Product classification
HS code for Paints: 3208.90
Paints and varnishes, based on polymers n.e.c. in heading no. 3208, dispersed or dissolved in a non-aqueous medium.
Classification of paints under HS 3208.90
Paints and varnishes classified under HS code 3208.90 are defined by their chemical composition, specifically being based on synthetic polymers or chemically modified natural polymers. The defining characteristic for this heading is that the polymers are dispersed or dissolved in a non-aqueous medium, meaning a solvent-based system rather than a water-based one. Subheading 3208.90 serves as a residual category for those products where the polymer is not an acrylic or vinyl polymer, which are instead classified under 3208.10 or 3208.20. For a product to be classified here, the weight of the organic solvent must exceed 50% of the weight of the solution. This classification is essential for distinguishing industrial-grade solvent-based coatings from water-based alternatives. The determination follows General Interpretative Rules 1 and 6, ensuring that the product's physical state as a liquid or paste and its chemical solvent base are the primary factors for its placement in the tariff schedule.
- Covers
- Solvent-based enamels
- Polyurethane lacquers
- Epoxy-based industrial coatings
- Silicone-based varnishes
- Non-aqueous metallic paints
- Also under 3208.90
- Sherwin-Williams ProMar 200
- AkzoNobel Interpon
- PPG Delfleet
- Jotun Hardtop
- Rust-Oleum Industrial Enamel
Codes often confused with 3208.90
Common mistake. Paints are frequently misclassified under heading 3209, which is reserved for paints and varnishes dispersed or dissolved in an aqueous (water) medium. Another common error involves heading 3210, which covers other paints and varnishes not based on polymers, or heading 3214, which is intended for glaziers' putty, grafting putty, and resin cements. Importers must verify the solvent content percentage to ensure the product does not fall under 3209.
Top exporters and importers of HS 320890 (the code used for paints), 2025
In 2025, the largest exporter of HS 320890 (the code used for paints) in UN Comtrade data was Germany, with 13% of world exports; the largest importer in UN Comtrade data was China, with 12% of world imports. Countries that did not report 2025 data are estimated from partner records, which can understate them.
Figures cover everything classified under HS 320890, not only paints.
Top exporters 2025 · share of world exports
- 1 Germany $1.2B 13% of world exports
- 2 Japan $1.1B 11% of world exports
- 3 United States $877M 9.3% of world exports
World total: $9.4B Reported figures on UN Comtrade ↗
Top importers 2025 · share of world imports
- 1 China $1.1B 12% of world imports
- 2 Germany $445M 4.7% of world imports
- 3 United States $384M 4.1% of world imports
World total: $9.4B Reported figures on UN Comtrade ↗
How these figures are built
109 countries reported 2025 trade to UN Comtrade in HS 2022, and their own totals are used. Countries that did not report are estimated from what other countries recorded trading with them. Those estimates miss trade with other non-reporting countries, so they can be low, and a non-reporting country can rank higher than shown or be missing from the list. World totals add both and leave out trade between two non-reporting countries. Figures are in current US dollars; reported imports are mostly valued CIF and exports FOB, and exports include re-exports. The UN Comtrade links show the underlying records; they can also list a few reporters left out here (regional groups and older HS editions).
Source: UN Comtrade (United Nations Statistics Division), 2025 annual data.
Brazil NCM codes for paints
Brazil splits HS 3208.90 into 5 NCM codes. Pick the one that matches your product:
- 3208.90.10Other polymer paints, non-aqueous
- 3208.90.21Cellulose derivative varnishes, non-aqueous
- 3208.90.29Other polymer varnishes, non-aqueous
- 3208.90.31Silicone solutions per Chapter 32 Note 4
- 3208.90.39Other polymer solutions per Chapter 32 Note 4
Source: Siscomex NCM table, updated Oct 2026. The Portuguese text on each NCM page is the official one.
Questions about paints
What is the HS code for Paints?
The HS code for Paints is 320890 (Paints and varnishes; based on polymers n.e.c. in heading no. 3208, dispersed or dissolved in a non-aqueous medium). The HS code for solvent-based paints not using acrylic or vinyl polymers is 3208.90.
How do I classify Paints for customs?
Paints is classified under HS code 320890 — Paints and varnishes; based on polymers n.e.c. in heading no. 3208, dispersed or dissolved in a non-aqueous medium. This is a 6-digit subheading level code.
What is the difference between 3208 and 3209?
Heading 3208 covers paints with a non-aqueous (solvent) medium, while 3209 covers those with an aqueous (water) medium.
Which countries are the top exporters of paints (HS 320890)?
In 2025, the top exporters of HS 320890 (the code used for paints) in UN Comtrade data were Germany ($1.2B, 13% of world exports), Japan ($1.1B) and the United States ($877M). World exports came to about $9.4B, adding countries' reported figures and partner-based estimates for those that did not report (UN Comtrade data). Countries that did not report 2025 data are estimated from partner records, which can understate them.
Which countries are the top importers of paints (HS 320890)?
In 2025, the top importers of HS 320890 (the code used for paints) in UN Comtrade data were China ($1.1B, 12% of world imports), Germany ($445M) and the United States ($384M). World imports came to about $9.4B, adding countries' reported figures and partner-based estimates for those that did not report (UN Comtrade data). Countries that did not report 2025 data are estimated from partner records, which can understate them.
Is the HS code for Paints the same in all countries?
The base HS code 320890 for Paints is internationally standardized for the first 6 digits across 200+ countries. Individual countries may add additional digits for national tariff lines and specific classifications.
What is the NCM code for paints in Brazil?
Brazil splits HS 320890 into 5 NCM codes, so the right one for paints depends on the product's details: 3208.90.10 (Other polymer paints, non-aqueous), 3208.90.21 (Cellulose derivative varnishes, non-aqueous), 3208.90.29 (Other polymer varnishes, non-aqueous), 3208.90.31 (Silicone solutions per Chapter 32 Note 4), 3208.90.39 (Other polymer solutions per Chapter 32 Note 4).