1. How to determine the HS code for paint exports?

According to the 2025 "Import and Export Tariff Schedule" issued by the General Administration of Customs, the classification of paint products requires special attention to three key elements:

• Main ingredient composition: The classification differences between oil-based paints (Chapters 3208-3210) and water-based paints (Chapters 3209-3211).
• Packing Specifications: Retail packaging (≤18kg) falls under tariff code 32.15, while industrial packaging is classified under tariff codes 32.08-32.11.
• Usage: For architectural paints and automotive paints, proof of intended use documents must be provided during declaration.

Taking the export of epoxy resin anticorrosive paint by a certain enterprise as an example, it is correctly classified under HS code 3209.10, 2025.Export tax refundThe rate remains unchanged at 13%. Misclassification may result in loss of tax refund or customs inspection risks.

II.Agency export,What is the tax rebate rate for paint?

According to the Ministry of Finance's 2025 "Announcement on Policies Related to Deepening the Value-Added Tax Reform":

• Oil-based paints: The tax rebate rate for solvent-based coatings is 9%, and products containing hazardous substances such as lead/mercury are not eligible for tax rebates.
• Water-based paint category: The tax rebate rate for environmentally friendly water-based coatings is 13%.
• Special function paint: The applicable tax refund rate for marine antifouling paint and aerospace coatings is 15%.

Please note the new additions in December 2024.VOC content limit standards, The tax refund ratio for oil-based paints with excessive volatile organic compound content will be reduced to 5% starting from July 2025.

III. Does the agency service fee affect tax calculation?

Under the agency export model, tax and fee calculations need to be differentiated across two dimensions:

• Basis for calculating the value of goods:
  • Customs declaration amount = factory tax-inclusive purchase price × (1 + reasonable profit margin)
  • The agency service fee is listed separately and is not included in the dutiable value.
• Key Points for Tax Refund Declaration:
  • Please provide the agency agreement and the cost allocation sheet.
  • The bank receipt voucher must match the amount on the customs declaration form and the agency contract.

IV. What documents are required for export agency?

Based on international trade practices, it is recommended to prepare the following materials:

• Basic files:
  • MSDS Chemical Safety Data Sheet (2025 Edition)
  • UN packaging certification (different versions applicable for sea/air transport)
• Tax documents:
  • VAT Special Invoice (the invoicing date shall not be earlier than the contract signing date)
  • Export goodsCustoms Declaration Form (Declaration elements must include paint film thickness and drying time).

V. How to Avoid Common Filing Errors?

According to customs audit cases from January to June 2025, the main risk points for paint exports include:

• Inaccurate ingredient declaration: A company declared anti-corrosion paint containing 15% zinc powder as ordinary paint, resulting in a loss of tax refund difference.
• Confusion in packaging specifications: The misdeclaration of a 20kg industrial paint package as an 18kg retail package has triggered a classification dispute.
• The test report has expired.: Use the 2024 environmental certification to declare exports for 2025.

It is recommended that enterprises conduct quarterly reconciliations.Classification of CustomsAdvance Ruling Decision, and conduct simulation declaration verification through the single window system.