Aircraft Paint Remover
CN β US| HS Code | Tariff Rate | Origin | Destination | Doc |
|---|---|---|---|---|
| 340510 | 0.0% | CN | US | Official Doc |
| 283699 | 0.0% | CN | US | Official Doc |
AI Analysis
π§ͺ Aircraft Paint Remover (Chemical Stripping Agents)
π HS Code Reference & Customs Clearance Guide | 2026 Latest Tariff Analysis | Professional Entry Strategies
π I. Product Definition & Classification: Do You Understand "Paint Removers" Really?
Aircraft Paint Removers are specialized chemical formulations designed to soften, dissolve, or lift protective and decorative coatings from aircraft fuselages, wings, and components. Due to the aggressive nature of aviation coatings (epoxies, polyurethanes) and the sensitivity of aluminum substrates, these products are distinct from household paint strippers.
In international trade, classification depends on the primary function and chemical composition:
1. Prepared Paint Removers (Heading 3405)
If the product is a finished mixture designed specifically for removing paints, varnishes, or similar coatings, it falls under Chapter 34. This is the most common classification for commercial/industrial paint removers.
β οΈ Key Distinction:
- If the product is a ready-to-use chemical mixture for stripping paint β HS 3405
- If the product is a basic chemical raw material (e.g., Sodium Carbonate) used as a cleaning agent but not primarily sold as a "paint remover" β HS 2836 (Only if no more specific heading applies).
π¦ II. HS Code Classification Details (2026 Latest Tariff Authority Match)
Based on the provided data, the two potential classifications are:
| HS Code | Product Description | Applicable Scenario | Primary Function |
|---|---|---|---|
3405.10 |
Prepared Paint Removers | Aircraft paint removal, industrial coating stripping, general surface preparation | β Specific: Designed explicitly for removing coatings |
2836.99 |
Other Carbonates / Chemical Products NESOI | Sodium carbonate-based industrial cleaners where no specific "paint remover" heading fits | β General: Used as a general cleaning agent or chemical component |
π Crucial Note:
- HS 3405.10 is the primary and most accurate classification for "Aircraft Paint Remover" because it specifically covers "prepared paint removers."
- HS 2836.99 is a fallback classification. It applies only if the product is primarily a basic chemical (like sodium carbonate) used for general cleaning, and there is no more specific heading for its intended use. It is less preferred for a dedicated paint remover product unless the composition is purely a basic salt with no other stripping agents.
π° III. 2026 Latest Tariff Rate Details (Including Surcharges & Policy Add-ons)
β Applicable Country: United States (US)
β Country of Origin: China (CN)
β Effective Date: From November 10, 2025 (and subsequent imports)
π― 1. 3405.10 ββ Prepared Paint Removers
| Item | Content |
|---|---|
| Base Rate | 0% (ad valorem) |
| USITC Additional Duty | +25% (Under USITC Footnote 9903.88.01 / Section 301) |
| IEEPA Additional Duty | +10% (Against China/HK products, effective from Nov 10, 2025) |
| Total Tax Rate | 35% |
| Tax Calculation | CIF Value Γ 35% |
| De Minimis Eligibility | β Not Eligible (deny_de_minimis) |
| Legal Path | IEEPA:9903.01.25 β USITC:3405.10 β FOOTNOTE:9903.88.01 |
π Explanation:
- The 25% USITC duty is part of the Section 301 tariffs on Chinese goods.
- The 10% IEEPA duty is an additional layer for certain chemical products originating in China.
- Total 35% is a significant cost factor. Incorrect classification could lead to penalties or underpayment.
π― 2. 2836.99 ββ Other Carbonates / Chemical Products NESOI
| Item | Content |
|---|---|
| Base Rate | 0% |
| USITC Additional Duty | +25% (If applicable under general chemical footnotes) |
| IEEPA Additional Duty | +10% (If applicable to specific chemical subsets) |
| Total Tax Rate | 35% (Estimated, subject to specific chemical footnote) |
| Tax Calculation | CIF Value Γ 35% |
| De Minimis Eligibility | β Not Eligible (deny_de_minimis) |
| Legal Path | IEEPA:9901.25 β USITC:2836.99 |
π Note:
- If the product is classified under 2836.99, it may still attract the same additional duties if it falls under the same general chemical tariff lists.
- Risk: Misclassifying a dedicated paint remover (3405) as a general chemical (2836) can trigger audits, as customs may argue the productβs primary function is paint removal, not general chemical use.
π οΈ IV. Customs Clearance Practical Advice (Real-World Pitfall Guide)
β 1. Required Documentation Checklist (All Must Be Provided)
| Document | Mandatory | Description |
|---|---|---|
| β Product Specification Sheet | βοΈ | Must detail active ingredients, concentration, and intended use (e.g., "Aircraft Paint Removal"). |
| β Safety Data Sheet (SDS) | βοΈ | Critical for chemical imports. Must comply with OSHA/GHS standards. |
| β Product Photos (with Label) | βοΈ | Show packaging, hazard symbols, and clear product name. |
| β Third-Party Test Report | βοΈ | EPA, DOT, or other relevant chemical safety certifications. |
| β Commercial Invoice | βοΈ | Clearly state: "Paint Remover for Aircraft Coatings, HS Code 3405.10." |
| β Certificate of Origin (CO) | βοΈ | If applicable for duty mitigation (though limited for China-origin goods). |
| β Packing List | βοΈ | Detail net/gross weight, volume, and hazardous material classification (if any). |
β 2. Declaration Tips (Key Mantra)
π₯ βFunction Determines Code, Chemicals Need SDS, Hazardous? Declare!β
| Situation | Correct Declaration | Wrong Practice |
|---|---|---|
| Ready-to-use Paint Remover | 3405.10 |
Misdeclare as "General Cleaner" β Risk of penalty |
| Sodium Carbonate Powder | 2836.99 |
Declare as "Paint Remover" β Over-classification risk |
| Hazmat Chemicals | Must declare Hazardous Material | Omit hazmat info β Shipment hold/fine |
| Bulk vs. Retail | Bulk: 3405.10.0000; Retail: 3405.10.0000 | Donβt split declaration for a single product |
β 3. Special Case Handling
| Scenario | Handling Advice |
|---|---|
| OEM/Private Label Paint Remover | Provide client order + SDS to prove itβs a finished paint remover, not a raw chemical. |
| Mixed Chemicals | If it contains methylene chloride (now restricted) or NMP, ensure compliance with EPA/DOT regulations. |
| Used in Aviation Maintenance | Provide proof of use (e.g., FAA-approved maintenance procedure) to justify HS 3405 over general chemicals. |
| Chemical Components Only | If selling raw sodium carbonate, use HS 2836.99, but do not market it as a "paint remover" unless itβs formulated for that purpose. |
π V. Global Market Clearance Comparison (2026 Latest)
| Country/Region | Recommended HS Code | Tariff | Certification | Notes |
|---|---|---|---|---|
| πΊπΈ USA | 3405.10 |
35% (China) | EPA + DOT Hazmat | High compliance cost |
| π¨π³ China | 3405.10 |
5-10% | None | Lower barriers for domestic use |
| πͺπΊ EU | 3405.10 |
0% (if REACH compliant) | REACH + CLP | Strict chemical registration |
| π¬π§ UK | 3405.10 |
0% | UK REACH | Post-Brexit chemical rules apply |
| π―π΅ Japan | 3405.10 |
0% | JIS Safety | No major surcharges |
π Conclusion:
- USA imposes 35% effective tariff on China-origin paint removers due to trade tensions.
- EU/UK/Japan have 0% base tariffs, but strict chemical compliance (REACH, CLP) is required.
- Misclassification in the US can lead to double duties or penalties.
π VI. Common Mistakes & Pitfall Guide (Lessons Learned)
β Mistake 1: Declaring a dedicated paint remover as "General Industrial Cleaner" (HS 3808)
π Consequence: Customs may reclassify to 3405.10 β Back taxes + fines!
β Mistake 2: Ignoring Hazmat status
π Consequence: Shipment detained by DOT/PHMSA β Demurrage charges + delays
β Mistake 3: Using "Chemical Product" as the description
π Consequence: Vague description leads to random inspection β Customs delay
β Mistake 4: Not providing SDS
π Consequence: Refused entry by customs or carrier
β Correct Approach:
"Aircraft Paint Remover, Liquid, Based on Glycol Ethers, For Industrial Use, Model XYZ, SDS Provided, EPA Compliant"
π― VII. Conclusion: Precise Classification Saves Money!
π― Remember:
πΉ βPaint Remover = 3405.10, Chemical Raw = 2836.99β
πΉ βHazmat? Declare It! SDS? Provide It!β
πΉ β35% Tariff in USA, 0% in EU, but Compliance is Key!β
π Pro Tip:
- If your product is originating from Vietnam, Thailand, or Malaysia, you may avoid the 35% US surcharge (check specific trade agreements).
- Apply for Advance Ruling with US Customs (CBP) to confirm HS Code before shipping.
- Ensure SDS and EPA/DOT compliance to avoid hazmat rejections.
π£ Immediate Action:
π Contact a licensed customs broker + Provide SDS + Apply for HS Code Advance Ruling
π Ensure smooth clearance, avoid penalties, and maximize profit margins!
β¨ Professional Customs Clearance Starts with Accurate Classification!
πΌ Every Dollar Saved is a Dollar Earned!
Customer Reviews
About HS Code Classification
The Harmonized System (HS) is an internationally standardized nomenclature developed by the World Customs Organization (WCO) to classify traded products. Over 200 countries use the HS system as the basis for customs tariffs, trade statistics, and import/export regulations.
Each HS code follows a hierarchical structure:
- Chapter (2 digits) β Broad category of goods (e.g., Chapter 84: Machinery and Mechanical Appliances)
- Heading (4 digits) β More specific grouping within the chapter
- Subheading (6 digits) β Internationally standardized breakdown, used by all WCO member countries
- National subdivisions (8-10 digits) β Country-specific extensions for further classification, such as US HTSUS 10-digit codes
Correct HS code classification is essential for smooth customs clearance, accurate duty payment, and compliance with trade regulations. Misclassification can lead to customs delays, overpayment of duties, or penalties.
When importing from CN to US, the applicable tariff rates may include:
- Most-Favored-Nation (MFN) rate β The standard duty rate applied to WTO members
- General rate β Applied to countries without trade agreements
- Trade remedy duties β Additional tariffs such as Section 301 (anti-dumping), Section 232 (national security), or countervailing duties
The information provided on this page is for reference purposes only. For official classification, please consult with your local customs authority or a licensed customs broker.