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 Guangzhou
Shipping from Guangzhou to Pasaia
Guangzhou to Pasaia
South China Sea · Malacca Strait · Indian Ocean · Bab-el-Mandeb · Suez Canal · Sicily Channel · Strait of Gibraltar · Bay of Biscay
- GuangzhouChina origin
- South China Sea
- Malacca Strait
- Indian Ocean
- Bab-el-Mandeb
- Suez Canal
- Sicily Channel
- Strait of Gibraltar
- Bay of Biscay
- PasaiaSpain
This route runs out of Nansha, at the mouth of the Pearl River, then follows a Suez corridor that Mediterranean services are using again more than any other Asia–Europe lane; at the far end is the port of Pasaia.
The Spanish side checks RII-PYA registration alongside the EU battery rules. The 6 points below are particular to this lane; each comes with what we do and the paperwork it touches.
What we need to start
- Typhoon season Jun–Oct
- Nansha export
- Consignee EORI
- EU declaration of conformity
- RII-PYA number
Route profile
The Guangzhou → Pasaia route in brief
Spain
RII-PYA registration with its number on every invoice, quarterly market data including batteries inside equipment, and the EU-wide CE and label duties.
Where this route gets difficult
6 points to plan for on the Guangzhou → Pasaia route
Loading port first, then the sea leg, then Pasaia and the Spain market.
- Origin port
Packaging certificate data now shared in Dongguan
Dongguan Customs and Dongguan MSA began sharing dangerous-goods packaging certificate data in September 2026, which they called a first in China, and agreed joint action on concealed and false declarations; Huangpu Customs runs a joint 'lithium batteries going overseas' service against misdeclaration as well. A mismatch between packaging certificate and MSA filing is visible to both.
What Anxin does: We check that the UN number, packaging code and quantities on the packaging certificate are exactly those on the MSA cargo report before either is submitted.
- Origin port
A recommended 25% charge for ESS from Nansha
Nansha MSA told a July 2024 meeting on energy-storage carriage that ESS batteries should travel at roughly 25% state of charge, with accidental activation prevented. It is advice, not a binding rule, yet it is the number the local authority has put on the record.
What Anxin does: For ESS cargo leaving Nansha we ask the manufacturer to state the shipping state of charge and the anti-activation measures in writing, and put both in the documents the carrier sees.
- Sea corridor
The round-Africa alternative
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.
- 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 Pasaia.
- Import country
The truck leg out of Pasaia runs under ADR
Once the container leaves the terminal by road, ADR applies: Directive 2008/68/EC makes EU countries use it for domestic dangerous goods journeys as well as international ones. UN 3480 is class 9, transport category 2, with tunnel restriction code (E), so the haulier in Spain has to plan around category E tunnels, and damaged or defective batteries fall under special provision 376 and packing instructions P908 or P911 instead of P903.
What Anxin does: We give the Spain haulier the same UN number, class and package details that appear on the sea dangerous goods declaration, so the ADR transport document matches the container paperwork from Guangzhou.
- Import country
Instructions and safety information in the language of Spain
Importers must make sure batteries come with instructions and safety information in a language end-users in Spain easily understand, as that Member State decides. Printed inserts and carton text are far easier to change before the goods are packed in China.
What Anxin does: We ask the importer which language Spain requires and check carton and insert photos against it before loading.
Documents & compliance
Checklist for Guangzhou → Pasaia
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.
In Guangzhou, before the box is loaded
- Packaging certificate and MSA cargo report cross-checked line by line (UN number, packaging code, quantity)
- For ESS: written shipping state of charge and anti-activation measures from the manufacturer
- 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)
Carrier and voyage
- Routing (Red Sea or Cape) and any war-risk surcharge stated on the booking
- Consignee EORI and HS-level description to the ENS filer before loading
- UN 38.3 test summary for every cell and battery type
At the Spain end
- RII-PYA registration number of the Spanish producer
- Haulier in Spain briefed with UN number, class 9 and tunnel code (E) for the road leg
- Label and QR-code status against the August 2026 and February 2027 dates
Before you book
One consistent file
A document that is present but inconsistent holds a booking as surely as a missing one: the UN number, model name or carton count reads differently in the Guangzhou export filings, the carrier booking and the Spain import papers. We compare all three before confirming space.
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
Risks on this route and who deals with them
| Risk | Where | Mitigation | Who acts |
|---|---|---|---|
| Mismatch between packaging certificate and MSA filing flagged by shared data | Dongguan / Nansha | Line-by-line check before submission | 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 |
| Importer not registered in the RII-PYA | Importer in Spain | Registration number confirmed before booking | Importer / SCRAP |
| Road route planned through a category E tunnel | Road leg from Pasaia | Tunnel code (E) passed to the haulier with the transport data | Haulier / forwarder |
Questions
Guangzhou → Pasaia: questions we are asked
Yes. Batteries incorporated in electrical and electronic equipment, removable or not, are registered and declared like loose batteries.
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.
Nansha MSA has recommended around 25% for ESS batteries and measures against accidental activation. Treat it as the local authority's recommendation; the carrier's own acceptance conditions also apply.
References
Regulations and port sources cited
- Registro de Pilas y Acumuladores: preguntas frecuentes (Ministerio de Industria y Turismo)
- Registro de Pilas y Acumuladores (RII-PYA) (Ministerio de Industria y Turismo)
- Inland transport of dangerous goods (summary of Directive 2008/68/EC) (EUR-Lex)
- JMIC Update 099 to Advisory Note (Joint Maritime Information Center (via UKMTO))
- Nansha MSA meeting on the safe carriage of energy-storage batteries (Guangzhou Nansha District Government)
- 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 Guangzhou
- 5ImportClearance at Pasaia
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After you send it
We check carrier acceptance for Guangzhou → Pasaia before any booking, and ask for missing battery documents first.
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