Paint and Varnish
CN β US| HS Code | Tariff Rate | Origin | Destination | Doc |
|---|---|---|---|---|
| 3209900000 | 40.9% | CN | US | Official Doc |
| 3209100000 | 40.1% | CN | US | Official Doc |
| 3208100000 | 38.7% | CN | US | Official Doc |
| 3208200000 | 38.6% | CN | US | Official Doc |
| 3210000000 | 36.8% | CN | US | Official Doc |
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AI Analysis
π¨ Paints and Varnishes: HS Code Classification & Tax Strategy Guide (2026)
π HS Code Reference & Customs Clearance Guide | 2026 Latest Tariff Analysis | Professional Clearance Strategy
π One, Product Definition & Classification: Do You Truly Understand "Paint and Varnish"?
Paints, varnishes, enamels, lacquers, and distempers are complex chemical mixtures used for finishing, protection, and decoration. In international trade, they are not a single category. The HS Code is determined by three critical factors: 1. Base Polymer Type: Polyester, Acrylic, Vinyl, or Others? 2. Solvent Medium: Aqueous (Water-based) or Non-aqueous (Solvent-based)? 3. Specific Application: General purpose, leather finishing, or specific industrial use?
β οΈ Key Distinction Point:
- Water-based (Aqueous) Acrylic/Vinyl: Often 0% Duty (Strategic Advantage!)
- Water-based "Other": High Tax (Base + Additional)
- Solvent-based (Non-aqueous): Generally 0% Duty (Lower Risk)
π¦ Two, HS Code Classification Details (2026 Latest Tariff Authority Comparison)
| HS Code | Product Description | Applicable Scenario | Solvent Base | Key Polymer |
|---|---|---|---|---|
3210.00.00.00 |
Other paints and varnishes; prepared water pigments for finishing leather | General purpose, leather finishing, mixed polymers | Any | Mixed/Other |
3208.10.00.00 |
Paints/varnishes based on polyesters, in non-aqueous medium | Solvent-based polyester coatings, automotive refinish | Non-aqueous | Polyester |
3208.20.00.00 |
Paints/varnishes based on acrylic or vinyl polymers, in non-aqueous medium | Solvent-based acrylic/vinyl lacquers, industrial coatings | Non-aqueous | Acrylic/Vinyl |
3209.90.00.00 |
Paints/varnishes based on synthetic polymers, in aqueous medium: Other | Water-based paints NOT acrylic/vinyl (e.g., epoxy, polyurethane dispersions) | Aqueous | Other/Synthetic |
3209.10.00.00 |
Paints/varnishes based on acrylic or vinyl polymers, in aqueous medium | Latex paints, water-based acrylics, eco-friendly wall paints | Aqueous | Acrylic/Vinyl |
π Critical Reminder:
- 3209.10.00.00 (Water-based Acrylic/Vinyl) is the Gold Standard for low duty (0%). If your product is water-based, verify if it is strictly Acrylic or Vinyl. If it is "Other" (e.g., Epoxy in water), it falls into3209.90.00.00with high taxes. - 3208 Series (Solvent-based): Generally safer for tax avoidance (0%), but check for environmental compliance (VOC limits) in the destination country.
π° Three, 2026 Latest Tariff Rate Breakdown (Including Additional Taxes)
β Applicable Market: United States (US)
β Origin: China (CN)
β Effective Date: 2025/2026 Current Rates (Subject to Trade Policy Changes)
π― 1. 3208.10.00.00 / 3208.20.00.00 ββ Solvent-based Paints (Polyester/Acrylic/Vinyl)
| Item | Detail |
|---|---|
| Base Tariff | 0.0% |
| Additional Tariff (Section 301) | 0.0% |
| Total Tax Rate | 0.0% |
| Tax Calculation | CIF Value Γ 0% = $0 |
| De Minimis Exemption | β Eligible (If value < $800, often duty-free entirely regardless of HS) |
| Legal Basis | HTSUS Chapter 32 Note 4 (Non-aqueous solutions) |
π Explanation:
- Solvent-based paints based on synthetic polymers (polyesters, acrylics, vinyls) are classified under Heading 3208.
- Currently, these specific sub-headings carry 0% total tax under the listed data.
- Advantage: Zero duty burden. However, ensure VOC (Volatile Organic Compound) compliance with US EPA standards.
π― 2. 3209.10.00.00 ββ Water-based Acrylic/Vinyl Paints
| Item | Detail |
|---|---|
| Base Tariff | 0.0% |
| Additional Tariff (Section 301) | 0.0% |
| Total Tax Rate | 0.0% |
| Tax Calculation | CIF Value Γ 0% = $0 |
| De Minimis Exemption | β Eligible |
| Legal Basis | HTSUS 3209.10 |
π Explanation:
- Water-based paints based on Acrylic or Vinyl polymers are highly favored.
- Despite being water-based, they enjoy 0% total tax.
- Strategy: If your paint is water-based, ensure the primary binder is Acrylic or Vinyl. Do NOT classify as "Other" if it is Acrylic/Vinyl, to avoid the high tax of3209.90.00.00.
π― 3. 3209.90.00.00 ββ Water-based "Other" Paints (High Risk!)
| Item | Detail |
|---|---|
| Base Tariff | 5.9% |
| Additional Tariff (Section 301) | 25.0% |
| Total Tax Rate | 30.9% |
| Tax Calculation | CIF Value Γ 30.9% |
| De Minimis Exemption | β Not Eligible (Likely subject to full duty if above $800) |
| Legal Basis | HTSUS 3209.90 |
π Explanation:
- This category captures water-based paints that are NOT Acrylic or Vinyl (e.g., water-borne epoxies, polyurethanes, alkyds, or mixed synthetic polymers).
- High Cost Warning: A 30.9% total tax rate significantly erodes profit margins.
- Action: If your product falls here, consider reformulating to use Acrylic/Vinyl binders to switch to3209.10.00.00(0% tax), if chemically feasible.
π― 4. 3210.00.00.00 ββ Other Paints & Leather Finishes
| Item | Detail |
|---|---|
| Base Tariff | 0.0% |
| Additional Tariff (Section 301) | 0.0% |
| Total Tax Rate | 0.0% |
| Tax Calculation | CIF Value Γ 0% = $0 |
| De Minimis Exemption | β Eligible |
| Legal Basis | HTSUS 3210 (General/Other category) |
π Explanation:
- Includes general paints not covered by 3208/3209, and specifically prepared pigments for finishing leather.
- Zero Tax advantage makes this an attractive classification for niche products (e.g., leather dyes, specialized industrial coatings) that don't fit the strict "Acrylic/Vinyl" or "Polyester" definitions of 3208/3209.
π οΈ Four, Customs Clearance Practical Advice (Risk Avoidance Guide)
β 1. Required Documentation Checklist
| Document | Mandatory? | Description |
|---|---|---|
| β Product Specification Sheet | βοΈ | Must list: Resin Type (Acrylic, Vinyl, Polyester, etc.), Solvent Base (Water/Solvent), VOC Content, Usage. |
| β Safety Data Sheet (SDS) | βοΈ | Critical for identifying hazardous materials, flash point, and chemical composition. |
| β Commercial Invoice | βοΈ | Must clearly state: "Paint/Varnish," HS Code, Origin, and Value. |
| β Coating Formulation Statement | βοΈ | Detailed breakdown of binders/resins to justify HS Code selection (e.g., proving it is Acrylic for 3209.10). |
| β VOC Compliance Certificate | βοΈ | Required for US import to prove compliance with EPA/State VOC limits. |
| β Labeling | βοΈ | Must include ingredient warnings, usage instructions, and manufacturer details per US regulations. |
β 2. Declaration Strategies (Key Mnemonics)
π₯ "Water-based Acrylic/Vinyl is Free, Solvent is Free, Water-based 'Other' is Expensive!"
| Scenario | Correct HS Code | Tax Rate | Common Mistake |
|---|---|---|---|
| Water-based Wall Paint (Latex) | 3209.10.00.00 |
0% | Misclassifying as "Other" (3209.90) β 30.9% |
| Solvent-based Car Lacquer | 3208.10.00.00 or 3208.20.00.00 |
0% | None (Standard) |
| Water-based Epoxy Coating | 3209.90.00.00 |
30.9% | High Cost! Consider reformulation. |
| Leather Finishing Spray | 3210.00.00.00 |
0% | Ensure it's specifically for leather finishing. |
| Mixed Synthetic Paint (No clear Acrylic/Vinyl) | 3209.90.00.00 |
30.9% | Risk of misclassification if "Other" is incorrect. |
β 3. Special Cases Handling
| Case | Handling Advice |
|---|---|
| Reformulation for Tax Savings | If currently classifying as 3209.90.00.00 (30.9%), consult chemists to replace non-Acrylic/Vinyl binders with Acrylic/Vinyl to qualify for 3209.10.00.00 (0%). |
| VOC Non-Compliance | Even with 0% duty, customs may seize goods if VOC levels exceed US EPA or State limits. Ensure pre-import testing. |
| Hazmat Classification | Paints are often Dangerous Goods (DG). Ensure proper UN packaging and DG declaration for air/sea freight to avoid logistical delays. |
| Leather Specific Products | If used for leather, explicitly declare "Prepared Pigments for Finishing Leather" under 3210.00.00.00 to ensure correct classification and 0% duty. |
π Five, Global Market Comparison (2026 Latest)
| Country/Region | Recommended HS Code | Tariff (China Origin) | Key Requirement | Notes |
|---|---|---|---|---|
| πΊπΈ USA | 3209.10.00.00 / 3208.x0 |
0% (Acrylic/Vinyl/Solvent) | EPA VOC, SDS | Avoid 3209.90 (30.9%) |
| π¨π³ China | 3209.10.00.00 |
~5% | CCC (if applicable) | Lower base tariff |
| πͺπΊ EU | 3209.10.00.00 |
0-6.5% | REACH Registration | Strict chemical compliance |
| π¬π§ UK | 3209.10.00.00 |
0-6.5% | UK REACH | Post-Brexit compliance |
| π―π΅ Japan | 3209.10.00.00 |
0-5% | JIS Standards | No major additional tariffs |
π Conclusion:
- USA is the critical market for high-tax risks (3209.90.00.00).
- 0% Duty Strategy: Focus on Solvent-based (3208) or Water-based Acrylic/Vinyl (3209.10).
- Risk Avoidance: Do NOT use3209.90.00.00unless necessary. The 30.9% tax is a significant cost driver.
π Six, Common Errors & Pitfalls (Lessons Learned)
β Error 1: Classifying Water-based Acrylic Paint as "Other Paint" (3209.90.00.00)
π Consequence: Paying 30.9% tax instead of 0%. Huge financial loss!
β Error 2: Ignoring VOC Compliance
π Consequence: Goods detained by CBP/EPA, even if duty is 0%. Clearance delay or destruction.
β Error 3: Incomplete Formulation Disclosure
π Consequence: Customs challenges HS Code. If they deem it "Other," they may apply the higher 30.9% rate retrospectively.
β Error 4: Mixing Leather Finish with General Paint
π Consequence: Misclassification. Use 3210.00.00.00 specifically for leather finishing agents to ensure correct 0% duty.
β Correct Practice:
"Water-based Acrylic Latex Paint, Low VOC, for Interior Walls, Model XYZ, EPA Compliant" β HS: 3209.10.00.00 (0%)
π― Seven, Conclusion: Precision Classification, Maximize Profit!
π― Remember the Golden Rules:
πΉ "Water-based Acrylic/Vinyl = 0% (Happy Path)"
πΉ "Solvent-based Polyester/Acrylic/Vinyl = 0% (Safe Path)"
πΉ "Water-based 'Other' = 30.9% (Avoid!)"
πΉ "Leather Finish = 3210.00.00.00 (0% Specific)"
π Pro Tip:
If your product is water-based but not Acrylic/Vinyl, consult a chemical engineer to reformulate with Acrylic/Vinyl binders. The 30.9% savings can outweigh R&D costs for high-volume shipments.
π£ Immediate Action:
π Contact your customs broker to verify your specific formulation against HS Codes 3208, 3209, and 3210.
π Provide a detailed Coating Formulation to justify Acrylic/Vinyl classification for 0% duty.
π Optimize your supply chain by choosing the right HS Code to eliminate unnecessary 30.9% taxes!
β¨ Professional Customs Clearance Starts with Accurate Classification!
πΌ Every Percent of Tax Saved is Pure Profit!
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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.