Product classification
HS code for Polymer paint: 3209.90
Paints and varnishes, (based on polymers other than acrylic or vinyl), dispersed or dissolved in an aqueous medium.
Classification of polymer paint under HS 3209.90
Polymer paint is classified under HS code 3209.90 when it consists of paints and varnishes based on synthetic polymers or chemically modified natural polymers, dispersed or dissolved in an aqueous (water-based) medium. Heading 3209 specifically covers water-based coatings. The subheading 3209.90 is a residual category for paints based on polymers other than acrylic or vinyl polymers (which are covered under 3209.10). This classification is determined by two primary factors: the solvent/medium (water) and the type of polymer binder used. If the paint uses a binder such as a polyurethane, epoxy resin, or alkyd resin, but is dispersed in water, it falls here. The classification process involves analyzing the chemical composition of the binder and the nature of the volatile medium. According to the Explanatory Notes to Chapter 32, these products include emulsions or dispersions where the polymer is the film-forming agent. The distinction between water-based and solvent-based is critical, as solvent-based paints fall under heading 3208.
- Covers
- Water-based epoxy paints
- Aqueous polyurethane varnishes
- Water-dispersed alkyd coatings
- Polymer-based emulsion paints (non-acrylic)
- Water-borne industrial coatings
- Also under 3209.90
- Rust-Oleum Water-Based Epoxy
- AkzoNobel Sikkens Autowave
- PPG Envirobase High Performance
- Sherwin-Williams ProMar 400 Zero VOC
Codes often confused with 3209.90
Common mistake. The most common misclassification is with 3209.10, which is specifically for acrylic or vinyl polymer-based paints. Many users assume all water-based "latex" paints are 3209.10, but if the binder is a different polymer, 3209.90 is required. Another error is 3208.90, which covers similar polymer paints but dissolved in non-aqueous (solvent) media. If the water content is less than 50% of the solvent weight, it might be considered solvent-based. Additionally, 3210.00 is sometimes used for "other" paints, but 3209 is more specific for water-based polymer systems. Proper identification of the solvent is the first step in avoiding these errors.
Top exporters and importers of HS 320990 (the code used for polymer paint), 2025
In 2025, the largest exporter of HS 320990 (the code used for polymer paint) in UN Comtrade data was Germany, with 17% of world exports; the largest importer in UN Comtrade data was the United States, with 8.4% 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 320990, not only polymer paint.
Top exporters 2025 · share of world exports
- 1 Germany $573M 17% of world exports
- 2 United States $331M 9.9% of world exports
- 3 France $257M 7.7% of world exports
World total: $3.4B Reported figures on UN Comtrade ↗
Top importers 2025 · share of world imports
- 1 United States $285M 8.4% of world imports
- 2 Germany $215M 6.3% of world imports
- 3 China $173M 5.1% of world imports
World total: $3.4B 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 polymer paint
Brazil splits HS 3209.90 into 3 NCM codes. Pick the one that matches your product:
- 3209.90.11Water-based polytetrafluoroethylene paints
- 3209.90.19Other water-based polymer paints
- 3209.90.20Other water-based polymer varnishes
Source: Siscomex NCM table, updated Oct 2026. The Portuguese text on each NCM page is the official one.
Questions about polymer paint
What is the HS code for Polymer paint?
The HS code for Polymer paint is 320990 (Paints and varnishes; (based on polymers other than acrylic or vinyl), dispersed or dissolved in an aqueous medium). The HS code for water-based polymer paint (other than acrylic or vinyl) is 3209.90.
How do I classify Polymer paint for customs?
Polymer paint is classified under HS code 320990 — Paints and varnishes; (based on polymers other than acrylic or vinyl), dispersed or dissolved in an aqueous medium. This is a 6-digit subheading level code.
What defines an aqueous medium in paint classification?
An aqueous medium is one where water is the primary volatile component, typically making up more than 50% of the solvent weight in the liquid phase.
Which countries are the top exporters of polymer paint (HS 320990)?
In 2025, the top exporters of HS 320990 (the code used for polymer paint) in UN Comtrade data were Germany ($573M, 17% of world exports), the United States ($331M) and France ($257M). World exports came to about $3.4B, 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 polymer paint (HS 320990)?
In 2025, the top importers of HS 320990 (the code used for polymer paint) in UN Comtrade data were the United States ($285M, 8.4% of world imports), Germany ($215M) and China ($173M). World imports came to about $3.4B, 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 Polymer paint the same in all countries?
The base HS code 320990 for Polymer paint 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 polymer paint in Brazil?
Brazil splits HS 320990 into 3 NCM codes, so the right one for polymer paint depends on the product's details: 3209.90.11 (Water-based polytetrafluoroethylene paints), 3209.90.19 (Other water-based polymer paints), 3209.90.20 (Other water-based polymer varnishes).