Product classification
HS code for Water-based paint: 3209.90
Paints and varnishes, (based on polymers other than acrylic or vinyl), dispersed or dissolved in an aqueous medium.
Classification of water-based paint under HS 3209.90
Water-based paints based on polymers other than acrylic or vinyl are classified under HS code 3209.90. Chapter 32 covers tanning or dyeing extracts, tannins, and their derivatives, as well as paints and varnishes. Heading 3209 specifically targets those dispersed or dissolved in an aqueous (water) medium. The distinction for 3209.90 is the chemical composition of the binder; it must be a polymer other than acrylic or vinyl polymers. This includes polyurethane, epoxy, or alkyd resins that have been modified for water solubility or dispersion. The classification logic is based on the medium (water) and the specific chemical nature of the film-forming substance. This code is essential for environmental regulation compliance, as water-based coatings generally have lower Volatile Organic Compound (VOC) levels than solvent-based alternatives.
- Covers
- Water-borne polyurethane floor finishes
- Water-based epoxy coatings for industrial use
- Aqueous dispersions of alkyd resins
- Water-based anti-corrosive paints (non-acrylic)
- Water-soluble varnishes based on polyesters
- 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 frequent misclassification is with HS code 3209.10, which is reserved for water-based paints specifically based on acrylic or vinyl polymers. Importers must check the Material Safety Data Sheet (MSDS) to confirm the polymer type. Another common error is classifying these under heading 3208, which is for paints dissolved in a non-aqueous (solvent) medium. If the primary liquid carrier is water, it must fall under 3209.
Top exporters and importers of HS 320990 (the code used for water-based paint), 2025
In 2025, the largest exporter of HS 320990 (the code used for water-based 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 water-based 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 water-based 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 water-based paint
What is the HS code for Water-based paint?
The HS code for Water-based paint is 320990 (Paints and varnishes; (based on polymers other than acrylic or vinyl), dispersed or dissolved in an aqueous medium).
How do I classify Water-based paint for customs?
Water-based 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 is the HS code for non-acrylic water-based paint?
The HS code for water-based paints based on polymers other than acrylic or vinyl is 3209.90.
How do I distinguish between 3208 and 3209?
Heading 3208 is for solvent-based paints (organic solvents), while heading 3209 is for water-based (aqueous) paints and varnishes.
Which countries are the top exporters of water-based paint (HS 320990)?
In 2025, the top exporters of HS 320990 (the code used for water-based 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 water-based paint (HS 320990)?
In 2025, the top importers of HS 320990 (the code used for water-based 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 Water-based paint the same in all countries?
The base HS code 320990 for Water-based 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 water-based paint in Brazil?
Brazil splits HS 320990 into 3 NCM codes, so the right one for water-based 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).