Asia – Mediterranean via Suez
Mediterranean services are the ones most likely to use Suez again (57% in September 2026), which puts the cargo back through Bab el-Mandeb, rated a SUBSTANTIAL threat.
Europe · sea freight from Dalian
Dalian to Peniche
Yellow Sea · Taiwan Strait · Malacca Strait · Indian Ocean · Bab-el-Mandeb · Suez Canal · Sicily Channel · Strait of Gibraltar
This route runs from Liaoning through Dalian's Dayaowan terminals, then follows a Suez corridor that Mediterranean services are using again more than any other Asia–Europe lane; at the far end is the port of Peniche.
Portugal registers battery producers with APA on SILiAmb. Below are 5 route-specific points to plan for, what we do about each, and the documents to have ready before booking.
What we need to start
Route profile
Mediterranean services are the ones most likely to use Suez again (57% in September 2026), which puts the cargo back through Bab el-Mandeb, rated a SUBSTANTIAL threat.
An annual SILiAmb declaration, a licensed management entity or individual system, and EU importer duties from the declaration of conformity to the importer's address on the battery.


Where this route gets difficult
Listed from loading in Dalian to import into Portugal, each with what we do about it.
Liaoning's first lithium battery export under JT/T 1543 sailed from Dayaowan on 4 May 2025, and Dalian MSA counted 885 TEU of lithium batteries exported in the first four months of that year. Carriers should not accept batteries that do not meet JT/T 1543, and with a thinner flow there are fewer sailings to fall back on if a booking is refused.
What Anxin does: We check JT/T 1543 conformity evidence with the manufacturer before booking and confirm the carrier's acceptance of the UN numbers in writing.
Asia–Mediterranean services used the Red Sea 57% of the time in September 2026 according to Sea-Intelligence, compared with 27% for North Europe, so a box for Peniche most probably goes via Suez and through Bab el-Mandeb. The JMIC rated that strait SUBSTANTIAL on 24 September 2026; the Houthis call their blockade selective and now hold Perim Island in the channel.
What Anxin does: We ask the carrier which routing its service to Peniche uses and name it on the quote, together with any war-risk or emergency surcharge.
For portable batteries, Annex I sets maximum levels of 0.0005 % mercury, 0.002 % cadmium and 0.01 % lead by weight, the lead limit applying since 18 August 2024. The importer in Portugal may be asked by market surveillance to demonstrate compliance.
What Anxin does: We ask the manufacturer for its substance declaration or test report reference and file it with the shipping documents for the Portugal importer; we do not test batteries.
For Peniche, 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.
Once the container leaves the terminal by road, ADR applies: Directive 2008/68/EC makes EU countries use it for domestic dangerous goods journeys as well as international ones. UN 3480 is class 9, transport category 2, with tunnel restriction code (E), so the haulier in Portugal has to plan around category E tunnels, and damaged or defective batteries fall under special provision 376 and packing instructions P908 or P911 instead of P903.
What Anxin does: We give the Portugal haulier the same UN number, class and package details that appear on the sea dangerous goods declaration, so the ADR transport document matches the container paperwork from Dalian.

Documents & compliance
Anxin reviews documents supplied by the shipper, manufacturer and importer; it does not issue test reports, safety data sheets or import certificates.

A document that is present but inconsistent holds a booking as surely as a missing one: the UN number, model name or carton count reads differently in the Dalian export filings, the carrier booking and the Portugal import papers. We compare all three before confirming space.
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 | Where | Mitigation | Who acts |
|---|---|---|---|
| Security incident near Bab el-Mandeb changes the routing or adds surcharges | Southern Red Sea | Routing and surcharges stated in writing before booking | Carrier, checked by Anxin |
| 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) |
| Road route planned through a category E tunnel | Road leg from Peniche | Tunnel code (E) passed to the haulier with the transport data | Haulier / forwarder |
Questions
The CE marking on the battery and the manufacturer's EU declaration of conformity, which must be available in the language Portugal requires. Both have applied since 18 August 2024.
Often: in September 2026, 57% of Asia–Mediterranean services used the Red Sea routing. Bab el-Mandeb was rated a SUBSTANTIAL threat by the JMIC on 24 September 2026, so we confirm each service's routing before booking.
Dayaowan MSA reported in 2024 that omissions and misdeclarations of lithium battery cargo were frequent because the rules are complex, and it uses AI document comparison. Consistent data across the declaration, SDS and packing documents is the main defence.
References
Next step
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We check carrier acceptance for Dalian → Peniche before any booking, and ask for missing battery documents first.
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