single storey brick office at the frontage. The quantity surveyor produces tonnages for frame, substructure and envelope. The sustainability consultant writes the policy framing and the hierarchy table. The architect confirms the retention of the brick office and the reuse of its roof slates on the new boundary wall. The structural engineer confirms bolted steel connections in the podium. The statement names a single person as responsible for the completion report. Five contributors, one document, and no contributor who could have produced it alone.
Who in the team should lead
Lead with whoever controls the quantities and can still be contacted in two years. On a larger scheme that is usually the cost consultant or a sustainability consultant with a cost background. On a smaller scheme it is often the architect, which works provided the structural tonnages come from the engineer rather than from a rule of thumb.
Councils expect the author to be suitably qualified for the technical content, and professional review before submission is strongly advised. The professional directory is the route to a reviewer who will sign off the technical judgements, and read what that sign-off actually covers before you brief one. On a contested scheme, a second opinion on the technical evidence is money well spent.
Interaction with whole life carbon work
The two documents share inputs and answer different questions. A Whole Life Carbon Assessment converts material quantities into kgCO2e across the life cycle modules. The circular economy statement takes the same quantities and asks about material flows, retention and recovery.
Commission them together from the same quantity data. Running them separately produces two documents with different tonnages for the same building, and an officer who spots that will doubt both.
PlanScope drafts a Circular Economy Statement structured to policy, with the headings and the policy citations in place and the gaps flagged for your team to fill. Reports should be reviewed before submission, and we do not guarantee planning approval. For specialist technical reports, qualified professional input may be required. This is general guidance, not legal advice; check the position with your local planning authority or a qualified professional before relying on it.
Frequently asked questions
Is a circular economy statement only required in London?
The formal requirement sits in the London Plan for applications referable to the Mayor, with Greater London Authority guidance on content. Outside London the same material is usually requested through local plan policy on resource efficiency and sustainable construction, or through a validation checklist, with far less prescription about format. Check the local validation list before assuming it is not needed.
Can an architect write it alone?
On a small scheme, yes, provided the structural tonnages come from the engineer and the specification carries real recycled content figures. On a larger scheme the quantities sit with the cost consultant, so the architect ends up compiling rather than authoring. The weak point in a single-author statement is almost always the substructure and frame tonnage.
What happens if the figures change after permission?
That is expected, because planning stage quantities are estimates. State the basis of each estimate and the design stage it came from. Where the statement is secured by condition, the post-completion report is where actual outcomes are declared, along with reasons for departure. Unexplained drift between the two is what causes problems.
How does it differ from a site waste management plan?
A site waste management plan is a construction phase document about handling and segregating waste on site. The circular economy statement is a design stage document about material flows across the whole life of the building, including retention of existing fabric and end-of-life recovery. They overlap on demolition arisings and should use the same tonnages.
Does design for disassembly always reduce carbon?
No. Mechanical fixings, demountable connections and oversized components can add material and therefore embodied carbon, even though they improve recovery at end of life. The statement is stronger when it names the trade-off and explains the choice than when it implies every circular measure also cut carbon.
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.