Dalian (Dayaowan)
North-east China's battery gateway at Dayaowan, with a small but growing lithium export flow, a local MSA that has named misdeclaration as its main problem, and both winter ice and spring fog.
Europe · sea freight from Dalian
Shipping from Dalian to Varna
Dalian to Varna
Yellow Sea · Taiwan Strait · Malacca Strait · Indian Ocean · Bab-el-Mandeb · Suez Canal · Bosporus · Black Sea
- DalianChina origin
- Yellow Sea
- Taiwan Strait
- Malacca Strait
- Indian Ocean
- Bab-el-Mandeb
- Suez Canal
- Bosporus
- Black Sea
- VarnaBulgaria
From Dalian to Varna, cargo moves from Liaoning through Dalian's Dayaowan terminals, crosses a Suez, Aegean and Bosporus passage into the Black Sea, and is discharged at the port of Varna.
The Bulgaria side follows the EU battery and customs pre-filing rules. This page sets out 6 points specific to this route, how Anxin handles each one and which documents to prepare.
What we need to start
- Dalian Dayaowan export
- Winter ice & spring fog
- National producer registration
- EU declaration of conformity
- Consignee EORI
Route profile
What sets Dalian → Varna apart
Bulgaria
The EU Battery Regulation's national registration, CE marking and label duties, and the ICS2 entry summary before loading.
Where this route gets difficult
6 points to plan for on the Dalian → Varna route
In the order the cargo meets them: at the loading port, at sea, at Varna and at customs in Bulgaria.
- Origin port
Ice in the northern Yellow Sea from January
Sea ice forms every winter in the Bohai Sea and northern Yellow Sea. In winter 2021/22 China's marine forecast centre expected floating ice about 15 nautical miles out in the northern Yellow Sea, where Dalian's Dayaowan lies, and about 60 in Liaodong Bay, peaking from mid-January to mid-February.
What Anxin does: For January–February sailings from Dalian we allow extra time between stuffing and the DG cut-off and reconfirm the vessel schedule the week before loading.
- Origin port
Spring fog season from April to July
The China Meteorological Administration describes sea fog as a major marine hazard in the Yellow and Bohai Seas, with the season mainly from April to July, seriously affecting sea transport. Fog holds keep vessels at anchor, and a late vessel can push the box past its documented sailing.
What Anxin does: In the fog season we avoid tight stuffing-to-cut-off gaps and keep the filing data ready to amend if the vessel changes.
- Sea corridor
Black Sea war-risk area widened in September 2026
The Joint War Committee extended its Black Sea listed area on 16 September 2026 to cover nearly the whole sea, excluding only Turkish, Georgian, Bulgarian and Romanian territorial waters. Ships going in must notify war-risk underwriters, who can charge extra premium per voyage, which carriers may pass on.
What Anxin does: We ask the carrier for any war-risk surcharge to Varna in writing before booking and recheck it if the sailing moves.
- Import country
Safety documentation for stationary storage systems
Since 18 August 2024 a stationary battery energy storage system placed on the EU market must be safe in normal operation, and its technical documentation must show testing against the Annex V safety parameters, from thermal shock and short-circuit protection to over-discharge and thermal propagation. Buyers of ESS cabinets in Bulgaria increasingly ask for that file before delivery.
What Anxin does: For ESS cabinets and racks bound for Bulgaria we ask the manufacturer to confirm that the Annex V test documentation exists before booking and note the answer in the shipment file.
- Import country
CE marking and a declaration of conformity in the right language
Since 18 August 2024 a battery sold in the EU needs the CE marking and an EU declaration of conformity from its manufacturer. The declaration has to be available in the language Bulgaria requires, and the importer is the one who must check both before the goods are released for sale.
What Anxin does: We ask the manufacturer in China for the declaration of conformity and a photo of the CE marking on the battery or its packaging before loading, and pass them to the Bulgaria importer. We check that the documents exist and match the goods; we do not assess conformity.
- Import country
The ICS2 entry summary is due before loading in Dalian
For Varna, EU security pre-filing happens at the other end of the voyage: the ICS2 entry summary must reach the system 24 hours before the container is loaded in Dalian. No filing means no loading, and a missing EORI number is enough to reject it.
What Anxin does: We collect the consignee's EORI number, an HS-level goods description and the house-bill parties at booking, and make sure the party filing the ENS has them before the Dalian cut-off.
Documents & compliance
Checklist for Dalian → Varna
Test reports, safety data sheets and import certificates come from the shipper, factory and importer, not from Anxin; our part is to review them before booking.
In Dalian, before the box is loaded
- Importer name, trade name and postal address printed on battery or packaging
- Annex V safety documentation confirmed for stationary storage systems
- Substance declaration covering mercury, cadmium and lead limits
- Safety data sheet and dangerous goods safe-carriage declaration for the MSA cargo report
- Customs packaging use-appraisal result for the dangerous goods packaging (with the maker's performance appraisal)
For the shipping line
- Final DG manifest data ready before the vessel reaches the Turkish Straits
- Lithium battery mark (SP188 cargo) or class 9 labels and placards
- Condition statement: new, used, damaged/defective (SP376) or for recycling (SP377)
At the Bulgaria end
- Label and QR-code status against the August 2026 and February 2027 dates
- Instructions and safety information in the language Bulgaria requires
Before you book
Send the file once, complete
Most delays on this route start with a document that exists but does not match: a UN number, a model name or a package count that differs between the Dalian filings, the carrier booking and the Bulgaria import file. We check the three against each other before the booking is confirmed.
Carriers we book with
Our booking panel; availability on this lane and acceptance of the declared UN numbers are confirmed for each booking. It does not mean that a listed carrier runs a direct service on this route. Carrier choice depends on the trade lane, cargo classification and each carrier's dangerous-goods acceptance at booking. The final carrier is confirmed on the booking.
Risk & mitigation
Risk table for Dalian → Varna
| Risk | Where | Mitigation | Who acts |
|---|---|---|---|
| Ice delays berthing in mid-winter | Northern Yellow Sea, Jan–Feb | Extra time before cut-off; schedule reconfirmed | Carrier, monitored by Anxin |
| Fog hold delays the vessel; filings need amending | Yellow Sea, Apr–Jul | Amendment-ready filing data | Anxin with the declarant |
| Additional war-risk premium added after booking | Black Sea listed area | Surcharge confirmed in writing | Carrier, checked by Anxin |
| Declaration of conformity missing or not in the required language | Importer in Bulgaria | Declaration and CE photo collected before loading | Manufacturer / importer |
| ENS not filed and the box is refused at loading | Loading port, Dalian | EORI and house-bill data passed to the filer at booking | Filer (carrier / forwarder) |
Questions
Dalian → Varna: questions we are asked
The CE marking on the battery and the manufacturer's EU declaration of conformity, which must be available in the language Bulgaria requires. Both have applied since 18 August 2024.
Possibly. Since 16 September 2026 almost the whole Black Sea, outside Turkish, Georgian, Bulgarian and Romanian territorial waters, is a Joint War Committee listed area, and underwriters may charge additional premiums. We get the carrier's surcharge in writing.
Sea ice forms every winter in the northern Yellow Sea; in 2021/22 it was forecast to reach about 15 nautical miles out there, peaking mid-January to mid-February. We plan extra time for those weeks.
References
Official sources for this page
- Regulation (EU) 2023/1542 on batteries and waste batteries (ELI) (EUR-Lex / Publications Office of the EU)
- ICS2 Release 3: Prepare your business for sending goods to or via the EU by sea and inland waterways (European Commission, DG TAXUD (leaflet KP0423828ENN))
- Regulation (EU) 2023/1542 concerning batteries and waste batteries (Official Journal PDF) (EUR-Lex / Publications Office of the EU)
- Turkish Straits Maritime Traffic Regulation (English translation) (Republic of Türkiye (translation published by VDA))
- Sea ice arrives: what are the impacts? (Bohai and northern Yellow Sea, winter 2021/22) (China Meteorological Administration (from China Natural Resources News))
- Sea fog in the Yellow and Bohai Seas (fog season mainly April–July) (China Meteorological Administration (from Guangming Daily))
- Export dangerous goods packaging inspection: service guide (Chinese) (General Administration of Customs of China (Lanzhou Customs service guide))
Next step
From enquiry to import
- 1EnquiryCargo, origin, destination
- 2Documents checkUN 38.3, SDS, packing
- 3BookingAfter carrier acceptance
- 4HandoverAt Dalian
- 5ImportClearance at Varna
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After you send it
We check carrier acceptance for Dalian → Varna before any booking, and ask for missing battery documents first.
All destinations from Dalian · Bulgaria ports
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