Shanghai (Yangshan / Waigaoqiao)
Yangshan and Waigaoqiao exports under Shanghai MSA's photo-verified packing system, where a mismatch between photos and EDI data keeps a DG box off the ship.
Europe · sea freight from Shanghai
Shanghai to Brunsbuttel
East China Sea · Taiwan Strait · Malacca Strait · Indian Ocean · Bab-el-Mandeb · Suez Canal · Strait of Gibraltar · English Channel
Lithium batteries for Brunsbuttel go out of Shanghai, where MSA spot-checks battery containers during and after filing. On the way they face a voyage that may run through Suez as drawn or round the Cape, depending on the service, and they arrive at the port of Brunsbuttel.
The German side adds producer registration with stiftung ear and the EU Battery Regulation's labelling calendar. 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
Yangshan and Waigaoqiao exports under Shanghai MSA's photo-verified packing system, where a mismatch between photos and EDI data keeps a DG box off the ship.
The map shows the Suez corridor, but in September 2026 most Asia–North Europe capacity still sails round the Cape of Good Hope.


Where this route gets difficult
In the order the cargo meets them: at the loading port, at sea, at Brunsbuttel and at customs in Germany.
Shanghai MSA's Notice No. 4 of 2024 accepts either an inspector-signed packing certificate or a packing declaration from the stuffing company, but places the burden on the shipper: the batteries must meet the UN tests and be protected against damage, short circuit and accidental activation, and MSA runs spot checks during and after the process, with proof to be produced on request.
What Anxin does: We keep a file per container (UN38.3 summary, SDS, packing photos, terminal protection details) so that proof can be produced the same day if Shanghai MSA asks for it after sailing.
Ships of 5,000 GT and above calling at EU ports, Brunsbuttel 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.
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 Germany for sale after that date need a design that meets the rule.
What Anxin does: When appliances with built-in batteries are booked for Germany we point the importer to the February 2027 date so the manufacturer answers the design question before shipment; we do not assess compliance.
Stationary battery energy storage systems placed on the EU market since 18 August 2024 must be safe in normal operation, with technical documentation showing tests against the Annex V parameters, including thermal shock, short-circuit protection, over-discharge and thermal propagation. ESS buyers in Germany increasingly ask for that file before delivery.
What Anxin does: For ESS cabinets and racks bound for Germany we ask the manufacturer to confirm that the Annex V test documentation exists before booking and note the answer in the shipment file.
Regulation (EU) 2025/1561 pushed the Battery Regulation's due diligence duties for cobalt, lithium, nickel and natural graphite back to 18 August 2027 and gave the Commission until 26 July 2026 for its guidelines. Buyers in Germany are already collecting the supply-chain information they will need.
What Anxin does: We pass the Germany buyer's due diligence questions to the manufacturer and keep their answers with the shipment file; the policy itself remains the producer's responsibility.

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

We line up UN numbers, model names and package counts across the Shanghai filings, the booking with the carrier and the documents for Germany before the booking is confirmed, so that a mismatch is fixed at origin rather than discovered at Brunsbuttel.
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 |
|---|---|---|---|
| Post-event spot check finds missing proof | Shanghai MSA | Evidence file kept per container | Shipper with Anxin |
| Emissions surcharge changes between quote and sailing | EU port call | Surcharge shown as a separate line with its basis | Carrier, checked by Anxin |
| Storage system delivered without Annex V test file | Buyer in Germany | Test documentation confirmed before booking | Manufacturer |
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).
Ships of 5,000 GT and above calling at EU ports are in the EU Emissions Trading System, covering 50% of the emissions of a voyage from outside the EU. Lines must surrender allowances for 70% of 2025 emissions and 100% from 2027, and may pass the cost on as a surcharge.
Shanghai MSA's Notice No. 4 of 2024 accepts either an inspector-signed packing certificate or a packing declaration issued by the stuffing company. Either way, the shipper remains responsible and must provide proof if MSA spot-checks.
References
Next step
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We check carrier acceptance for Shanghai → Brunsbuttel before any booking, and ask for missing battery documents first.
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