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 Xiamen
Xiamen to Bilbao
South China Sea · Malacca Strait · Indian Ocean · Bab-el-Mandeb · Suez Canal · Sicily Channel · Strait of Gibraltar · Bay of Biscay
This route runs through Xiamen, the port for more than 90% of Fujian's lithium battery exports, 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 Bilbao.
The Spanish side checks RII-PYA registration alongside the EU battery rules. 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
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.
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
Loading port first, then the sea leg, then Bilbao and the Spain market.
Xiamen's energy-storage transport guide 2.0 (August 2026) notes that some ESS containers are carried on multipurpose ships and requires a pre-voyage meeting with the terminal and lashing parties. It also lists the terminals with class 9 qualification: Xiamen Hyundai terminal, Yuanhai Tongda, and Haixiang berths 7–8.
What Anxin does: For ESS units we confirm early whether the carrier offers container-ship or multipurpose carriage, which qualified terminal is used, and who attends the pre-voyage meeting.
Because Bilbao is an EU port, container ships of 5,000 GT or more calling there fall under the EU Emissions Trading System, which covers half the emissions of the voyage from China. Lines surrendered allowances for 70% of those emissions in 2025 and must cover 100% from 2027, a cost that can reach shippers 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.
The Battery Regulation's due diligence obligations on cobalt, lithium, nickel and natural graphite were postponed by Regulation (EU) 2025/1561 and now apply from 18 August 2027, with Commission guidelines due by 26 July 2026. Buyers in Spain are already asking suppliers for the supply-chain data they will need.
What Anxin does: We pass the Spain buyer's due diligence questions to the manufacturer and keep their answers with the shipment file; the policy itself remains the producer's responsibility.
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 Bilbao.
Loose cells and batteries built into electrical equipment, removable or not, both fall under the Spanish register. Declarations are quarterly, errors can be corrected until 25 January of the following year, and changes to registration data must be updated within a month.
What Anxin does: When batteries travel inside devices we list battery quantity and chemistry separately on the packing list, so the importer can report them without reopening cartons.

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 Xiamen filings, the booking with the carrier and the documents for Spain before the booking is confirmed, so that a mismatch is fixed at origin rather than discovered at Bilbao.
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 |
|---|---|---|---|
| ESS unit arrives at a terminal without class 9 qualification | Xiamen port | Qualified terminal confirmed at booking | Anxin with the carrier |
| Emissions surcharge changes between quote and sailing | EU port call | Surcharge shown as a separate line | Carrier, checked by Anxin |
| Importer not registered in the RII-PYA | Importer in Spain | Registration number confirmed before booking | Importer / SCRAP |
| Embedded batteries left out of the quarterly declaration | Importer in Spain | Battery data on the packing list | Importer |
Questions
24 hours before the container is loaded in China, not before it reaches Bilbao. Without it carriers do not load the box, and a filing without an EORI number is rejected.
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.
Yes. Xiamen MSA reported 104 ESS containers of 36 tonnes each loaded for Houston in June 2026. Xiamen's ESS guide 2.0 requires a pre-voyage meeting and use of a class 9 qualified terminal.
References
Next step
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We check carrier acceptance for Xiamen → Bilbao before any booking, and ask for missing battery documents first.
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