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
Dalian to Portimão
Yellow Sea · Taiwan Strait · Malacca Strait · Indian Ocean · Bab-el-Mandeb · Suez Canal · Sicily Channel · Strait of Gibraltar
Lithium batteries for Portimão go from Liaoning through Dalian's Dayaowan terminals. On the way they face a Bab el-Mandeb and Suez passage into the Mediterranean, and they arrive at the port of Portimão.
Portugal registers battery producers with APA on SILiAmb. 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
Route profile
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.
SILiAmb registration with APA and an annual declaration, a licensed management entity or approved individual system, and the EU-wide battery and ICS2 duties.


Where this route gets difficult
They run from the Dalian terminal through the voyage to Portimão and the Portugal import file.
Dayaowan MSA reported in April 2024 that omissions and misdeclarations of lithium battery cargo were frequent because the rules are complex. Its answer was a dedicated desk and hotline, priority handling for EV batteries, and AI comparison of documents to cut down container openings: a comparison that flags any gap between the declaration and the paperwork behind it.
What Anxin does: We reconcile the UN number, classification, packing group, quantity and SDS across every document before filing, which is exactly what an automated comparison will test.
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.
Ships of 5,000 GT and above calling at EU ports, Portimão included, are in the EU Emissions Trading System: 50% of the emissions of a voyage from China are covered, and the share of emissions for which lines must surrender allowances rises from 70% (for 2025 emissions) to 100% from 2027. Carriers can pass that cost on as a surcharge.
What Anxin does: We ask for the emissions surcharge to be shown as its own line in the quote, with the basis the carrier uses, so that successive quotes can be compared like for like.
The importer in Portugal carries the check: CE marking on the battery and an EU declaration of conformity, translated into the language Portugal asks for, have both been required since 18 August 2024 for batteries entering the EU market.
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 Portugal importer. We check that the documents exist and match the goods; we do not assess conformity.
The Battery Regulation's due diligence obligations on cobalt, lithium, nickel and natural graphite were postponed by Regulation (EU) 2025/1561 and now apply from 18 August 2027, with Commission guidelines due by 26 July 2026. Buyers in Portugal are already asking suppliers for the supply-chain data they will need.
What Anxin does: We pass the Portugal buyer's due diligence questions to the manufacturer and keep their answers with the shipment file; the policy itself remains the producer's responsibility.
Article 11 of the Battery Regulation says that from 18 February 2027 portable batteries inside appliances must be readily removable and replaceable by the end-user using commercially available tools, without heat or solvents, except under limited derogations. Appliances sold in Portugal after that date need a design that complies.
What Anxin does: When appliances with built-in batteries are booked for Portugal we point the importer to the February 2027 date so the manufacturer answers the design question before shipment; we do not assess compliance.

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 |
|---|---|---|---|
| Declaration flagged by document comparison; container opened | Dayaowan | Cross-document reconciliation before filing | Anxin with the declarant |
| Emissions surcharge changes between quote and sailing | EU port call | Surcharge shown as a separate line | Carrier, checked by Anxin |
| Declaration of conformity missing or not in the required language | Importer in Portugal | Declaration and CE photo collected before loading | Manufacturer / importer |
Questions
ADR, which the EU applies to domestic journeys through Directive 2008/68/EC. UN 3480 is class 9, transport category 2, with tunnel restriction code (E).
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 → Portimão before any booking, and ask for missing battery documents first.
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