Chapter 32 covers 'Tanning or dyeing extracts; tannins and their derivatives; dyes, pigments and other colouring matter; paints and varnishes; putty and other mastics; inks', and is a core chapter for chemicals and coatings. This chapter includes a wide range of products from natural tanning materials and synthetic dyes to various paints, varnishes, and inks, but excludes separate organic dye intermediates (Chapter 29) and certain specialized adhesives (such as Chapter 35). The classification of Chapter 32 is mainly based on the chemical nature of the product, its use, and the type of medium, and it is a key chapter for customs classification in the coatings industry. Heading 3208 covers 'Paints and varnishes (including enamels and lacquers) based on synthetic polymers or chemically modified natural polymers, dispersed or dissolved in a non-aqueous medium; solutions as defined in Note 4 to this Chapter'. This heading mainly targets solvent-based coatings, and its core criteria are that the film-forming substance is a synthetic polymer or chemically modified natural polymer and that it is dispersed or dissolved in a non-aqueous medium (such as organic solvents). Note: coatings dissolved in an aqueous medium are classified under 3209, while 3208 specifically refers to non-aqueous medium systems. The first 2 digits '32' represent Chapter 32, namely 'Tanning or dyeing extracts; tannins and their derivatives; dyes, pigments and other colouring matter; paints and varnishes; putty and other mastics; inks'. The 3rd-4th digits '08' represent heading 3208, namely 'Paints and varnishes based on synthetic polymers or chemically modified natural polymers, dispersed or dissolved in a non-aqueous medium'. The 5th-6th digits '10' are the subheading, representing 'Polyester paints and varnishes (dissolved in an aqueous medium)'. Note: although the subheading text explicitly states 'dissolved in an aqueous medium', according to HS classification rules, subheading 3208.10 actually refers to polyester paints and varnishes whose medium is water (water-based). However, it should be noted that 3208 as a whole is for non-aqueous media, and the subheading description of 3208.10 differs in historical versions. In the current HS 2022 version, 3208.10 is 'Polyester paints and varnishes (dissolved in an aqueous medium)', which may be a special case in the coding table description, and the latest HS version should prevail. This product is classified under 3208.10 rather than adjacent codes because its film-forming substance is polyester (a synthetic polymer), and according to the subheading text it is explicitly dissolved in an aqueous medium. If it were acrylic or vinyl polymer, it would be classified under 3208.20 or 3208.30; if it were dispersed in a non-aqueous medium, it would be classified under 3208.90; if it were an aqueous medium but the film-forming substance were not polyester, it would be classified under 3209. Therefore, polyester + aqueous medium is the core feature of 3208.10.

Product name: The standard name of the declared commodity should include 'polyester paint' or 'polyester varnish' and the water-based medium feature. Composition and content: List the main components and percentages, including polyester resin, water, additives, pigments, etc. Use: Explain the use of the coating, such as building walls, metal anti-corrosion, wood coating, etc. Appearance: Describe the physical state of the product, such as liquid, viscous liquid, emulsion, etc. Packaging specifications: Indicate the packaging form and net weight, such as iron drum, net weight 20 kg. Brand: Declare the brand name (if any); if there is no brand, indicate 'unbranded'. Model: Fill in the product model or grade for easy identification. Whether dissolved in aqueous medium: Clearly declare whether water is used as the dispersion medium, answering 'yes' or 'no'. Product name: Polyester water-based varnish; Composition and content: polyester resin 45%, water 50%, additives 5%; Use: used for topcoating metal surfaces; Appearance: milky white liquid; Packaging specifications: iron drum, net weight 20 kg/drum; Brand: XX brand; Model: PE-100; Whether dissolved in aqueous medium: Yes. Mistakenly classifying water-based polyester coatings under 3208.90 (non-aqueous medium), resulting in tax rate differences. Failure to list polyester resin in the composition and content, making it impossible to prove it is polyester-based. Ignoring 'dissolved in an aqueous medium' in the subheading text and incorrectly declaring it as solvent-based.

The core basis for classification is: 1) whether the film-forming substance is polyester (a synthetic polymer); 2) whether the dispersion medium is water. According to HS rules, subheading 3208.10 is explicitly 'Polyester paints and varnishes (dissolved in an aqueous medium)', so both polyester and water-based conditions must be met simultaneously. If the film-forming substance is acrylic or vinyl, it is classified under 3208.20 or 3208.30; if it is another polymer, it is classified under 3208.90; if it is water-based but not polyester, it is classified under 3209. In addition, attention should be paid to the difference from 3209 (water-based coatings); 3209 covers all water-based coatings based on synthetic polymers, while 3208.10 is limited to polyester types. 3208.20 Acrylic paints and varnishes (dissolved in an aqueous medium): The film-forming substance is acrylic polymer, not polyester. If the product is an acrylic water-based coating, it should be classified under 3208.20. 3208.90 Other paints and varnishes (non-aqueous medium): The medium is non-aqueous (organic solvent), and the film-forming substance may be polyester or other polymers. If the polyester coating is solvent-based, it is classified under 3208.90. 3209.10 Acrylic paints and varnishes (aqueous medium): 3209 is for water-based coatings, but the film-forming substance is acrylic or another polymer, not polyester. If a polyester water-based coating is mistakenly classified under 3209, it is incorrect. 3208.10 Polyester paints and varnishes (dissolved in an aqueous medium): This code itself; note the distinction from other subheadings. 3907.91 Polyesters in primary forms: 3907 is for plastics in primary forms. If the polyester resin has not been made into paint, it is classified under 3907, not 3208. Is the film-forming substance polyester? Is the medium water? Has it been made into paint or varnish? Is it a non-aqueous medium? If not, consider 3209. Is it in primary form? If yes, classify under Chapter 39.

How should 'dissolved in an aqueous medium' in HS code 320810 be understood? It means the coating uses water as the dispersion medium rather than an organic solvent. Usually water-based coatings use water as the thinner and have low VOC content. If the product uses an organic solvent as the medium, it should not be classified under 320810, and 320890 should be considered. How can it be determined whether a coating is polyester-based? Check the ingredient list. If the main film-forming substance is polyester resin (such as alkyd resin, unsaturated polyester, etc.), it is polyester-based. If it is acrylic, epoxy, polyurethane, etc., it is not. What is the difference in classification between water-based polyester coatings and solvent-based polyester coatings? Water-based polyester coatings are classified under 320810, and solvent-based polyester coatings under 320890. The tax rates may differ, so the medium must be accurately declared. If a polyester coating contains both a small amount of organic solvent and water, how should it be classified? The main medium shall prevail. If water is the main dispersion medium, it can still be classified under 320810; if the organic solvent is predominant, it is classified under 320890. It is recommended to provide an MSDS as proof. What is the difference between 320810 and 320910? 320810 is polyester-based water-based coatings, and 320910 is acrylic-based water-based coatings. The main difference lies in the film-forming substance: the former is polyester, and the latter is acrylic. What special documents are required to declare 320810? Usually an MSDS, component test report, water-based certificate, etc. are required. The MSDS should clearly state the film-forming substance and medium. How can cross-border e-commerce sellers of water-based polyester paint query the HS code? They can use the customs tariff query system, enter the keywords 'polyester paint' or 'water-based coating', and filter for subheading 320810. They may also consult a professional customs broker. What is the export tax rebate rate for 320810? The rebate rate may be adjusted with policy changes. It is recommended to check the latest export tax rebate rate database or consult the tax authorities. Usually the rebate rate for coatings is between 0-13%.