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 Funchal
Yellow Sea · Taiwan Strait · Malacca Strait · Indian Ocean · Bab-el-Mandeb · Suez Canal · Sicily Channel · Strait of Gibraltar
Lithium batteries for Funchal 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 Funchal.
On the Portuguese side, APA's SILiAmb register and the EU importer checks both apply. 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
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
Listed from loading in Dalian to import into Portugal, each with what we do about it.
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.
Services that avoid the Red Sea, 43% of the Mediterranean total, go round the Cape of Good Hope and re-enter through Gibraltar. SAMSA estimates that about 200 of the 576 containers lost at sea in 2024, 35% of the total, went overboard near the Cape.
What Anxin does: On Cape sailings we apply the CINS blocking and bracing checks strictly on stuffing photos before sealing.
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 asks the importer to put its own name, registered trade name or trade mark and postal address, with a single contact point, on the battery. Only when the battery's size or nature makes that impossible may the details move to the packaging or an accompanying document, so a Portugal importer's details need to reach the factory before printing.
What Anxin does: We pass the Portugal importer's name and address block to the manufacturer before the goods are packed in China and check carton or battery photos for it before loading.
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
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.

We line up UN numbers, model names and package counts across the Dalian filings, the booking with the carrier and the documents for Portugal before the booking is confirmed, so that a mismatch is fixed at origin rather than discovered at Funchal.
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 |
|---|---|---|---|
| Fog hold delays the vessel; filings need amending | Yellow Sea, Apr–Jul | Amendment-ready filing data | Anxin with the declarant |
| Heavy weather off South Africa on a Cape sailing | Cape of Good Hope | CINS stuffing checks | Packing site, 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 |
| Importer details missing from battery and packaging | Importer in Portugal | Address block sent to the factory before packing | Manufacturer / importer |
Questions
The importer's: name, registered trade name or trade mark and postal address with a contact point, on the battery or, if it is too small, on the packaging or accompanying document.
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 → Funchal before any booking, and ask for missing battery documents first.
All destinations from Dalian · Portugal ports

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