Collectively, the world has mastered the art of the linear business model: design, produce, use, waste. It's a model that has served us well for decades - mass production distributed through mass logistics. However the need for change is more important than ever.

A circular economy promises a more sustainable future where resources are conserved and waste is minimized. Laying within this circular paradigm shift, we find the challenging concept of reverse logistics.

In this conversation:

Sebastian Bujnoch, Senior Business Development Manager, Circunomics

Nils Steinbrecher, Senior Director Sales, Key Account Management and Marketing, Cylib

Philipp Brunotte, CEO, LiBCycle

Reverse Logistics

This webinar discusses reverse logistics as a critical pillar of a sustainable, circular economy, focusing on batteries. It highlights current challenges in transport, storage, regulatory compliance, and market dynamics, and stresses the need for better digitalization, harmonized waste codes, and clearer policies to enable efficient regional and cross-border battery recycling.

• Reverse logistics is essential to reduce carbon footprint across battery lifecycles (mining, production, recycling)
• Main challenges: batteries classified as waste, complex cross-border compliance, and storage permits within Europe (Germany focus)
• Logistics inefficiencies and regulatory bottlenecks drive up cost and emissions; consolidation and regionalization are needed

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HOST: Good afternoon, everyone. Thank you for joining us on your lunch break — bon appétit! We hope the next 45 minutes is both informative and inspiring. Each of us is part of a global movement to create a more sustainable and circular economy here on Earth.

My name is Inga, and I'm joined today by three experts in their respective fields. They've come together to discuss an important topic when it comes to achieving effective circularity — and that is reverse logistics. We invite you to throw any questions into the chat at any time, and we'll do our best to answer them over the course of the next 40 to 45 minutes.

First, we have Philipp Brunotte — with a Master of Science in Mechanical Engineering and Management from the Technical University in Munich. Philipp has held several positions in small to medium-sized enterprises, including strategy consulting at Accenture and Bain & Company, as well as in private equity at Kalista Private Equity. In 2021, Philipp founded and currently serves as CEO of LiBCycle, a logistics company specializing in lithium-ion batteries, headquartered in Munich.

Philipp, we're so glad you can join us today. In a couple of sentences, can you tell us why reverse logistics is important to you and to the work you do at LibCycle?

PHILIPP (CEO, LibCycle): Thank you for the introduction. Reverse logistics is an important part of the circular economy because we are focused on becoming carbon neutral — in producing, mining, and recycling batteries. Between all of those steps, there are logistics steps, and a huge portion of the total cost and CO₂ emissions currently come from logistics. We have to optimize reverse logistics to become truly sustainable across the whole circular economy. That's why we focus on this topic and why we are actively approaching those challenges.

HOST: Next, we have Nils Steinbrecher, Managing Director at TESS Sustainable Battery Solutions. Nils holds a Master of Science in Business Administration with a focus in Electrical Engineering. He finished his master's thesis at Hong Kong University on the topic of sustainable transport for Hong Kong. Together with his team at TESS, they are on a mission to make TESS the global leader in lithium-ion battery recycling and to support their clients in closing the loop for a circular economy.

Nils, we're glad you're here. Can you tell us in just a couple of sentences why reverse logistics stands out to you as an important topic in the world right now?

NILS (Managing Director, TESS Sustainable Battery Solutions): Thanks for the introduction, Inga. Philipp already mentioned it from the logistics expert side, so I'll speak from our clients' perspective. Our clients are OEMs and cell manufacturers — everyone who has waste material. They are not logistics companies, so they need their batteries transported to us. That's definitely one reason why this is important — getting the battery to the recycler. The other point is that recycling will happen mainly on a regional basis. We can't have recycling facilities in every European country, so batteries need to be transported from one country to another to our locations. That's why this is one of the key topics for us.

HOST: And finally, we have our very own Sebastian Bujnoch from Circunomics — our Senior Business Developer. Sebastian's previous positions were concentrated in product development, product design, and product engineering. For 14 years, he worked in China and Hong Kong in manufacturing before joining a German recycling company in Hong Kong, where he began focusing on circular economy solutions. Sebastian returned to Europe in 2022.

Sebastian, can you tell us why you consider this topic to be a critical one at this point in history?

SEBASTIAN (Senior Business Developer, Circunomics): Thanks, Inga. Similar to what Philipp and Nils already mentioned — everyone is talking about the circular economy. We've been doing a linear economy — producing stuff, selling stuff — for basically 100 years or longer. But the circular economy, where you take back products, repair them, remanufacture them, repurpose them, and then recycle them — that's a relatively new thing. And as Philipp mentioned, whatever you do in that process, whether it's manufacturing or remanufacturing, you always have a logistics piece in between. You always have to transport things from A to B.

For the linear economy, we mastered that over the last 100 years. We are experts at producing things, putting them in a warehouse, and sending them out to customers. But when it comes to returning products — that's always been an exception for companies. They often don't have the processes or the IT support. Many large ERP systems don't really support the process of returning a product.

A story a friend of mine told me proves this well. He ordered a spare battery for his e-bike through one of the big online shopping companies. It was the wrong one, and when he tried to send it back, they told him: "Just keep it. It's too much hassle for us to take it back — it's a special transport. We'll just send you the correct one free of charge. If you don't need it, give it away or dispose of it at a recycling point."

With that in mind, Philipp — when it comes to battery recycling and transport, where are we right now? Is it getting better, or is there still a lot of work and hassle in transporting these batteries?

PHILIPP: Good question. The current situation is improving because volumes are rising in the market and we as companies develop along with it. But there are still a number of challenges.

The main issue is the waste status. Batteries are classified as waste when transported for recycling, and so we have significant compliance issues regarding transport, storage, and how logistics is generally structured — where a larger company subcontracts several smaller companies to do the work.

This creates problems, particularly for international transport. When crossing borders, you lose all flexibility regarding subcontracting, changing routes, and consolidating shipments. For example, if we have a customer in Hungary producing battery cells and wanting to ship to the Netherlands, we need a waste notification — an export allowance. We have to ask Hungary if it's okay to export the waste, ask the Czech Republic if it's okay to transit through, ask Germany if we can drive through, and then ask the Netherlands if it's okay to import the waste.

This is quite a lengthy procedure because every national authority has to approve it. It can take six to nine months per notification. And once approved, you have a dedicated transport route — one starting point, one destination. If the road is closed, you have to ask the authority which alternative road you can use, and that can take days or even weeks. Even a 100-meter detour requires a formal change in the route.

This makes logistics extremely difficult. You also have to navigate different national waste laws in each country, different tracking systems, and different approvals. It's a completely different setup from standard logistics or even standard dangerous goods logistics.

SEBASTIAN: That's a great point, Philipp. Batteries, from a logistics standpoint, are classified as dangerous goods in the best case — for example, when new batteries are being shipped from production to a car manufacturer. But in the worst case, they're classified as waste, and that's a huge challenge for reverse logistics. Once something is classified as waste, you're in a completely different set of laws. In Germany, for example, that means you can't store it in a normal facility — you have to be a certified recycler or waste company. And as Philipp mentioned, crossing borders within the European Union is a total hassle. Six to nine months is quite typical.

Looking outside Europe — do you have any idea how this works in the US or Asia? Is it more favorable there?

PHILIPP: Since we only operate in Europe, I have only basic knowledge of other regions. In the US, different states have different waste laws. In some states, the waste status doesn't apply, so batteries are transported as normal goods. In Asia, I don't have direct experience, but I'd assume it's similar. Nils may be able to speak to that, since TESS operates there.

NILS: To add to what's been discussed — in the US, it might actually be going in reverse because I've heard there have been incidents and they're catching up on regulation. Generally, being one country makes it easier, though even within Germany, the state of Hesse has different laws than Bavaria, and waste is treated differently. Within the US, it's similar.

The Basel Convention, under which waste notifications run, is a global convention that most countries have signed. So even if you're shipping batteries from Australia to Singapore or Australia to New Zealand, those waste regulations apply. That said, some regions make it easier in practice — transporting a battery from Thailand to Singapore requires a notification, but that process is much faster and more digitalized than in Europe.

To give a practical example: OEM dealers are small shops. If an electric car comes in for scrapping, the dealer may be able to remove the battery, but then they have that one battery — and for just that single battery, they already need a license to store it. Most small shops are not ready to hold a waste license. That's where it starts to get very complicated.

Is it getting better? There are many associations — Global Battery Alliance, European Battery Alliance, Recharge, and others — that have written letters advocating for simpler transport rules in Europe. The battery regulation came out, but it wasn't really coordinated with the ADR — the transport regulations. With the growing number of battery chemistries and volumes coming to market, it will be very difficult to be efficient as a company transporting batteries within Europe. The administration is very complicated and it's not getting easier.

SEBASTIAN: That brings up an interesting question. We've had NMC batteries, and now LFP batteries which are considered safer. There's talk of solid-state batteries, sodium batteries — some cheaper, some safer. Is there any discussion in Europe or in your industry about revisiting the logistics standards for batteries, given that some of these products are becoming safer? Or is it still the same approach — batteries are dangerous, put them in a thick aluminum box?

NILS: That's a very good point, Sebastian. There are two things to consider. First, there's the battery as a loaded battery — the risk of catching fire and the energy stored inside. Chemistry makes a big difference there. But then there are also the metals themselves, which are hazardous regardless of chemistry. Whatever metal is in the battery is treated as a potential waste that could contaminate water or ground.

Sodium-ion batteries, for example, are already out as samples in the market. But the legislation hasn't caught up — all current legislation is written for lithium-ion batteries, and no one knows how to ship sodium-ion batteries because they're simply not lithium-ion. There's still a lot to be done across Europe to address different chemistries.

The good news is that most new developments aim to remove hazardous metals to reduce cost, and batteries are becoming safer — less risk of fire, short circuit, or explosion. The regulatory framework needs to catch up with that reality, and transport should become easier going forward.

PHILIPP: To add a couple of points — sodium batteries are currently assigned the same UN number as lithium batteries, so from a transport perspective, they're treated exactly the same.

On the broader waste issue: historically, people in Europe disposed of waste irresponsibly — dumping it in forests or in the ocean. Batteries are classified as hazardous waste primarily due to water contamination risks and hazardous materials inside. The biggest challenge comes from the waste classification, not just the dangerous goods classification.

Even for new battery storage, the legislation is unclear. In Germany, we have several warehouses and face different water protection class requirements depending on the region — no clear standard. Fire protection is not regulated by the government or local authorities in any consistent way. It's mostly determined by your insurance company, which then creates its own guidelines. Finding an insurance company willing to cover your battery storage is often the main challenge. This varies significantly between recyclers, and it's highly individual — especially depending on whether the batteries are in good condition or critically defective.

SEBASTIAN: Thanks for bringing that up. I recall looking for storage for batteries classified as red — dangerous waste — and being quoted €30 per square meter per month here in southern Germany. That's comparable to renting an apartment in downtown Munich — for an old battery in a warehouse.

What you've described points to a total lack of adequate storage supply in Europe for batteries, especially waste batteries. And there doesn't seem to be a clear national or European-wide law defining exactly what you need to store a red battery. It always comes back to local authorities and the fire brigade. How difficult is it right now to secure storage facilities or recycling batches here in Europe?

PHILIPP: When we're talking about larger storage facilities and we're not working together as partners — recyclers and logistics companies — the risk becomes incalculable. For example, you need a Bundes-Immissionsschutzgesetz (BImSchG) certification — a German federal emissions law certification — where not only authorities are involved, but also local residents. If a few people object, you have to go to court. The certification process, even once the building is ready, takes at least 9 months — in reality, closer to a year or a year and a half — for a medium-sized 10,000 square meter facility. During that time, you're not operational, which represents roughly one to one and a half million euros in financing costs, plus construction and land costs. The risk is extremely high because at the end of the certification process, after 12 months, the local authority can still say no. You can be left with a storage facility and no certification. This needs to change. From an investor perspective, you need a clearer business case.

NILS: To add an example — we looked at different sites in Europe. In some countries, we were offered 10,000 to 20,000 tons per year of recycling capacity, but only 60 tons of storage capacity. That 60-ton limit came from the local fire brigade, who required containers placed 10 meters apart and connected to the fire brigade — meaning you need enormous space. The companies that win in this environment are those with old permits that broadly cover their activities. The moment you apply for a new permit, you face all these challenges.

What we also observed last year was that many OEMs had stored their batteries while waiting for recyclers to process them — but storage allowances in Germany are only valid for 12 months. After that, you need a different permit — a depository permit. So you have to clear the batteries within 12 months or obtain a separate permit. Storage is a huge challenge, and we're still talking about relatively small volumes. In five to ten years, volumes will be much larger, and we'll need to solve this.

The challenge right now is that the requirements for storing 100 tons of batteries are almost the same as for storing 1,000 tons. To make the logistics work, we need to create consolidation storage points — aggregate smaller quantities, load them onto large trucks, ship over longer distances, and deliver to the destination. That requires major investment in a market where future volumes are unpredictable. Customers say they have 10,000 tons of battery scrap per year, and it ends up being 2,000 tons. If you build for 10,000 and only get 2,000, it's a significant financial challenge.

SEBASTIAN: So to summarize — we have the challenge of physically moving batteries across borders, especially when classified as waste, and we have the challenge of storing waste batteries in Europe, particularly in Germany. And what I'm reading from this is that if you're a logistics company with capital to spare, it might be worth acquiring old recyclers or waste companies with existing permits. Am I correct?

PHILIPP: Yes, we've searched for those companies. But we're not alone, and there are only a few companies that truly have the right certificates. Knowledge about which certificates are actually required is very limited in the market. Some companies say they can handle it, but when you do a legal check, the waste code isn't included for batteries. Then the facility is disqualified, and they have to apply for a new BImSchG certification with the correct waste code. And generally, facilities that obtained their Bundes-Immissionsschutzgesetz (BImSchG) 20 or 30 years ago would likely not receive it today under current standards.

SEBASTIAN: There was an interesting question in the chat: are politicians and lawmakers aware of these challenges? We talk about this a lot within our battery and circular economy community — but how aware are the lawmakers in Berlin, Brussels, and Strasbourg? Do they know we need to standardize this? Are they aware but moving slowly, or do we really need to push this into their faces to drive change?

NILS: I mentioned earlier the battery associations — or, less charitably, lobbyists — that put a voice forward to local governments and especially to Brussels. If you go to the Recharge website, some of these challenges are documented, and they are communicating them to the right people. But I don't think it's seen as urgent yet. There are also industry players who see the complexity as a useful market barrier — if you can navigate the complicated regulatory environment and offer services to clients despite those challenges, it's actually good for those companies that can do it. That's partly why we're still here, along with Circunomics. Others who start from scratch may give up.

Nevertheless, over the next five to ten years, things need to change. We need to continue raising our voices in associations, at conferences, and in the right rooms.

PHILIPP: From my perspective, the regulatory framework is generally good — it's an achievement we should value. But the bureaucracy and the long waiting times need to change. If we could submit a notification online and receive approval within two days, no one would complain. The laws are fundamentally sound — we've seen what happens with waste when there's an opportunity to cut costs. But we need to make the bureaucracy faster and leaner. The government needs to do its own work to help us bring better solutions to market faster, with less planning risk.

SEBASTIAN: Essentially, it comes down to digitalization — which is a separate topic for another webinar.

There's a question in the chat: can you explain how large-scale batteries intended for recycling ended up being sold on the black market — reportedly a significant issue two to three years ago?

NILS: To use the e-waste example: if 10 containers of e-waste are going to Hamburg, only a few are actually checked. Containers still end up in African countries where they shouldn't be — even with all the existing regulations. I agree with Philipp that we need those regulations, but enforcement is still failing, even with e-waste, which has been regulated for a long time. Things go where they shouldn't. Some containers are caught, but the others aren't, and the operation still turns a profit. In the battery world, it's the same — or it will be. We continuously hear about waste going to China, India, or other places without proper notification. As long as people are caught and close shop, they often just open up again elsewhere. This needs enforcement and administration to stop it — but it continues to happen. And obviously it's harmful to those of us doing legitimate business, because it takes business away from us.

SEBASTIAN: In that discussion — do you think the Battery Passport will help? The idea is full traceability, so you could see that a battery was supposed to go to recycling but never arrived at the recycler. Could that help stop the practice?

NILS: From what I know about the Battery Passport, that function isn't really there — not to track whether a battery is still in a legal chain or has disappeared from it. If there's no enforcement mechanism to ensure traceability is maintained, batteries can still disappear. The people doing illegal work won't update the Battery Passport to say "I have it in China now." They'll do everything to delete any traces. So I don't know if that helps. So far, the Battery Passport seems more focused on tracing raw materials, mining origins, and greenhouse gas emissions.

SEBASTIAN: Would you agree that for batteries with positive material value for recycling — like NMC batteries from large EVs — once Europe has sufficient recycling capacity, there's actually a financial incentive to keep them in Europe? That reduces the incentive to ship and dump them?

NILS: It's a global business. If someone has a business case — legal or illegal — and the illegal option is more profitable, they may choose it. When logistics prices spiked — like when the Ukraine war started — the European market became much more attractive. But when logistics prices normalize, there are more business cases to ship waste around the world to wherever it's cheaper to process. I think if Europe's recycling and reverse logistics industry is competitive, that's the answer — and that's why we need administration to make it easier for us. If we're competitive, it doesn't make sense to ship abroad. But with all the administrative burden and lack of digitalization we've discussed, it is difficult to be competitive.

SEBASTIAN: One last question before we go to the audience Q&A. Philipp, you're on the transport side — shipping new batteries and handling reverse logistics. Nils, you're on the recycling end. We've heard that reverse logistics volumes haven't yet hit critical mass simply because EVs haven't been in service long enough. We're seeing small batteries from e-scooters slowly coming back. When do you think the curve really turns upward — where quantities make logistics meaningfully cheaper? Are we two, three, or five years away? And Nils, when do you think European recyclers will have enough feedstock to run their facilities at scale?

PHILIPP: From a logistics perspective, it's hard to define what "cheap" means exactly. We become more cost-efficient year by year. If we look at the total volume in Germany across all car manufacturers, we could set up a well-functioning system — possibly within three to five years. But that would require all manufacturers and all recyclers working together, which isn't realistic. No single company will be the sole source for an entire market. Markets like Spain, Italy, Portugal, and Greece are further behind. From around 2029–2030, I'd say we'll have a fairly well-developed market in Germany. But you have to do the work now to be operational by then.

NILS: From a recycling perspective, there's currently no regulation that stops EVs from following the same end-of-life path as ICE vehicles. Statistics show that most Teslas at the moment go to Ukraine, which is outside the EU — so they're gone and not available to European recyclers. A significant percentage of EVs are also going to Africa. So the volume that European companies can actually access is uncertain.

Recyclers also take production scrap — from cell manufacturers and from OEMs that buy cells in Asia and produce modules and packs in Europe. We look at when end-of-life volumes will surpass production scrap volumes. We used to say 2030, but batteries are lasting much longer because most people don't use their cars as intensively as taxis or commercial vehicles. I'd now say around 2035 is when end-of-life volumes really pick up.

Even production scrap today is being shipped to Asia and North America. We just had a tender for 10,000 tons that dropped to 3,000 tons because the company put two sites on hold. Volume is continuously changing. If you invest in a recycling facility in Europe — which costs close to double-digit millions at the pre-treatment stage, and potentially over 100 million for a full hydrometallurgical process — you're making that investment in an environment where chemistries are changing, regulations are changing, and volumes are unpredictable. You have to be very flexible. And customers are working in the opposite direction — they don't want to produce waste, so they're extending battery life as long as possible.

SEBASTIAN: Coming back to the waste discussion — we have one more question, Inga.

HOST: Yes, and we just have a couple of minutes left, so please keep answers brief. The question is: there are discussions in some countries about listing batteries under EWC 16 06 05 as green-listed waste. Do you see a possibility of that happening in Europe as well?

So EWC 16 06 05 is the European Waste Catalogue code describing batteries as "other batteries and accumulators" — classified as non-hazardous. That would make them easier to ship. Do you see that happening in Europe, Philipp? Or will batteries always be treated as a complicated, high-risk transport?

PHILIPP: I see a strong trend in the opposite direction. In the past, the 16 06 05 code was often used, but now most of our customers are using the 16 01 21 asterisk code — the hazardous battery code. From my perspective, that's the right approach because it gives us the strategic ability to keep batteries within Europe. The materials inside are essentially a mine — we should keep that resource here and recycle it locally.

NILS: I can confirm that the JRC — the Joint Research Centre of the European Commission — is actively working on harmonizing waste codes across Europe. That harmonization is necessary because local authorities can currently assign different waste codes, making it easier for some companies than others. For us at TESS, the next challenge is also the Black Mass — the product of mechanical treatment — which in some European countries is still classified as hazardous waste and in others is not. Harmonization is definitely required to make it simpler and more efficient to operate as a European company.

HOST: Time has flown and we are out of it! As we wrap up, I want to thank all of our panelists for taking time out of your busy schedules to be here. Thank you also to everyone who joined us today. If you have further questions, we encourage you to reach out to any of us — all three websites are listed in the live stream notes on YouTube. At Circunomics, keep your eyes open for the next live discussion coming toward the end of the summer. We wish you a lovely remainder of your day and look forward to engaging with you all again soon.

ALL: Thank you very much, everyone. Thanks for joining. Bye!

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