Jessica Morgan-Smith, Partner at MPG, believes that despite strong policy ambition for a circular economy, misalignment and inefficiencies within planning and environmental permitting regimes are becoming the key bottlenecks to delivering the infrastructure needed to make it a reality.
The aspirations to deliver circular infrastructure and a wider circular economy cannot be designed separately from the regimes that intend to deliver and regulate them.
However, as it stands, the urgency to deliver a circular economy isn’t matched by a system designed to facilitate it quickly. The UK cannot deliver a truly circular economy without rapidly expanding recycling and resource-recovery infrastructure.
Navigating planning and environmental permitting is increasingly becoming the most significant barrier to building the facilities needed for the transition. Whether this is because of operator or regulator misunderstanding, a system that is not fit-for-purpose, or a combination of both, remains to be seen.
Removing the bottleneck
In November 2024, the UK Government’s Circular Economy Taskforce was established to support the development of England’s first circular economy strategy. It brings together leaders from industry, academia and society to co-design policies and practical mechanisms that keep materials in use for longer, improve resource efficiency and reduce waste.
The taskforce’s objectives include driving economic growth through investment in circular technologies and infrastructure, creating skilled green jobs, strengthening supply chains, lowering costs for consumers and accelerating progress towards net zero emissions. Overall, it plays a central role in guiding the transition from a traditional ‘take, make, dispose’ model to a more sustainable and resource-efficient economy.
The establishment of the Circular Economy Taskforce cemented the UK’s ambitions to really focus on progressing and delivering a circular future. Alongside this, the government has set ambitious goals for waste reduction, recycling and resource efficiency as part of its wider climate and sustainability agenda.
Achieving the government’s ambitions requires additional and appropriate infrastructure. Materials do not recycle themselves! They must be collected, sorted, processed and transformed into secondary raw materials through a network of recycling plants, transfer stations, treatment facilities and specialist recovery operations.
Yet the sector faces a growing contradiction. While the government increasingly encourages circular resource use, the systems responsible for approving new infrastructure, namely planning and environmental permitting, often struggle to keep pace with the scale and urgency of development required.
The result is that many viable projects are delayed, redesigned beyond recognition, or abandoned long before they ever process their first tonne of material.
At a strategic level, most Planning Authorities recognise the need for waste and recycling infrastructure. National and Regional policies frequently encourage facilities that support recycling, recovery, and resource efficiency. And whilst the circular economy is no longer just a theory, it is still not fully acknowledged from a national planning policy perspective.
The current National Planning Policy Framework (NPPF) does not mention the term ‘circular economy’. However, the December 2025 draft has the following policy proposed, which gives us some hope:
“PM3: Minerals and waste plans 1. Minerals and waste plans should set out specific proposals to facilitate a sufficient supply of minerals to meet society’s needs and enable the delivery of sustainable waste management and a circular economy.”
The biggest challenge, however, tends to emerge at the local planning stage. Waste and recycling facilities are rarely popular neighbours. Concerns about traffic, noise, dust, odour and visual impact are very common, even with the stringent modern requirements on new facilities and the lengthy planning consultation process.
Local authorities are therefore placed in a difficult position, balancing national infrastructure needs against local political and community pressure whilst ensuring no harm is caused to people or the environment in the process.
In many cases, planning applications are refused or delayed because of perceived environmental impacts rather than evidenced risks. The irony is that these same communities depend on recycling infrastructure to manage their waste sustainably.
Without local facilities, materials travel further, emissions increase and recycling performance in the local authority, and subsequently nationally, can ultimately decline.
Materials do not recycle themselves!
Alongside planning permission, most recycling and waste treatment facilities require an environmental permit to operate. Environmental permitting, regulated in England by the Environment Agency, ensures that waste sites operate in a way that protects human health and the environment by controlling emissions, managing risks and enforcing legal compliance. It sounds simple, but the regulatory framework has grown increasingly complex over time.
Operators must often produce extensive technical documentation to support permit applications in a bid to control potential risks from sites and reduce the potential impact. These can include management plans for noise, dust, odour, fire, for example.
For large or complex facilities, the preparation of these documents can take months and require significant specialist input, often resulting in infrastructure changes to meet the stringent requirements of regulations.
This level of scrutiny is important, but the process has, in our experience, often become disproportionate, particularly for lower-risk recycling activities when regulators, planners and operators interpret requirements differently.
In practice, the regulatory journey can involve several stages:
- Planning application
- Environmental permit application
- Technical queries and additional information requests
- Public consultation
- Permit and Planning determination
Each step adds time and uncertainty. One of the biggest challenges facing investors in recycling infrastructure is uncertainty. Developing a new facility requires major up-front investment in land, buildings and specialist processing equipment, often running into millions of pounds before any operations commence.
Investors must therefore be confident that a project can secure both planning permission and environmental permits within a predictable timeframe. Unfortunately, this is not always the case.
Projects may encounter:
- Extended regulatory determination periods due to a lack of appropriate experience with the regulators or complex operational requirements.
- Changing guidance or interpretation of rules.
- Requests for further assessments are made late in the process.
- Inconsistencies between regulators or regions.
Where regulatory clarity is lacking, developers may simply decide that projects are too risky to pursue, which has real consequences on the future of the circular economy. When recycling and recovery capacity fail to keep pace with waste generation, several outcomes are likely:
- Increased exports of waste materials.
- Greater reliance on landfill or energy recovery.
- Lost opportunities to recover valuable resources.
- Higher costs for local authorities and businesses.
In effect, the circular economy becomes constrained, not by technology or demand, but by regulatory bottlenecks. This is particularly relevant as the UK looks to implement policies, such as extended producer responsibility, deposit return schemes and consistent collections.
These reforms will increase the volume and diversity of recyclable materials entering the system. Without sufficient processing capacity, these materials may struggle to find a home.
The planning and permitting systems are not inherently broken, as is often suggested by frustrated consultants and developers! Both play vital roles in protecting communities and the environment. The issue lies in alignment.
Planning authorities, environmental regulators and policymakers often operate within separate frameworks with different priorities and timelines.
As a result, developers must independently navigate multiple regulatory processes that are technically linked but operationally disconnected, with, as we regularly find, often contradictory requirements.
Improving coordination between these systems could significantly accelerate infrastructure delivery.
Potential improvements could include:
- Joint pre-application discussions involving planners and environmental regulators can identify potential issues early, reducing the risk of redesign later.
- Lower-risk recycling operations should benefit from streamlined permitting processes where appropriate, which we understand the EA are currently exploring through the increased issue and use of standard rules permits.
- Clearer guidance on issues, such as waste classification, end-of-waste criteria and environmental controls, would help developers design compliant facilities from the outset.
- National and regional strategies should identify priority locations for recycling infrastructure, helping local authorities support appropriate development.
The transition to a circular economy is often discussed in terms of innovation, technology and behavioural change, but at its core, circularity depends on something more tangible, places where materials can be processed and transformed into new resources.
Recycling plants, transfer stations, sorting facilities and specialist treatment sites are the engines of the circular economy. Without them, the system simply cannot function.
The UK already has many of the expertise, technology and private investment opportunities needed to progress a circular economy. What it needs now is a planning and regulatory environment that enables it.
If the country is serious about reducing waste, increasing recycling and building a more resource-efficient economy, then accelerating the development and regulation of recycling infrastructure must become a national priority. Otherwise, the circular economy risks remaining an aspiration rather than a reality.
