Beyond compliance: the real potential of circularity assessments
Nimit Raval of Pascall + Watson examines circularity assessments and evaluates their current implementation in the UK.
Over the past year, I have observed a consistent pattern in how circularity assessments are approached. On smaller projects, where the requirement is self-imposed or client-driven, the assessment tends to arrive early. It shapes conversations about what to retain, how to repurpose them, and which materials hold future value. However, the opposite may occur in larger, policy-mandated schemes. The Circular Economy Statement is submitted to satisfy a validation checklist, drafted retrospectively against a design that is already resolved. The document exists. The thinking it was meant to generate does not.
This is the central tension in the sector’s response to an increasingly demanding policy environment. Circularity assessments are becoming mandatory. On balance, that is a good thing. But a mandatory document is not automatically the same as a useful one.
In London, the framework is the most developed in the UK. Policy SI 7 of the London Plan 2021 requires Circular Economy Statements for all referable applications, broadly covering major developments above 15,000 to 20,000 square metres. The GLA’s three-stage process runs from a strategic draft at pre-application, through a detailed report including a Bill of Materials, recycling targets and whole-life carbon alignment, to a post-completion verification at handover. The London Plan targets 95% diversion of construction and excavation waste from landfill. These are not aspirational statements. They are quantified commitments, tracked throughout the planning process.
What is revealing is how individual boroughs have gone further. Camden applies GLA-standard statements to all major developments, not just referable ones. The City of London mandates pre-demolition audits for almost all significant schemes, requiring teams to understand what is already in a building before a design response is developed. Westminster, sharpened by the public debate around the Marks and Spencer Oxford Street proposals, now demands rigorous justification for demolition, including sixty-year whole-life evidence that a new building will meaningfully outperform a retrofit. Hackney takes a different approach, prioritising bio-based and timber-first strategies that return materials to biological cycles rather than simply diverting them from landfill.
These are not inconsistencies. They are, in their best form, policy specificity driving design specificity. The planning requirement is changing the design conversation. That is what it should do, and it is already happening in practice.
Outside London, the topic is gaining traction. Scotland’s National Planning Framework 4 has introduced a genuine national standard through Policy 12, making retrofit-first and material reuse formal planning hurdles for major developments in Edinburgh and Glasgow. Wales, shaped by the statutory obligations of the Well-being of Future Generations Act, is embedding long-term resource thinking into its planning culture in ways that are structurally different from England but no less serious. In England, progress depends heavily on local authority ambition. Bristol, Brighton, Cambridge and Greater Manchester are each advancing circular requirements through their own frameworks, at their own pace.
This variation is both a challenge and an opportunity. The risk is that circularity becomes a postcode lottery, applied rigorously in one local authority area and ignored in the next. The opportunity is that the places making genuine progress can teach the rest. Scotland’s retrofit-first mandate and London’s pre-demolition audit requirements address the same problem from different regulatory starting points. Bristol’s emerging resource strategies and Camden’s embodied carbon thinking are converging on the same outcomes. The sector must create a mechanism to systematically share this learning.
The common thread across every version of these assessments that genuinely shapes design is timing. A pre-demolition audit commissioned at the outset changes what gets designed. A Bill of Materials developed alongside the structural engineer, rather than assembled after planning consent, changes what gets specified. Circularity principles embedded at Stage 2 of the RIBA Plan of Work look fundamentally different from those introduced at Stage 4. The principles are not complicated. The discipline required to apply them at the right moment is.
The mandate is arriving. In London, it is already well established. Across the rest of the UK, the direction of travel is clear. The question now is not whether practices will submit Circular Economy Statements, but whether those statements will mark the start of a design process or the end of a compliance exercise.
