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 Ningbo
Ningbo to Cascais
East China Sea · Taiwan Strait · Malacca Strait · Indian Ocean · Bab-el-Mandeb · Suez Canal · Sicily Channel · Strait of Gibraltar
Lithium batteries for Cascais go through Ningbo-Zhoushan, where Zhejiang MSA's guide sets a 60% weight-balance test for battery containers. On the way they face a Bab el-Mandeb and Suez passage into the Mediterranean, and they arrive at the port of Cascais.
Portugal registers battery producers with APA on SILiAmb. This page sets out 5 points specific to this route, how Anxin handles each one and which documents to prepare.
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.
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
Listed from loading in Ningbo to import into Portugal, each with what we do about it.
Zhejiang MSA's January 2026 battery guide lets the shipper skip the UN38.3 test summary at the MSA cargo-report stage (it goes to the carrier instead) and skip resubmitting the safety data sheet for the same maker, owner and model. The carrier, however, must still check the documents and refuse batteries that do not meet the ship-carriage standard JT/T 1543-2025.
What Anxin does: We send the UN38.3 summary and SDS to the carrier with the booking request, and keep a per-model file so repeat shipments use the SDS already on record.
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 Cascais 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 Cascais uses and name it on the quote, together with any war-risk or emergency surcharge.
Importers placing batteries on the market in Portugal register with the Portuguese Environment Agency (APA) on SILiAmb and submit an annual declaration by 31 March that includes batteries built into other products. They meet their responsibility through a licensed management entity such as Electrão, or through an individual system authorised by APA.
What Anxin does: We ask the Portuguese importer for its APA registration and management entity before booking, and list battery weights separately so its declaration is easy.
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 Portugal 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 Portugal importer. We check that the documents exist and match the goods; we do not assess conformity.
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 Portugal for sale after that date need a design that meets the rule.
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
These documents come from the shipper, the manufacturer and the importer. Anxin checks them against each other; it does not issue test reports, safety data sheets or import certificates.

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 Ningbo filings, the carrier booking and the Portugal 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 | Where | Mitigation | Who acts |
|---|---|---|---|
| Carrier rejects booking over UN38.3 / JT/T 1543-2025 documents | Ningbo booking stage | UN38.3 summary and SDS sent with the booking request | Shipper with Anxin |
| 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 |
| Importer not registered on SILiAmb | Importer in Portugal | Registration confirmed before booking | Importer |
| 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.
Yes. Zhejiang MSA's 2026 guide removed it from the MSA cargo-report stage, but it still has to go to the carrier, which must refuse batteries that do not meet JT/T 1543-2025.
References
Next step
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We check carrier acceptance for Ningbo → Cascais before any booking, and ask for missing battery documents first.
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