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 Pasaia
South China Sea · Malacca Strait · Indian Ocean · Bab-el-Mandeb · Suez Canal · Sicily Channel · Strait of Gibraltar · Bay of Biscay
From Xiamen to Pasaia, cargo moves out of Xiamen's Haicang and Songyu terminals on the Taiwan Strait, crosses a Suez corridor that Mediterranean services are using again more than any other Asia–Europe lane, and is discharged at the port of Pasaia.
The Spanish side checks RII-PYA registration alongside the EU battery rules. 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
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.
Spain's RII-PYA number on invoices, quarterly data that counts batteries inside equipment, EU importer duties and ADR for the road leg.


Where this route gets difficult
Listed from loading in Xiamen to import into Spain, each with what we do about it.
Through the single window, Xiamen Customs now issues the lithium battery packaging use-appraisal certificate after automatic pre-review matching: roughly 10 minutes in a case reported in August 2026, compared with about half a day for the former on-site inspection. Only products that pass pre-review as compliant and valid get the fast path; mismatches return to inspection.
What Anxin does: We check the product data, UN38.3 summary and packaging codes against the application before it is submitted, so the certificate comes through pre-review rather than falling back to an on-site check.
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 Pasaia 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 Pasaia uses and name it on the quote, together with any war-risk or emergency surcharge.
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.
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 Spain increasingly ask for that file before delivery.
What Anxin does: For ESS cabinets and racks bound for Spain we ask the manufacturer to confirm that the Annex V test documentation exists before booking and note the answer in the shipment file.
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 Spain after that date need a design that complies.
What Anxin does: When appliances with built-in batteries are booked for Spain 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
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.

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 Xiamen 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
| Risk | Where | Mitigation | Who acts |
|---|---|---|---|
| Application fails pre-review and falls back to on-site inspection | Xiamen Customs | Data checked against the application first | Anxin with the manufacturer |
| 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 |
| Storage system delivered without Annex V test file | Buyer in Spain | Test documentation confirmed before booking | Manufacturer |
Questions
24 hours before the container is loaded in China, not before it reaches Pasaia. 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.
For products that pass automatic pre-review, Xiamen Customs issues it through the single window; the case reported in August 2026 took about 10 minutes, against about half a day for the old on-site inspection. Products that do not pass pre-review still need inspection.
References
Next step
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We check carrier acceptance for Xiamen → Pasaia before any booking, and ask for missing battery documents first.
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