Chapter 32 covers tanning and dyeing extracts, tannins and their derivatives, dyes, pigments and other colouring matter, paints and varnishes, putty and similar adhesives, inks, etc. The core feature of this chapter is that the products are used for colouring, coating, decorating or protecting surfaces, including colouring substances and film-forming substances of both natural and synthetic origin. Acrylic polymer paints and varnishes, as coatings based on synthetic polymers, are an important part of this chapter. 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. Specifically, it includes solvent-based coatings based on acrylic polymers, polyesters, vinyl polymers, etc. This heading emphasizes a non-aqueous medium (such as organic solvents), distinguishing it from water-based medium coatings (heading 3209). First 2 digits 32: Chapter 32, covering dyes, pigments, paints, varnishes, inks, etc. Digits 3-4: 08: Heading 3208, referring to paints and varnishes based on synthetic polymers or chemically modified natural polymers, dispersed or dissolved in a non-aqueous medium. Digits 5-6: 20: Subheading 320820, specifically referring to paints and varnishes based on acrylic polymers or vinyl polymers. Acrylic polymers include pure acrylic, styrene-acrylic copolymers, etc., widely used in architectural, automotive, and industrial coatings. This commodity uses acrylic polymer as the film-forming substance and is dispersed or dissolved in a non-aqueous medium (such as organic solvents), conforming to the description of heading 3208 and subheading 320820. If it is a water-based medium (with water as the dispersion medium), it should be classified under 3209; if it is other polymers (such as polyester, polyurethane), it should be classified under other subheadings of 3208; if it is natural resin or oil-based paint, it may be classified under earlier subheadings of 3208 or 3210.
Chapter
Chapter 32 covers tanning and dyeing extracts, tannins and their derivatives, dyes, pigments and other colouring matter, paints and varnishes, putty and similar adhesives, inks, etc. The core feature of this chapter is that the products are used for colouring, coating, decorating or protecting surfaces, including colouring substances and film-forming substances of both natural and synthetic origin. Acrylic polymer paints and varnishes, as coatings based on synthetic polymers, are an important part of this chapter.
Heading
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. Specifically, it includes solvent-based coatings based on acrylic polymers, polyesters, vinyl polymers, etc. This heading emphasizes a non-aqueous medium (such as organic solvents), distinguishing it from water-based medium coatings (heading 3209).
Digit Breakdown
First 2 digits 32: Chapter 32, covering dyes, pigments, paints, varnishes, inks, etc. Digits 3-4: 08: Heading 3208, referring to paints and varnishes based on synthetic polymers or chemically modified natural polymers, dispersed or dissolved in a non-aqueous medium. Digits 5-6: 20: Subheading 320820, specifically referring to paints and varnishes based on acrylic polymers or vinyl polymers. Acrylic polymers include pure acrylic, styrene-acrylic copolymers, etc., widely used in architectural, automotive, and industrial coatings.
Classification Basis
This commodity uses acrylic polymer as the film-forming substance and is dispersed or dissolved in a non-aqueous medium (such as organic solvents), conforming to the description of heading 3208 and subheading 320820. If it is a water-based medium (with water as the dispersion medium), it should be classified under 3209; if it is other polymers (such as polyester, polyurethane), it should be classified under other subheadings of 3208; if it is natural resin or oil-based paint, it may be classified under earlier subheadings of 3208 or 3210.
📝 Declaration Elements
Product Name: The standard name of the declared commodity should include keywords such as acrylic polymer paint or varnish, avoiding colloquial names or brand names. Composition and Content: List the main components and their percentage contents, such as acrylic resin, solvents, pigments, additives, etc., and indicate whether other polymers are contained. Appearance: Describe the physical state of the product, such as liquid, viscous liquid, paste, etc., as well as characteristics such as colour and odour. Whether Dispersed in Non-Aqueous Medium: Clearly state the type of dispersion medium, such as organic solvents (toluene, xylene, etc.); if it is water, classify under 3209. Use: Explain the specific application scenarios, such as architectural wall coating, automotive refinish paint, industrial equipment anti-corrosion, etc. Brand: Declare the brand name (if no brand, state none), which helps customs valuation and intellectual property verification. Model: Declare the product model or specification, such as A-100, X200, etc., to distinguish different formulations. Packaging Specification: State the packaging form and net weight, such as iron drum, 20kg/drum, for statistics and supervision. Product Name: Acrylic polymer paint; Composition and Content: Acrylic resin 45%, xylene 30%, titanium dioxide 20%, additives 5%; Appearance: White viscous liquid; Whether Dispersed in Non-Aqueous Medium: Yes (organic solvent); Use: For architectural exterior wall coating; Brand: XX brand; Model: AW-100; Packaging Specification: Iron drum, 20kg/drum. Mistakenly classifying water-based acrylic coatings under 320820, when they should actually be classified under 320910. The acrylic resin content in the composition does not reach above 50%, and it may be classified under other subheadings. Failing to distinguish between varnish and paint; varnish usually does not contain pigments, but the classification is the same.
Product Name
The standard name of the declared commodity should include keywords such as acrylic polymer paint or varnish, avoiding colloquial names or brand names.
⚠️ Writing only 'paint' or 'coating' without reflecting the acrylic component, leading to classification disputes.
Composition and Content
List the main components and their percentage contents, such as acrylic resin, solvents, pigments, additives, etc., and indicate whether other polymers are contained.
⚠️ Failing to indicate the acrylic resin content, or vaguely writing 'resin', making it impossible to determine whether it is the main component.
Appearance
Describe the physical state of the product, such as liquid, viscous liquid, paste, etc., as well as characteristics such as colour and odour.
⚠️ Writing only 'liquid' without stating whether it contains pigments or whether it is transparent, affecting subheading determination.
Whether Dispersed in Non-Aqueous Medium
Clearly state the type of dispersion medium, such as organic solvents (toluene, xylene, etc.); if it is water, classify under 3209.
⚠️ Mistakenly declaring water-based acrylic coatings as non-aqueous medium, leading to classification errors.
Use
Explain the specific application scenarios, such as architectural wall coating, automotive refinish paint, industrial equipment anti-corrosion, etc.
⚠️ The use description is too broad, such as 'for coating', which cannot assist classification.
Brand
Declare the brand name (if no brand, state none), which helps customs valuation and intellectual property verification.
⚠️ Omitting or misreporting the brand, leading to subsequent audit risks.
Model
Declare the product model or specification, such as A-100, X200, etc., to distinguish different formulations.
⚠️ Incomplete model filling or inconsistency with the actual product, affecting traceability.
Packaging Specification
State the packaging form and net weight, such as iron drum, 20kg/drum, for statistics and supervision.
⚠️ Writing only 'drum' without stating the net weight, leading to unit conversion errors.
Example： Product Name: Acrylic polymer paint; Composition and Content: Acrylic resin 45%, xylene 30%, titanium dioxide 20%, additives 5%; Appearance: White viscous liquid; Whether Dispersed in Non-Aqueous Medium: Yes (organic solvent); Use: For architectural exterior wall coating; Brand: XX brand; Model: AW-100; Packaging Specification: Iron drum, 20kg/drum.
Common Mistakes：
Mistakenly classifying water-based acrylic coatings under 320820, when they should actually be classified under 320910.
The acrylic resin content in the composition does not reach above 50%, and it may be classified under other subheadings.
Failing to distinguish between varnish and paint; varnish usually does not contain pigments, but the classification is the same.
🎯 Classification Logic
The core criteria for classification are: 1. Whether the basic component is an acrylic polymer; 2. Whether it is dispersed or dissolved in a non-aqueous medium; 3. Whether it is a paint or varnish. According to the Import and Export Tariff and its notes, subheading 320820 only covers paints and varnishes based on acrylic polymers or vinyl polymers. If the product is water-based, classify under 3209; if it is other polymers, classify under other subheadings of 3208; if it is natural resin, classify under earlier subheadings of 3208 or 3210. 320910 Acrylic polymer water-based paints and varnishes: The core difference lies in the dispersion medium: 320910 is water-based (with water as the dispersion medium), while 320820 is non-aqueous (organic solvents). If the product uses water as the thinner, it should be classified under 320910. 320890 Other polymer paints and varnishes: 320890 covers paints and varnishes based on other synthetic polymers (such as polyester, polyurethane, epoxy resin) other than acrylic and vinyl polymers, dispersed in a non-aqueous medium. If the film-forming substance is not acrylic, classify under 320890. 320990 Other water-based paints and varnishes: 320990 covers water-based paints and varnishes based on other synthetic polymers. If the product is water-based and not an acrylic polymer, classify under 320990. 321000 Other paints and varnishes; prepared pigments; inks: 321000 covers natural resins, oil-based paints, enamels, etc., as well as inks. If the product is natural resin-based or oil-based, classify under 321000. 390690 Acrylic polymers in primary forms: 390690 is acrylic polymers in primary forms, not made into paints or varnishes. If the product is a pure polymer without added solvents, pigments, etc., classify under 390690. Confirm whether the film-forming substance is an acrylic polymer. Confirm whether the dispersion medium is a non-aqueous medium (organic solvent). Confirm whether the product is a paint or varnish (not adhesive, ink). Confirm whether the acrylic polymer is the main component (usually >50%). Confirm whether pigments, fillers and other additives have been added.
Basis
The core criteria for classification are: 1. Whether the basic component is an acrylic polymer; 2. Whether it is dispersed or dissolved in a non-aqueous medium; 3. Whether it is a paint or varnish. According to the Import and Export Tariff and its notes, subheading 320820 only covers paints and varnishes based on acrylic polymers or vinyl polymers. If the product is water-based, classify under 3209; if it is other polymers, classify under other subheadings of 3208; if it is natural resin, classify under earlier subheadings of 3208 or 3210.
Confused Codes：
320910 - Acrylic polymer water-based paints and varnishes
The core difference lies in the dispersion medium: 320910 is water-based (with water as the dispersion medium), while 320820 is non-aqueous (organic solvents). If the product uses water as the thinner, it should be classified under 320910.
320890 - Other polymer paints and varnishes
320890 covers paints and varnishes based on other synthetic polymers (such as polyester, polyurethane, epoxy resin) other than acrylic and vinyl polymers, dispersed in a non-aqueous medium. If the film-forming substance is not acrylic, classify under 320890.
320990 - Other water-based paints and varnishes
320990 covers water-based paints and varnishes based on other synthetic polymers. If the product is water-based and not an acrylic polymer, classify under 320990.
321000 - Other paints and varnishes; prepared pigments; inks
321000 covers natural resins, oil-based paints, enamels, etc., as well as inks. If the product is natural resin-based or oil-based, classify under 321000.
390690 - Acrylic polymers in primary forms
390690 is acrylic polymers in primary forms, not made into paints or varnishes. If the product is a pure polymer without added solvents, pigments, etc., classify under 390690.
Self-Check：
✓ Confirm whether the film-forming substance is an acrylic polymer.
✓ Confirm whether the dispersion medium is a non-aqueous medium (organic solvent).
✓ Confirm whether the product is a paint or varnish (not adhesive, ink).
✓ Confirm whether the acrylic polymer is the main component (usually >50%).
✓ Confirm whether pigments, fillers and other additives have been added.
❓ FAQ
How to determine whether acrylic paint is water-based or solvent-based? Check the product MSDS or ingredient list: if the thinner is water or the main solvent is water, it is water-based and classified under 320910; if the thinner is an organic solvent (such as xylene, butyl acetate), it is solvent-based and classified under 320820. It can also be preliminarily judged by appearance and odour, but the composition shall prevail. Is there any difference in classification between acrylic varnish and acrylic paint? No difference. HS code 320820 covers both paints and varnishes, as long as the basic component is an acrylic polymer and it is dispersed in a non-aqueous medium, it is classified under this code. Varnish usually does not contain pigments, while paint contains pigments, but the classification is the same. If the acrylic resin content is less than 50%, can it still be classified under 320820? Subheading 320820 requires that the basic component be an acrylic polymer, usually referring to the component with the highest content or the main film-forming effect. If the acrylic resin content is lower than other resins, it may be classified according to other polymers, such as 320890. It is recommended to provide accurate component proportions. What elements should be declared for acrylic polymer paint used for automotive refinishing? It is necessary to declare the product name, composition and content, appearance, whether it is a non-aqueous medium, use (automotive refinishing), brand, model, and packaging specification. The use should be specific, such as 'for automotive body refinishing', so that customs can confirm the classification. How to classify small-package acrylic paint sold via cross-border e-commerce? It is still classified according to composition and medium, regardless of package size. If it is solvent-based acrylic paint, classify under 320820; if water-based, classify under 320910. However, note that small packages may involve dangerous goods transportation requirements, and MSDS must be provided during declaration. What is the difference between acrylic paint and acrylic latex paint? Acrylic latex paint usually uses water as the dispersion medium and is classified under 320910; acrylic paint usually uses organic solvents as the dispersion medium and is classified under 320820. The film-forming substance may be the same, but different media lead to different classifications. How to check the import tax rate for 320820? You can log in to the website of the General Administration of Customs of China or use the 'China Customs Import and Export Tariff' to check, enter HS code 320820, and view the MFN rate, general rate, VAT rate, etc. Tax rates may be adjusted with policies; it is recommended to refer to the latest version. What are the consequences of mistakenly declaring 320820 as 320890? It may lead to classification errors, affecting tax collection and customs statistics. If discovered by customs, it may require tax supplementation, fines, or even affect the enterprise's credit rating. It is recommended to declare truthfully and apply for pre-classification when necessary.
Q: How to determine whether acrylic paint is water-based or solvent-based?
A: Check the product MSDS or ingredient list: if the thinner is water or the main solvent is water, it is water-based and classified under 320910; if the thinner is an organic solvent (such as xylene, butyl acetate), it is solvent-based and classified under 320820. It can also be preliminarily judged by appearance and odour, but the composition shall prevail.
Q: Is there any difference in classification between acrylic varnish and acrylic paint?
A: No difference. HS code 320820 covers both paints and varnishes, as long as the basic component is an acrylic polymer and it is dispersed in a non-aqueous medium, it is classified under this code. Varnish usually does not contain pigments, while paint contains pigments, but the classification is the same.
Q: If the acrylic resin content is less than 50%, can it still be classified under 320820?
A: Subheading 320820 requires that the basic component be an acrylic polymer, usually referring to the component with the highest content or the main film-forming effect. If the acrylic resin content is lower than other resins, it may be classified according to other polymers, such as 320890. It is recommended to provide accurate component proportions.
Q: What elements should be declared for acrylic polymer paint used for automotive refinishing?
A: It is necessary to declare the product name, composition and content, appearance, whether it is a non-aqueous medium, use (automotive refinishing), brand, model, and packaging specification. The use should be specific, such as 'for automotive body refinishing', so that customs can confirm the classification.
Q: How to classify small-package acrylic paint sold via cross-border e-commerce?
A: It is still classified according to composition and medium, regardless of package size. If it is solvent-based acrylic paint, classify under 320820; if water-based, classify under 320910. However, note that small packages may involve dangerous goods transportation requirements, and MSDS must be provided during declaration.
Q: What is the difference between acrylic paint and acrylic latex paint?
A: Acrylic latex paint usually uses water as the dispersion medium and is classified under 320910; acrylic paint usually uses organic solvents as the dispersion medium and is classified under 320820. The film-forming substance may be the same, but different media lead to different classifications.
Q: How to check the import tax rate for 320820?
A: You can log in to the website of the General Administration of Customs of China or use the 'China Customs Import and Export Tariff' to check, enter HS code 320820, and view the MFN rate, general rate, VAT rate, etc. Tax rates may be adjusted with policies; it is recommended to refer to the latest version.
Q: What are the consequences of mistakenly declaring 320820 as 320890?
A: It may lead to classification errors, affecting tax collection and customs statistics. If discovered by customs, it may require tax supplementation, fines, or even affect the enterprise's credit rating. It is recommended to declare truthfully and apply for pre-classification when necessary.
⚠️ Disclaimer: HS code classification, declaration elements, tariff rates and regulatory conditions on this page are for reference only and do not constitute legal advice on customs classification. Tariff rates and regulations are subject to change; the latest announcements from the General Administration of Customs and on-site determinations shall prevail. Please consult professional customs brokers or customs authorities before import/export.