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 Dalian
Dalian to Horta
Yellow Sea · Taiwan Strait · Malacca Strait · Indian Ocean · Bab-el-Mandeb · Suez Canal · Sicily Channel · Strait of Gibraltar
Lithium batteries for Horta go from Liaoning through Dalian's Dayaowan terminals. On the way they face a Suez corridor that Mediterranean services are using again more than any other Asia–Europe lane, and they arrive at the port of Horta.
The Portuguese side adds SILiAmb registration to the EU battery rules. The 5 points below are particular to this lane; each comes with what we do and the paperwork it touches.
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
In the order the cargo meets them: at the loading port, at sea, at Horta and at customs in Portugal.
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.
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 Horta 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 Horta uses and name it on the quote, together with any war-risk or emergency surcharge.
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 Portugal increasingly ask for that file before delivery.
What Anxin does: For ESS cabinets and racks bound for Portugal we ask the manufacturer to confirm that the Annex V test documentation exists before booking and note the answer in the shipment file.
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.
For portable batteries, Annex I sets maximum levels of 0.0005 % mercury, 0.002 % cadmium and 0.01 % lead by weight, the lead limit applying since 18 August 2024. The importer in Portugal may be asked by market surveillance to demonstrate compliance.
What Anxin does: We ask the manufacturer for its substance declaration or test report reference and file it with the shipping documents for the Portugal importer; we do not test batteries.

Documents & compliance
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.

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 Horta.
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 |
| 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 |
| Storage system delivered without Annex V test file | Buyer in Portugal | Test documentation confirmed before booking | Manufacturer |
Questions
It registers with APA on the SILiAmb platform, files an annual declaration by 31 March, and joins a licensed management entity or runs an APA-authorised individual system.
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 → Horta before any booking, and ask for missing battery documents first.
All destinations from Dalian · Portugal ports

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