How is planning policy influencing and supporting the development of the circular economy in the built environment and what actions are local authority planners taking to support circularity and reuse? What role do pre-demolition audits (otherwise known as pre-deconstruction/pre-refurbishment audits or material inventories) play in this?

Reusefully are working on a wide range of projects around London and also in cities including Glasgow, Edinburgh, Manchester, Cambridge and Bristol, as well as projects in smaller urban centres and rural areas across the UK. Many of these projects have a direct relationship to the range of planning requirements now being introduced across the UK.

In London, GLA Circular Economy Statements (CES) are required for all ‘referable developments’, which are typically developments of a larger scale, for example residential sites of more than 150 proposed dwellings or commercial schemes of more than 20,000 square metres inside central London. or 15,000 outside of the centre. These have been a requirement since 2021.

It is important to meet the requirements for Pre-Demolition Audits  which sits within the CES. An audit is defined as detailed inventory of the materials in the building that will need to be managed upon demolition. At pre-application stage, applicants are strongly encouraged to submit an independent audit where demolition is proposed. If substantial demolition is proposed, the audit should include core information such as an explanation as to why it is proposed that the building(s) be demolished, and a summary of the key components and materials present in the existing buildings, with an estimate of the quantities and associated embodied carbon and whether they are suitable for reclamation.

Where possible, additional best practice information should be included including a description of the value of existing building elements or materials can be recovered and a schedule of practical and realistic providers who can act as brokers for each of the reclaimed items, together with target reuse and reclamation rates. The London Plan with this requirement in place is now being consulted on, with a dedicated policy for circular economy  for PDA’s.

Beyond the GLA requirements, a number of London boroughs are now setting specific requirements, many of which apply to smaller developments. We are also seeing examples of projects being conditioned to meet targets or outcomes related to PDAs.  Below is a quick review of some of these.

• City of London - The City of London’s Planning for Sustainability SPD and Retrofit First Guidance is available on the CoL website sets particular requirements for audits of a detailed and granular nature. They also ask for a narrative on how the audit is/will inform the design of the new scheme.

• Westminster - Westminster City Council adopted its ‘Retrofit First’ policy at the beginning of 2026. Westminster now require detailed, granular audits, with recommendations maximising reuse. They also require a Deconstruction Circularity score, with range provided based on recommended actions and potential, and a Post-Deconstruction Audit should be submitted within three months of the completion of any demolition works.

• Camden - At the moment, there are no specific requirements above that required for GLA’s Circular Economy Statement, however the draft local plan for Camden has requirements for new developments to prioritise and enable the repurposing and re-use of existing buildings over demolition and minimising waste and whole life carbon. Other draft policies for Camden also prioritise the retention of existing buildings and require project teams to use resources to maximum efficiency.

• Hammersmith and Fulham - Local Plan Regulation 18 is currently open for public consultation. This requires all major development proposals (including extensions, refurbishments, and changes of use) to promote circular‑economy principles during design and construction. This must be in line with the GLA guidance, and the template spreadsheet. Major developments must submit a CES demonstrating, among other things, the reuse and recycling of existing materials.

• Enfield - All major development proposals will be required to meet the objectives through the provision of a CES. Proposals should prioritise reuse and retrofit of existing buildings wherever possible before considering the dismantling of old buildings and the design of new buildings.

• Newham – no specific requirements above GLA at the moment. Newham are promoting a new circular construction hub to focus on reuse of construction products – Tipping Point East.

• Tower Hamlets – no specific planning requirements above GLA at the moment but promoting use of the platforms such as ROMULUS.

• Barking & Dagenham – no specific requirements above GLA but where the development proposal involves demolition, developers are encouraged to maximise the recovery of materials for reuse or recycling. 

Outside London

Numerous planning authorities around the UK are stressing the need to apply circular economy principles such as pre-deconstruction audits, a retrofit-first approach, and reuse of materials.

Some examples - the draft Greater Cambridge Local Plan supports circular economy practices and sustainable resource use. All development proposals should, where practical and viable, take opportunities to reduce the development’s embodied carbon content through the careful choice, use and sourcing of materials. 

Bristol’s proposed policy on embodied carbon, materials and waste requires major developments to assess embodied carbon and promote material retention and reuse.

NPF4 is Scotland’s statutory spatial strategy and planning policy document. Development proposals should seek to reduce, reuse, or recycle materials in line with the waste hierarchy. Proposals are supported where they reuse existing buildings and infrastructure, and minimise demolition and encourage salvage materials for reuse.

Moreover, as many local authorities stipulate the requirement to meet BREEAM targets, PDAs will often be done as part of this – related to Wst01 criteria. Indeed may local authorities may not be aware of these audits being undertaken. 

Need help meeting any aspects of planning requirements for circularity and reuse? Contact us for an informal discussion using any of the methods below.

If you want to understand how planning requirements fit into the wider ecosystem, our ‘reuse pathway’ provides a useful reference ad concise summary of the things you need to consider when aiming to move from ‘reuse potential to reuse reality’.

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