Taiwan Paint Import Agency: Full Chemical Customs Declaration Process and Risk Mitigation

Compliance Prerequisites and Core Processes of Taiwan Paint Import Agency

Importing paint from Taiwan to the Chinese mainland is essentially cross-border trade of chemical products,which requires two core prerequisites to be clarified first: product attribute determination and document system compliance.Whether the paint is classified as hazardous goods directly determines the subsequent declaration process.The 2026 edition of the Catalogue of Hazardous Chemicals has added multiple solvent-based paint items.If the paint contains flammable components such as benzene and esters,it shall be re-identified in accordance with Chinese regulations even if the Taiwanese manufacturer marks it as "non-hazardous".

Mr.Tu,a client,once had his imported Taiwan water-based paint directly detained by Waigang Port Customs for no attached Chinese version MSDS.We assisted him in supplementing the MSDS conforming to GB 30000.2-2013 (which must include GHS label elements such as the signal word for flammable liquids and flame symbol),and re-pasting warning labels in line with GB 20576-2006,before the cargo was released within 48 hours.

Dual-track Verification of MSDS and GHS Labels

• MSDS must include a Chinese version,and clearly mark three core contents: "hazard category","signal word" and "precautionary statement",to avoid using only English or traditional Chinese;
• GHS labels shall be pasted on the surface of paint packaging with "pictogram" (e.g.flame for flammability),"signal word" (e.g."Danger") and "precautionary statement" (e.g."Keep away from fire sources") at the same time,with a size no less than 50×50mm;
• If the paint is identified as non-hazardous,"non-hazardous chemical" shall be noted in the "remarks column" of the customs declaration form,with a Non-Hazardous Chemical Declaration (sealed by the Taiwanese manufacturer) attached.

Full Process Breakdown of Paint Import at Shanghai Port

As an agent with 20 years of experience at Shanghai Port,Zhongshitong has summarized the "three pre-reviews and two declarations" operation method: commodity inspection pre-review (submit sample composition analysis 3 working days in advance),valuation pre-review (submit the reference table of dutiable value of similar paints imported from Taiwan),license pre-review (confirm whether dual-use item control is involved),before carrying out formal declaration.

1.Commodity Inspection Pre-review: Component Classification and Quarantine Verification

If the paint contains heavy metals (such as lead,cadmium) or volatile organic compounds (VOC),the application for Import Paint Registration Certificate shall be completed in advance.The new requirement of "VOC content detection in paint" added in 2026 requires a test report issued by Shanghai Research Institute of Chemical Industry,with the test value ≤ 420g/L (in line with GB 18582-2020 standard).

A batch of Taiwan paint containing 10% benzene solvent was classified as "synthetic resin paint containing flammable solvents" (HS code 32099000.90).If it was incorrectly classified as "other paints" (32099090),the tariff rate would rise from 6.5% to 10.5%.We provided the component certificate issued by the Taiwanese manufacturer at the time of export,and finally achieved correct classification,saving the client CNY 80,000 in tariff costs.

2.Customs Valuation: Golden Balance of Price Declaration

Customs valuation refers to the "transaction value method for identical goods",that is,the dutiable value of similar paints imported from Taiwan in the same period.We recommend clients that: declared value = Taiwan FOB price + reasonable freight + insurance premium,and commercial invoices,packing lists and bill of lading copies from the Taiwanese manufacturer (marked with "FOB SHANGHAI" or "CIF SHANGHAI") shall be provided.

Note: If the declared value is more than 10% lower than the benchmark price of the customs system,price inquiry will be triggered,and a "price explanation letter" (stating reasonable reasons such as raw material price increase of Taiwan paint and process upgrading) shall be supplemented.

3.Import License: Verification of Dual-use Items and Chemical List

If the paint contains phosphorus flame retardants or specific heavy metals (e.g.lead content > 0.01%),the Environmental Management Registration Certificate for Chemical Import shall be applied to Shanghai Customs in advance.Zhongshitong can assist clients to submit applications online through the "Single Window",with an average approval cycle of 5 working days.

Risk Warning: Three "Death Traps" for Chemical Import

1.Misdeclaration of hazardous goods as general cargo: The Taiwan paint imported by Mr.Tu,a client,was judged as hazardous goods but declared as general cargo for no confirmation of flammable solvent content,resulting in 15 days of detention at Yangshan Port and demurrage of more than CNY 200,000.The problem was finally solved with our assistance in supplementing MSDS and hazardous goods identification report,which is a profound lesson.

2.Demurrage trap: The shipping schedule of the near-sea route from Taiwan to Shanghai is often delayed due to weather.If the client does not confirm the "demurrage starting point" in advance (e.g.demurrage starts to be charged if customs declaration is not completed within 5 days after the cargo arrives at the port),high costs are likely to be incurred.It is recommended to specify "the seller is responsible for delivery alongside the vessel" in the contract,and require the Taiwanese freight forwarder to provide a demurrage exemption letter issued by the ship owner.

3.Exchange loss risk: The fluctuation of RMB against New Taiwan Dollar reached ±3% in 2026.It is recommended that clients lock the exchange rate 3 working days before customs declaration (handle forward foreign exchange settlement and sale through cooperative banks of Zhongshitong) to avoid cost increase caused by exchange rate fluctuation.

Practical Case: 72-hour Turnaround from Port Detention to Customs Clearance

Situation: In March 2026,Mr.Tu imported 100 barrels of "environmentally friendly water-based paint" produced in Taiwan through a Taiwanese freight forwarder.The cargo owner misjudged it as non-hazardous and declared it as general cargo.After the cargo arrived at the port,it was found to contain 35% ethanol (flammable liquid) during customs inspection,and was detained for 3 days.

Task: The Zhongshitong team needs to complete hazardous goods identification,supplement declaration materials,and coordinate with customs for expedited release within 72 hours.

Action: ① Contact Shanghai Research Institute of Chemical Industry to issue the Hazardous Characteristic Classification and Identification Report on the same day; ② Simultaneously submit the "Import Hazardous Chemicals Enterprise Compliance Declaration" (sealed by Zhongshitong) to the customs; ③ Coordinate with the inspection department of Yangshan Port Customs to arrange priority inspection to ensure that GHS labels are consistent with the declaration content.

Result: All processes were completed within 72 hours,the cargo was released smoothly without additional demurrage,and Mr.Tu highly recognized our "7×24 hour emergency response" service.

Conclusion: Core Value of Taiwan Paint Import Agency

Relying on 20 years of chemical agency experience at Shanghai Port,Zhongshitong can quickly solve pain points such as "inconsistent MSDS","hazardous goods misjudgment" and "valuation disputes".If you are planning to import paint from Taiwan,it is recommended to contact us 3 working days in advance,and we will provide a free Paint Import Compliance Self-check List to avoid legal risks and hidden costs.