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'. This chapter is an important chapter in the chemical industry regarding colouring and coating materials, including products ranging from natural tanning materials and synthetic dyes to various paints, varnishes, pigments, inks, etc. Its core lies in changing the surface colour of materials or providing protective coatings through chemical or physical means, and it is widely used in textiles, construction, automobiles, printing and other industries. 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 specifically targets solvent-based (non-aqueous medium) paints and varnishes based on synthetic polymers, including polyester, acrylic, polyurethane, epoxy and other types. The key features are 'non-aqueous medium' and 'based on synthetic polymers', which distinguish it from water-based coatings (3209) and natural resin coatings (3207). Code 320890 is a 6-digit subheading. The first 2 digits '32' represent Chapter 32, belonging to products related to the chemical industry. The 3rd-4th digits '08' represent heading 3208, namely 'Paints and varnishes (including enamels and lacquers) based on synthetic polymers or chemically modified natural polymers, dispersed or dissolved in a non-aqueous medium'. The 5th-6th digits '90' represent subheading 320890, namely 'Other', indicating other types not named under heading 3208. Specifically, under heading 3208, products are first divided by polymer type into polyester (320810), acrylic (320820), and polyurethane (320890? Note: in fact 320890 is 'Other', and polyurethane may be classified under 320890, but the subheading structure needs to be confirmed. According to the HS code, the subheadings under heading 3208 include: 320810 polyester, 320820 acrylic, 320890 other. Therefore polyurethane paints are usually classified under 320890 because they are not separately named. Thus 320890 represents other synthetic polymer paints besides polyester and acrylic, including polyurethane, epoxy, polyamide, etc. This product is polyurethane paint and varnish, belonging to coatings based on synthetic polymers (polyurethane) and dispersed in a non-aqueous medium. Since the HS code does not establish a separate subheading for polyurethane under heading 3208, while polyester (320810) and acrylic (320820) are separately named, polyurethane is classified under the 'Other' subheading 320890. If it is a water-based polyurethane coating, it should be classified under 3209; if it is a natural resin varnish, it should be classified under 3207.
Chapter
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'. This chapter is an important chapter in the chemical industry regarding colouring and coating materials, including products ranging from natural tanning materials and synthetic dyes to various paints, varnishes, pigments, inks, etc. Its core lies in changing the surface colour of materials or providing protective coatings through chemical or physical means, and it is widely used in textiles, construction, automobiles, printing and other industries.
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; solutions as defined in Note 4 to this Chapter'. This heading specifically targets solvent-based (non-aqueous medium) paints and varnishes based on synthetic polymers, including polyester, acrylic, polyurethane, epoxy and other types. The key features are 'non-aqueous medium' and 'based on synthetic polymers', which distinguish it from water-based coatings (3209) and natural resin coatings (3207).
Digit Breakdown
Code 320890 is a 6-digit subheading. The first 2 digits '32' represent Chapter 32, belonging to products related to the chemical industry. The 3rd-4th digits '08' represent heading 3208, namely 'Paints and varnishes (including enamels and lacquers) based on synthetic polymers or chemically modified natural polymers, dispersed or dissolved in a non-aqueous medium'. The 5th-6th digits '90' represent subheading 320890, namely 'Other', indicating other types not named under heading 3208. Specifically, under heading 3208, products are first divided by polymer type into polyester (320810), acrylic (320820), and polyurethane (320890? Note: in fact 320890 is 'Other', and polyurethane may be classified under 320890, but the subheading structure needs to be confirmed. According to the HS code, the subheadings under heading 3208 include: 320810 polyester, 320820 acrylic, 320890 other. Therefore polyurethane paints are usually classified under 320890 because they are not separately named. Thus 320890 represents other synthetic polymer paints besides polyester and acrylic, including polyurethane, epoxy, polyamide, etc.
Classification Basis
This product is polyurethane paint and varnish, belonging to coatings based on synthetic polymers (polyurethane) and dispersed in a non-aqueous medium. Since the HS code does not establish a separate subheading for polyurethane under heading 3208, while polyester (320810) and acrylic (320820) are separately named, polyurethane is classified under the 'Other' subheading 320890. If it is a water-based polyurethane coating, it should be classified under 3209; if it is a natural resin varnish, it should be classified under 3207.
📝 Declaration Elements
Product name: The specific name of the declared commodity, such as 'polyurethane varnish', 'polyurethane topcoat', etc., which should accurately reflect the product type and use. Composition and content: List the main components and percentages, including polyurethane resin, solvents, pigments, additives, etc., and indicate the polyurethane content. Appearance: Describe the physical state of the product, such as liquid, viscous liquid, whether it contains pigments, etc., which helps distinguish varnish from pigmented paint. Packaging specifications: Indicate the packaging form and net weight, such as iron drum, 20kg/drum. Use: Explain the product's application field, such as automotive refinishing, furniture coating, industrial anti-corrosion, etc. Brand: Declare the brand or trademark; if there is no brand, indicate 'unbranded'. Model: Product model or specification, to facilitate identification of the specific product. Solvent type: Indicate the main solvent type, such as xylene, butyl acetate, etc., to confirm the non-aqueous medium. Product name: Polyurethane varnish; Composition and content: polyurethane resin 60%, xylene 20%, butyl acetate 15%, additives 5%; Appearance: transparent liquid; Packaging specifications: iron drum, 20kg/drum; Use: for automotive refinishing coating; Brand: XX brand; Model: PU-100; Solvent type: xylene, butyl acetate. Mistakenly classifying water-based polyurethane coatings under 320890, when they should actually be classified under 3209. Failure to indicate the polyurethane resin content, making it impossible to determine the basic component. Confusing polyurethane paint with polyester paint; polyester paint should be classified under 320810.
Product name
The specific name of the declared commodity, such as 'polyurethane varnish', 'polyurethane topcoat', etc., which should accurately reflect the product type and use.
⚠️ Only writing 'paint' or 'coating' without indicating the polyurethane component.
Composition and content
List the main components and percentages, including polyurethane resin, solvents, pigments, additives, etc., and indicate the polyurethane content.
⚠️ Failure to indicate the polyurethane resin content, or only writing 'resin' without specifying it.
Appearance
Describe the physical state of the product, such as liquid, viscous liquid, whether it contains pigments, etc., which helps distinguish varnish from pigmented paint.
⚠️ Failure to distinguish varnish (transparent) from pigmented paint (opaque).
Packaging specifications
Indicate the packaging form and net weight, such as iron drum, 20kg/drum.
⚠️ Failure to provide net weight or unclear packaging unit.
Use
Explain the product's application field, such as automotive refinishing, furniture coating, industrial anti-corrosion, etc.
⚠️ The use description is too broad, such as 'for coating'.
Brand
Declare the brand or trademark; if there is no brand, indicate 'unbranded'.
⚠️ Confusing brand with manufacturer.
Model
Product model or specification, to facilitate identification of the specific product.
⚠️ Incomplete model entry or inconsistency with the actual product.
Solvent type
Indicate the main solvent type, such as xylene, butyl acetate, etc., to confirm the non-aqueous medium.
⚠️ Failure to indicate the solvent, or mistakenly writing it as water.
Mistakenly classifying water-based polyurethane coatings under 320890, when they should actually be classified under 3209.
Failure to indicate the polyurethane resin content, making it impossible to determine the basic component.
Confusing polyurethane paint with polyester paint; polyester paint should be classified under 320810.
🎯 Classification Logic
The core criteria for classification are: 1) whether the product is based on a synthetic polymer (polyurethane); 2) whether it is dispersed or dissolved in a non-aqueous medium; 3) whether it is paint or varnish. At the same time, reference should be made to the Explanatory Notes to heading 3208 and the subheading structure. If the product is water-based, it is classified under 3209; if it is a natural resin, it is classified under 3207. In addition, attention should be paid to whether it is a solution as defined in Note 4 to this Chapter, that is, besides varnishes, solutions based on synthetic polymers dissolved in a non-aqueous medium are also classified under 3208 if the conditions are met. 320810 Paints and varnishes based on polyesters: Based on polyester, not polyurethane. If the product is based on polyurethane, it cannot be classified under this code. 320820 Paints and varnishes based on acrylic polymers: Based on acrylic polymers. If the product is polyurethane-modified acrylic, the classification should be determined according to the main component; if polyurethane is predominant, it is classified under 320890. 320910 Water-based acrylic paints and varnishes: Based on acrylic polymers and dispersed in an aqueous medium. If the product is water-based polyurethane, it should be classified under 320990. 320990 Other water-based paints and varnishes: Based on other synthetic polymers and dispersed in an aqueous medium. If the product is water-based polyurethane, it is classified under this code. 321000 Other paints and varnishes; prepared pigments: Includes paints not based on synthetic polymers, such as natural resin varnishes, oil-based paints, etc. If the product is polyurethane, it is classified under 3208. Confirm that the basic component of the product is polyurethane resin. Confirm that the dispersion medium is non-aqueous (organic solvent). Confirm that the product is paint or varnish, not adhesive. Confirm whether it belongs to a solution as defined in Note 4 to this Chapter. Check the subheading structure and exclude polyester and acrylic types.
Basis
The core criteria for classification are: 1) whether the product is based on a synthetic polymer (polyurethane); 2) whether it is dispersed or dissolved in a non-aqueous medium; 3) whether it is paint or varnish. At the same time, reference should be made to the Explanatory Notes to heading 3208 and the subheading structure. If the product is water-based, it is classified under 3209; if it is a natural resin, it is classified under 3207. In addition, attention should be paid to whether it is a solution as defined in Note 4 to this Chapter, that is, besides varnishes, solutions based on synthetic polymers dissolved in a non-aqueous medium are also classified under 3208 if the conditions are met.
Confused Codes:
320810 - Paints and varnishes based on polyesters
Based on polyester, not polyurethane. If the product is based on polyurethane, it cannot be classified under this code.
320820 - Paints and varnishes based on acrylic polymers
Based on acrylic polymers. If the product is polyurethane-modified acrylic, the classification should be determined according to the main component; if polyurethane is predominant, it is classified under 320890.
320910 - Water-based acrylic paints and varnishes
Based on acrylic polymers and dispersed in an aqueous medium. If the product is water-based polyurethane, it should be classified under 320990.
320990 - Other water-based paints and varnishes
Based on other synthetic polymers and dispersed in an aqueous medium. If the product is water-based polyurethane, it is classified under this code.
321000 - Other paints and varnishes; prepared pigments
Includes paints not based on synthetic polymers, such as natural resin varnishes, oil-based paints, etc. If the product is polyurethane, it is classified under 3208.
Self-Check:
✓ Confirm that the basic component of the product is polyurethane resin.
✓ Confirm that the dispersion medium is non-aqueous (organic solvent).
✓ Confirm that the product is paint or varnish, not adhesive.
✓ Confirm whether it belongs to a solution as defined in Note 4 to this Chapter.
✓ Check the subheading structure and exclude polyester and acrylic types.
❓ FAQ
How to query the HS code for polyurethane paint? First confirm that the product is solvent-based (non-aqueous medium) and based on polyurethane. Then look for heading 3208 in Chapter 32. Since polyurethane is not separately named under 3208, it is classified under subheading 320890. If it is water-based, it is classified under 3209. It is recommended to use the customs tariff or authoritative databases and make a comprehensive judgment based on product composition and use. Are the HS codes for polyurethane varnish and polyurethane pigmented paint the same? Yes, both are classified under 320890, because the HS code under heading 3208 is divided by polymer type, not by whether pigments are contained. However, when declaring, the appearance (transparent or opaque) must be indicated to distinguish varnish from pigmented paint for customs inspection. Which code should water-based polyurethane coatings be classified under? Water-based polyurethane coatings should be classified under heading 3209, specifically 320990 (other water-based paints and varnishes), because 3209 covers paints and varnishes based on synthetic polymers and dispersed in an aqueous medium. If it is water-based acrylic, it is classified under 320910. How should polyurethane paint containing a small amount of acrylic be classified? Classification depends on the main component. If the polyurethane resin content is the highest, it is classified under 320890; if acrylic resin is predominant, it is classified under 320820. It should be judged according to the composition content table, usually taking the polymer with the largest weight percentage as the basic component. What is the difference between 320890 and 321000? 320890 specifically refers to paints and varnishes based on synthetic polymers (such as polyurethane) in a non-aqueous medium; 321000 covers other paints and varnishes, such as products based on natural resins, drying oils, etc., as well as prepared pigments. If the product is polyurethane, it is classified under 320890. What key information is required when declaring 320890? It is necessary to provide product name, composition and content (especially polyurethane resin content), appearance, packaging specifications, use, brand, model, solvent type, etc. Composition content and solvent type are key to determining classification and must be accurate. How to query the tax rate for polyurethane paint? Tax rates vary by country, trade agreement and annual adjustments. It is recommended to consult the latest edition of the 'Customs Import and Export Tariff of the People's Republic of China' or query through the General Administration of Customs website or the International Trade Single Window. At the same time, attention can be paid to preferential rates under free trade agreements. What are the consequences of mistakenly classifying polyurethane paint under 320810? It may lead to classification errors, affecting tariff collection and trade statistics. If discovered by customs, it may require supplementary tax payment, fines, and even affect enterprise credit. Therefore, polyester and polyurethane should be accurately distinguished to ensure the correct code.
Q: How to query the HS code for polyurethane paint?
A: First confirm that the product is solvent-based (non-aqueous medium) and based on polyurethane. Then look for heading 3208 in Chapter 32. Since polyurethane is not separately named under 3208, it is classified under subheading 320890. If it is water-based, it is classified under 3209. It is recommended to use the customs tariff or authoritative databases and make a comprehensive judgment based on product composition and use.
Q: Are the HS codes for polyurethane varnish and polyurethane pigmented paint the same?
A: Yes, both are classified under 320890, because the HS code under heading 3208 is divided by polymer type, not by whether pigments are contained. However, when declaring, the appearance (transparent or opaque) must be indicated to distinguish varnish from pigmented paint for customs inspection.
Q: Which code should water-based polyurethane coatings be classified under?
A: Water-based polyurethane coatings should be classified under heading 3209, specifically 320990 (other water-based paints and varnishes), because 3209 covers paints and varnishes based on synthetic polymers and dispersed in an aqueous medium. If it is water-based acrylic, it is classified under 320910.
Q: How should polyurethane paint containing a small amount of acrylic be classified?
A: Classification depends on the main component. If the polyurethane resin content is the highest, it is classified under 320890; if acrylic resin is predominant, it is classified under 320820. It should be judged according to the composition content table, usually taking the polymer with the largest weight percentage as the basic component.
Q: What is the difference between 320890 and 321000?
A: 320890 specifically refers to paints and varnishes based on synthetic polymers (such as polyurethane) in a non-aqueous medium; 321000 covers other paints and varnishes, such as products based on natural resins, drying oils, etc., as well as prepared pigments. If the product is polyurethane, it is classified under 320890.
Q: What key information is required when declaring 320890?
A: It is necessary to provide product name, composition and content (especially polyurethane resin content), appearance, packaging specifications, use, brand, model, solvent type, etc. Composition content and solvent type are key to determining classification and must be accurate.
Q: How to query the tax rate for polyurethane paint?
A: Tax rates vary by country, trade agreement and annual adjustments. It is recommended to consult the latest edition of the 'Customs Import and Export Tariff of the People's Republic of China' or query through the General Administration of Customs website or the International Trade Single Window. At the same time, attention can be paid to preferential rates under free trade agreements.
Q: What are the consequences of mistakenly classifying polyurethane paint under 320810?
A: It may lead to classification errors, affecting tariff collection and trade statistics. If discovered by customs, it may require supplementary tax payment, fines, and even affect enterprise credit. Therefore, polyester and polyurethane should be accurately distinguished to ensure the correct code.
⚠️ 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.