Product classification
HS code for Varnishes: 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 varnishes under HS 3208.90
Varnishes based on polymers dispersed or dissolved in a non-aqueous medium are classified under HS code 3208.90. This code is part of Chapter 32, which encompasses tanning or dyeing extracts, tannins, and their derivatives, as well as paints and varnishes. Heading 3208 specifically addresses paints and varnishes where the medium is non-aqueous (solvent-based). The subheading 3208.90 is a residual category for products that do not fall under the more specific subheadings for polyester, acrylic, or vinyl polymers. Classification depends on the chemical nature of the binder and the type of solvent used, ensuring that solvent-borne protective coatings are distinguished from water-borne alternatives. To qualify for this code, the weight of the solvent must often exceed 50% of the weight of the solution, or the product must be clearly identified as a solvent-based coating. These products are used extensively in wood finishing, automotive topcoats, and industrial metal protection where a durable, non-aqueous film is required.
- Covers
- Solvent-based clear varnishes
- Polyurethane coatings (non-aqueous)
- Epoxy resin varnishes
- Alkyd resin enamels
- Cellulose lacquers
- Marine varnishes
- 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. The most common misclassification occurs with HS code 3209.10 or 3209.90, which are reserved for paints and varnishes based on polymers in an aqueous (water-based) medium. Another error involves HS code 3210.00, which covers other paints and varnishes not based on synthetic polymers, such as those based on natural resins or oil-based paints without synthetic polymer modification.
Top exporters and importers of HS 320890 (the code used for varnishes), 2025
In 2025, the largest exporter of HS 320890 (the code used for varnishes) 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 varnishes.
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 varnishes
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 varnishes
What is the HS code for Varnishes?
The HS code for Varnishes is 320890 (Paints and varnishes; based on polymers n.e.c. in heading no. 3208, dispersed or dissolved in a non-aqueous medium). Varnishes based on synthetic polymers in a non-aqueous medium are classified under HS code 3208.90.
How do I classify Varnishes for customs?
Varnishes 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.
How do I distinguish between HS 3208 and HS 3209?
The distinction is based on the solvent; 3208 is for solvent-based (non-aqueous) products, while 3209 is for water-based (aqueous) products.
Which countries are the top exporters of varnishes (HS 320890)?
In 2025, the top exporters of HS 320890 (the code used for varnishes) 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 varnishes (HS 320890)?
In 2025, the top importers of HS 320890 (the code used for varnishes) 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 Varnishes the same in all countries?
The base HS code 320890 for Varnishes 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 varnishes in Brazil?
Brazil splits HS 320890 into 5 NCM codes, so the right one for varnishes 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).