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 Burgas
East China Sea · Taiwan Strait · Malacca Strait · Indian Ocean · Bab-el-Mandeb · Suez Canal · Bosporus · Black Sea
This route runs from the Yangtze River Delta via Shanghai's Yangshan and Waigaoqiao terminals, then follows a Suez, Aegean and Bosporus passage into the Black Sea; at the far end is the port of Burgas.
Bulgaria applies the EU Battery Regulation, starting with registration in its own national producer register. 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.
Suez, the Aegean and the Turkish Straits, with a 24-hour DG sailing plan before the Bosporus and, since September 2026, almost the whole Black Sea on the war-risk list.


Where this route gets difficult
Loading port first, then the sea leg, then Burgas and the Bulgaria market.
At Shanghai the packing inspector must upload photos taken before, during and after stuffing through the MSA's remote system, with face recognition and phone location on, before the electronic packing certificate goes out by EDI. A container is not loaded if the photos are missing, uploaded late, taken outside the verified stuffing site, or do not match the EDI cargo data. Stuffing sites outside Shanghai must be registered with Shanghai MSA.
What Anxin does: We confirm that the stuffing site (including factory sites in Jiangsu or Zhejiang) is registered for Shanghai's remote system, and we check the photo upload against the EDI data before the packing certificate is sent.
The Joint War Committee extended its Black Sea listed area on 16 September 2026 to cover nearly the whole sea, excluding only Turkish, Georgian, Bulgarian and Romanian territorial waters. Ships going in must notify war-risk underwriters, who can charge extra premium per voyage, which carriers may pass on.
What Anxin does: We ask the carrier for any war-risk surcharge to Burgas in writing before booking and recheck it if the sailing moves.
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 Bulgaria for sale after that date need a design that meets the rule.
What Anxin does: When appliances with built-in batteries are booked for Bulgaria we point the importer to the February 2027 date so the manufacturer answers the design question before shipment; we do not assess compliance.
Sea cargo for the EU needs a complete Entry Summary Declaration under ICS2 Release 3, and for deep-sea containers it is due 24 hours before loading at the departure port. Carriers apply 'no manifest, no load', and a filing without a valid EORI number is rejected, so a data gap in Shanghai leaves the box on the quay.
What Anxin does: We collect the consignee's EORI number, an HS-level goods description and the house-bill parties at booking, and make sure the party filing the ENS has them before the Shanghai cut-off.
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 Bulgaria 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 Bulgaria 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 Shanghai.

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

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 Shanghai export filings, the carrier booking and the Bulgaria 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
| Risk | Where | Mitigation | Who acts |
|---|---|---|---|
| Container refused for loading: photos late, off-site or not matching EDI data | Yangshan / Waigaoqiao | Photo upload checked against EDI data before the certificate is sent | Packing inspector, checked by Anxin |
| Additional war-risk premium added after booking | Black Sea listed area | Surcharge confirmed in writing | Carrier, checked by Anxin |
| ENS not filed and the box is refused at loading | Loading port, Shanghai | EORI and house-bill data passed to the filer at booking | Filer (carrier / forwarder) |
| Road route planned through a category E tunnel | Road leg from Burgas | Tunnel code (E) passed to the haulier with the transport data | Haulier / forwarder |
Questions
No. Under the Battery Regulation producers register in each Member State where they first make batteries available, and the authority has up to 12 weeks to grant a complete application. A producer without an establishment in Bulgaria needs an authorised representative there.
Possibly. Since 16 September 2026 almost the whole Black Sea, outside Turkish, Georgian, Bulgarian and Romanian territorial waters, is a Joint War Committee listed area, and underwriters may charge additional premiums. We get the carrier's surcharge in writing.
It can, but Shanghai MSA checks the phone location of the packing photos against a verified stuffing site, and sites outside Shanghai must be registered with it. We confirm registration before the stuffing date; otherwise the container can be refused for loading.
References
Next step
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We check carrier acceptance for Shanghai → Burgas before any booking, and ask for missing battery documents first.
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