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 Vilagarcía de Arousa
Dalian to Vilagarcía de Arousa
Yellow Sea · Taiwan Strait · Malacca Strait · Indian Ocean · Bab-el-Mandeb · Suez Canal · Sicily Channel · Strait of Gibraltar
- DalianChina origin
- Yellow Sea
- Taiwan Strait
- Malacca Strait
- Indian Ocean
- Bab-el-Mandeb
- Suez Canal
- Sicily Channel
- Strait of Gibraltar
- Vilagarcía de ArousaSpain
This route runs from Liaoning through Dalian's Dayaowan terminals, then follows a Bab el-Mandeb and Suez passage into the Mediterranean; at the far end is the port of Vilagarcía de Arousa.
The Spanish side checks RII-PYA registration alongside the EU battery rules. 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
- Winter ice & spring fog
- Dalian Dayaowan export
- RII-PYA number
- Spanish-language safety information
- Consignee EORI
Route profile
How Dalian → Vilagarcía de Arousa differs from other lanes
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.
Where this route gets difficult
5 points to plan for on the Dalian → Vilagarcía de Arousa route
Listed from loading in Dalian to import into Spain, each with what we do about it.
- Origin port
Sea fog off Dalian, April to July
Sea fog is one of the main marine hazards of the Yellow and Bohai Seas according to the China Meteorological Administration, concentrated between April and July and with a serious effect on shipping. A vessel held at anchor by fog can arrive late enough to push a box beyond the sailing its documents name.
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
EU emissions trading now covers the whole inbound voyage share
Ships of 5,000 GT and above calling at EU ports, Vilagarcía de Arousa 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.
- Import country
Spain's battery register and the number on invoices
Spain's industry ministry runs the RII-PYA battery register, and every battery importer must be registered and declared as a producer there, either through a collective scheme filing for its members or directly online with an electronic signature or Cl@ve. The register number issued has to appear on the producer's invoices.
What Anxin does: We ask the Spanish importer for its RII-PYA number and whether its SCRAP filed the registration, then carry the number on the documents we prepare for Vilagarcía de Arousa.
- Import country
The ICS2 entry summary is due before loading in Dalian
For Vilagarcía de Arousa, 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.
- Import country
Built-in portable batteries must be user-replaceable from February 2027
From 18 February 2027, Article 11 requires portable batteries built into appliances to be readily removable and replaceable by the end-user with commercially available tools, without heat or solvents, apart from limited derogations. Appliances shipped to Spain for sale after that date need a design that meets the rule.
What Anxin does: When appliances with built-in batteries are booked for Spain 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
Documents to line up for Dalian → Vilagarcía de Arousa
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.
At the Dalian end
- 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)
- Container packing certificate signed by a certified packing inspector after supervised stuffing
- Transport-condition classification report where applicable
Carrier and voyage
- Routing (Red Sea or Cape) and any war-risk surcharge stated on the booking
- Condition statement: new, used, damaged/defective (SP376) or for recycling (SP377)
- Consignee EORI and HS-level description to the ENS filer before loading
For import into Spain
- RII-PYA registration number of the Spanish producer
- Label and QR-code status against the August 2026 and February 2027 dates
- Instructions and safety information in the language Spain 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 Spain 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
What could go wrong from Dalian to Vilagarcía de Arousa, and who acts
| Risk | Where | Mitigation | Who acts |
|---|---|---|---|
| Fog hold delays the vessel; filings need amending | Yellow Sea, Apr–Jul | Amendment-ready filing data | Anxin with the declarant |
| Emissions surcharge changes between quote and sailing | EU port call | Surcharge shown as a separate line | Carrier, checked by Anxin |
| Importer not registered in the RII-PYA | Importer in Spain | Registration number confirmed before booking | Importer / SCRAP |
| 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 → Vilagarcía de Arousa: questions we are asked
The importer, as producer, in the RII-PYA register. A collective scheme may register it on its behalf; otherwise registration is online with an electronic signature or Cl@ve. The registration number must appear on invoices.
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.
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
Where these points come from
- Registro de Pilas y Acumuladores: preguntas frecuentes (Ministerio de Industria y Turismo)
- Registro de Pilas y Acumuladores (RII-PYA) (Ministerio de Industria y Turismo)
- 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)
- JMIC Update 099 to Advisory Note (Joint Maritime Information Center (via UKMTO))
- Reducing emissions from the shipping sector (European Commission (DG Climate Action))
- 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 Vilagarcía de Arousa
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After you send it
We check carrier acceptance for Dalian → Vilagarcía de Arousa before any booking, and ask for missing battery documents first.
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