Chapter 32 covers tanning materials, dyes, pigments, paints, varnishes, putty and similar products, inks, etc. This chapter includes a wide range of products from natural resins to synthetic polymers, used for coloring, coating, or protecting surfaces. Heading 3209 specifically deals with paints and varnishes based on synthetic polymers, dispersed or dissolved in an aqueous medium. Heading 3209 covers paints and varnishes based on synthetic polymers, including acrylic polymers, vinyl polymers, etc., and must be in an aqueous medium (water or water-soluble medium). This heading includes architectural coatings, industrial coatings, etc., but excludes oil-based media (classified under 3208) or non-polymer-based coatings (such as 3207). First 2 digits 32: Chapter 32, covering tanning materials, dyes, pigments, paints, varnishes, putty, and inks, etc. Digits 3-4 09: Heading 3209, referring to paints and varnishes based on synthetic polymers, dispersed or dissolved in an aqueous medium. Digits 5-6 10: Subheading 320910, specifically referring to water-based paints and varnishes based on acrylic polymers or vinyl polymers. The product is an acrylic polymer water-based paint, meeting the definition of heading 3209: based on synthetic polymer (acrylic) and in an aqueous medium. It is not classified under 3208 (oil-based medium) or 3207 (non-polymer-based), nor under 3210 (other paints), as 3210 typically refers to non-aqueous or non-polymer-based finished products.
Chapter
Chapter 32 covers tanning materials, dyes, pigments, paints, varnishes, putty and similar products, inks, etc. This chapter includes a wide range of products from natural resins to synthetic polymers, used for coloring, coating, or protecting surfaces. Heading 3209 specifically deals with paints and varnishes based on synthetic polymers, dispersed or dissolved in an aqueous medium.
Heading
Heading 3209 covers paints and varnishes based on synthetic polymers, including acrylic polymers, vinyl polymers, etc., and must be in an aqueous medium (water or water-soluble medium). This heading includes architectural coatings, industrial coatings, etc., but excludes oil-based media (classified under 3208) or non-polymer-based coatings (such as 3207).
Digit Breakdown
First 2 digits 32: Chapter 32, covering tanning materials, dyes, pigments, paints, varnishes, putty, and inks, etc. Digits 3-4 09: Heading 3209, referring to paints and varnishes based on synthetic polymers, dispersed or dissolved in an aqueous medium. Digits 5-6 10: Subheading 320910, specifically referring to water-based paints and varnishes based on acrylic polymers or vinyl polymers.
Classification Basis
The product is an acrylic polymer water-based paint, meeting the definition of heading 3209: based on synthetic polymer (acrylic) and in an aqueous medium. It is not classified under 3208 (oil-based medium) or 3207 (non-polymer-based), nor under 3210 (other paints), as 3210 typically refers to non-aqueous or non-polymer-based finished products.
📝 Declaration Elements
Product Name: The specific name of the declared product should include key information such as acrylic and water-based, e.g., 'acrylic water-based paint'. Composition Content: List the main components and percentages, such as acrylic resin 30%, water 50%, pigment 15%, additives 5%. Use: Explain the use of the paint, such as architectural wall coating, metal anti-corrosion, etc. Packaging Specifications: Indicate the packaging form and net weight, such as 20kg/drum. Brand: Declare the brand name (if any); if no brand, indicate 'no brand'. Model: Declare the product model or specification, such as A100. Whether Dispersed in Aqueous Medium: Confirm whether water is the dispersion medium, answer 'yes' or 'no'. Product Name: Acrylic water-based paint; Composition Content: Acrylic resin 35%, water 50%, titanium dioxide 10%, additives 5%; Use: Architectural interior wall coating; Packaging Specifications: 20kg/drum; Brand: ABC; Model: A100; Whether Dispersed in Aqueous Medium: Yes. Misreporting water-based paint as oil-based paint, leading to classification under 3208. Incomplete declaration of composition content, not listing all components and proportions. Use description too broad, not specifying the application scenario.
Product Name
The specific name of the declared product should include key information such as acrylic and water-based, e.g., 'acrylic water-based paint'.
⚠️ Only writing 'paint' or 'coating' without specifying composition and water-based nature.
Composition Content
List the main components and percentages, such as acrylic resin 30%, water 50%, pigment 15%, additives 5%.
⚠️ Not listing the proportions of each component, or only writing 'acrylic resin' without content.
Use
Explain the use of the paint, such as architectural wall coating, metal anti-corrosion, etc.
⚠️ Vague description of use, such as 'industrial use', without specifics.
Packaging Specifications
Indicate the packaging form and net weight, such as 20kg/drum.
⚠️ Not indicating net weight or unclear packaging unit.
Brand
Declare the brand name (if any); if no brand, indicate 'no brand'.
⚠️ Confusing brand with manufacturer, or not declaring the brand.
Model
Declare the product model or specification, such as A100.
⚠️ Missing model or inconsistent with use.
Whether Dispersed in Aqueous Medium
Confirm whether water is the dispersion medium, answer 'yes' or 'no'.
Misreporting water-based paint as oil-based paint, leading to classification under 3208.
Incomplete declaration of composition content, not listing all components and proportions.
Use description too broad, not specifying the application scenario.
🎯 Classification Logic
The core basis for classification is: 1. Whether the basic component is a synthetic polymer (such as acrylic polymer); 2. Whether it is dispersed or dissolved in an aqueous medium; 3. Whether it is a paint or varnish. If all are met, classify under 3209, and then according to the polymer type, classify under subheading 320910. 3208 Acrylic polymer oil-based paint: 3208 is oil-based medium (non-aqueous), 3209 is aqueous medium. The core difference lies in the dispersion medium. 3207 Non-polymer-based paint: 3207 covers paints not based on synthetic polymers, such as natural resin-based, not classified under 3209. 3210 Other paints and varnishes: 3210 typically refers to non-aqueous or non-polymer-based finished products, such as nitrocellulose lacquer, different from 3209's water-based polymer base. 3906 Acrylic polymers in primary forms: 3906 is polymers in primary forms, not made into paint, while 3209 is finished paint. Confirm whether the basic component is acrylic polymer. Confirm whether the dispersion medium is water. Confirm whether the product is paint or varnish. Confirm whether it is a finished product, not in primary form. Confirm whether it belongs to 3209 rather than 3208 or 3210.
Basis
The core basis for classification is: 1. Whether the basic component is a synthetic polymer (such as acrylic polymer); 2. Whether it is dispersed or dissolved in an aqueous medium; 3. Whether it is a paint or varnish. If all are met, classify under 3209, and then according to the polymer type, classify under subheading 320910.
Confused Codes：
3208 - Acrylic polymer oil-based paint
3208 is oil-based medium (non-aqueous), 3209 is aqueous medium. The core difference lies in the dispersion medium.
3207 - Non-polymer-based paint
3207 covers paints not based on synthetic polymers, such as natural resin-based, not classified under 3209.
3210 - Other paints and varnishes
3210 typically refers to non-aqueous or non-polymer-based finished products, such as nitrocellulose lacquer, different from 3209's water-based polymer base.
3906 - Acrylic polymers in primary forms
3906 is polymers in primary forms, not made into paint, while 3209 is finished paint.
Self-Check：
✓ Confirm whether the basic component is acrylic polymer.
✓ Confirm whether the dispersion medium is water.
✓ Confirm whether the product is paint or varnish.
✓ Confirm whether it is a finished product, not in primary form.
✓ Confirm whether it belongs to 3209 rather than 3208 or 3210.
❓ FAQ
How to determine whether acrylic water-based paint should be classified under 320910 or 320990? 320910 specifically refers to water-based paints based on acrylic polymers or vinyl polymers, 320990 is water-based paints based on other polymers. If the basic component is acrylic polymer, classify under 320910; if it is other polymers such as polyurethane, classify under 320990. What is the difference in HS codes between acrylic water-based paint and oil-based paint? Water-based paint is classified under 3209, oil-based paint under 3208. The difference lies in the dispersion medium: water-based paint uses water as medium, oil-based paint uses organic solvents as medium. The medium type must be clearly declared. If the acrylic resin content in acrylic water-based paint is less than 50%, can it still be classified under 320910? Yes, the HS code does not specify a minimum polymer content. As long as the acrylic polymer is the basic component and it is an aqueous medium, it can be classified under 320910. However, note that if other components dominate, it may affect classification. In the declaration elements for acrylic water-based paint, how detailed should the composition content be? All main components and their percentages should be listed, including resin, water, pigments, additives, etc. If solvents are contained, they should also be indicated. Composition content is an important basis for customs classification and valuation. For cross-border e-commerce sales of acrylic water-based paint, how to query the HS code and tax rate? You can query HS code 320910 through the General Administration of Customs website or the International Trade Single Window. Tax rates change with policies, so it is recommended to check the latest version. You can also consult a professional customs broker. If acrylic water-based paint is used for artistic painting, is it still classified under 320910? Yes, as long as it is water-based paint based on acrylic polymer, regardless of use, it is classified under 320910. However, if it is art pigment, it may be classified under 3213, depending on specific composition and packaging. When declaring, how to distinguish between 'water-based' and 'water-soluble'? 'Water-based' means water is the dispersion medium, and the polymer is dispersed in particle form; 'water-soluble' means the polymer is dissolved in water. 3209 includes paints dispersed or dissolved in aqueous media, both can be classified, but must be accurately described when declaring. Does the packaging specification of acrylic water-based paint affect the HS code? Usually not, the HS code is based on composition and medium, not packaging. However, if it is retail packaging, other classification factors may be involved, such as 3210. General industrial packaging is still classified under 320910.
Q: How to determine whether acrylic water-based paint should be classified under 320910 or 320990?
A: 320910 specifically refers to water-based paints based on acrylic polymers or vinyl polymers, 320990 is water-based paints based on other polymers. If the basic component is acrylic polymer, classify under 320910; if it is other polymers such as polyurethane, classify under 320990.
Q: What is the difference in HS codes between acrylic water-based paint and oil-based paint?
A: Water-based paint is classified under 3209, oil-based paint under 3208. The difference lies in the dispersion medium: water-based paint uses water as medium, oil-based paint uses organic solvents as medium. The medium type must be clearly declared.
Q: If the acrylic resin content in acrylic water-based paint is less than 50%, can it still be classified under 320910?
A: Yes, the HS code does not specify a minimum polymer content. As long as the acrylic polymer is the basic component and it is an aqueous medium, it can be classified under 320910. However, note that if other components dominate, it may affect classification.
Q: In the declaration elements for acrylic water-based paint, how detailed should the composition content be?
A: All main components and their percentages should be listed, including resin, water, pigments, additives, etc. If solvents are contained, they should also be indicated. Composition content is an important basis for customs classification and valuation.
Q: For cross-border e-commerce sales of acrylic water-based paint, how to query the HS code and tax rate?
A: You can query HS code 320910 through the General Administration of Customs website or the International Trade Single Window. Tax rates change with policies, so it is recommended to check the latest version. You can also consult a professional customs broker.
Q: If acrylic water-based paint is used for artistic painting, is it still classified under 320910?
A: Yes, as long as it is water-based paint based on acrylic polymer, regardless of use, it is classified under 320910. However, if it is art pigment, it may be classified under 3213, depending on specific composition and packaging.
Q: When declaring, how to distinguish between 'water-based' and 'water-soluble'?
A: 'Water-based' means water is the dispersion medium, and the polymer is dispersed in particle form; 'water-soluble' means the polymer is dissolved in water. 3209 includes paints dispersed or dissolved in aqueous media, both can be classified, but must be accurately described when declaring.
Q: Does the packaging specification of acrylic water-based paint affect the HS code?
A: Usually not, the HS code is based on composition and medium, not packaging. However, if it is retail packaging, other classification factors may be involved, such as 3210. General industrial packaging is still classified under 320910.
⚠️ 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.