"Tariffs and Painting Services" Topic

I send figures to Sri Lanka or the UK to be painted. I have already purchased the figures and have paid the tariff tax. I am now paying for a service. Are such services subject to the tariff tax?

The answer will vary from day to day, as per Policy.

The short answer is not if you do it right though the "change in value" can be tariffed at a small percent. Consulting ChatGPT for 1) Do you have to pay the tariff, 2) how to set up your order to avoid it and what your painting services need to do to help, and 3) sources and 4) Sample letters

1) 1. Tariffs apply only to imported goods, not services

Tariffs are duties on physical goods crossing a border.

Services (like painting, assembling, or customizing) are not taxed directly under U.S. customs law — there's no tariff on labor done overseas.

So if you are just paying a Sri Lankan or UK painter for their service, that payment isn't subject to a tariff.

2. The problem is when the painted figures come back into the U.S.

Customs sees them as a new importation, even though you originally bought the figures in the U.S. and already paid duties.

Unless you can prove they are your own goods being returned after processing, they could be dutiable again.

3. The U.S. has a rule for this: HTSUS 9802.00

Under HTSUS subheading 9802.00.50 ("Articles exported for repairs or alterations and returned"), goods can re-enter with duty applied only on the value of the foreign processing, not the whole item.

Example:

You export $200 USD worth of unpainted minis.

Pay a painter in Sri Lanka $100 USD to paint them.

When they come back, U.S. Customs should only assess duty on the $100 USD painting service, not the $200 USD figures.

Requirements:

You need to show proof that you exported the goods from the U.S. (shipping docs).

The importer (you or a forwarder) must declare them under 9802.00 with documentation of the service fee.

4. Special note for the UK vs. Sri Lanka

UK/EU shipments (post-Brexit) → normally tariff-free on wargame figures (HS 9503/9504), so if declared correctly, you may owe little or nothing on re-entry beyond processing value.

Sri Lanka → same principle, but CBP may scrutinize more closely, so proper paperwork is crucial.

✅ Bottom Line

No, you don't pay a tariff on the service itself.

Yes, when the painted minis come back into the U.S., CBP can apply duty on the value added abroad (the painting fee), not on the original figures — if you declare under HTS 9802.

Without correct paperwork, Customs might mistakenly assess duty on the full value again, so documentation is critical.

2) Guide: Exporting Minis for Painting & Re-Importing
1. Before You Ship Them Out

Document ownership/value

Keep your purchase receipt or invoice showing you already bought and paid for the figures in the U.S.

Take photos of the unpainted minis (helps prove they're yours).

Decide export method

Use USPS, UPS, FedEx, or DHL with tracking.

On the customs form (export declaration), write:

"U.S.-origin goods temporarily exported for processing (painting). To be returned."

Use HS code 9503.00.00 (toys, models, miniatures) or 9504.90 (tabletop games) — whatever applies.

2. While They're Abroad

You'll pay the painter for their service fee (that's not taxable by U.S. Customs).

Ask the painter to prepare a service invoice stating:

Description: "Painting service for customer-supplied miniatures."

Value: the amount you paid (e.g. $100 USD).

Note: "Goods remain property of customer; no transfer of ownership."

3. When They Return to the U.S.

The minis are treated as a re-import after alteration.

Import declaration must reference HTSUS 9802.00.50.

You need:

Proof of export

Original shipping docs showing you sent the minis out.

Foreign service invoice

Showing only the painting fee.

Declaration statement

A simple cover note:

"These articles are of U.S. origin, exported for alteration (painting), and are returned without change in name, character, or use. Duty should apply only to the foreign processing cost under HTSUS 9802.00.50."

4. How Duty Is Calculated

CBP will assess duty only on the value added abroad (the painting fee).

Example:

$200 USD worth of minis exported.

$100 USD painting service in UK/Sri Lanka.

On return, CBP charges duty only on $100 USD (often 0–5% depending on classification).

5. Practical Tips

Use a customs broker if you're shipping large batches — they know 9802 filings well.

Mark clearly on return package:

"U.S. Goods Returned, Altered — Claiming HTS 9802.00.50."

Keep everything in one folder (export docs, invoices, photos, receipts). CBP may ask for proof.

✅ Summary

Service fees aren't taxed directly — only goods are.

With proper paperwork, CBP should only duty the painting fee, not the full value again.

The key is to declare under HTSUS 9802.00.50 and provide proof of export + service invoice.

3) Official Resources used for this explanation:
Here's the official U.S. Customs guidance backing up the process I described for sending figures abroad for painting and re-importing them duty-liable only on the value of the added service, not the entire figure set.

Legal Basis for Reduced Duty on Altered Goods (HTSUS 9802)
1. HTS Chapter 98 – Subheading 9802.00.50

This classification applies to "Articles exported for repairs or alterations and returned." When returned, they are duty-assessed only on the value of the repair or alteration, not on the full value of the item. The duty is the same rate that would apply to the whole article, but then prorated to just that value added abroad.
CustomsMobile
+3
CustomsMobile
+3
ICPA
+3
Legal Information Institute
+6
StarUSA
+6
Legal Information Institute
+6

2. Required Documentation (19 CFR §10.8)

U.S. Customs requires two declarations when reimporting such items:

From the overseas processor, confirming that only the stated alterations were done and that the item is the same as originally exported.

From the importer or agent, affirming the export details and that the returning item is indeed the same.
eCFR
Legal Information Institute

Additional supporting documentation like export records is required unless Customs waives it based on confidence in the evidence.
StarUSA
+10
eCFR
+10
CustomsMobile
+10

Practical Application to Your Specific Scenario

Scenario: You sent a set of wargaming figures from the U.S. to Sri Lanka or the UK to be painted. The product was originally your U.S.-purchased property, and you paid duties at that time.

Import Implication: When they return painted, they qualify under HTSUS 9802.00.50 as "altered goods." Duty applies only to the painting service cost, not the original figure value—if you file correctly with documentation.

Summary Reference Table
Step Requirement Source
Use HTSUS 9802.00.50 for entry Duty on value of alteration only
StarUSA
+3
ICPA
+3
Legal Information Institute
+3
StarUSA
+13
CustomsMobile
+13
CustomsMobile
+13
eCFR
+7
U.S. Customs and Border Protection
+7
Harmonized Tariff Schedule
+7

Submit processor's declaration Confirms alterations only occurred
eCFR
Legal Information Institute

Submit importer declaration Confirms export and return of same item
eCFR
Legal Information Institute

Support with export docs/invoices Proves original export and alteration value
eCFR

Chat generated some helpful forms, this is suggestion only not legal advice:

1. Exporter's Statement (You) – at Time of Export

U.S. Goods Export Declaration

I, [Your Full Name / Company], certify that the following articles are of U.S. origin and are being exported temporarily for alteration (painting). These articles remain my property and will be returned after processing.

Description of Goods: [# of Miniatures, material, scale, HS code 9503.00 or 9504.90]
Quantity: [#]
Original Purchase Value: [$XXX]

Purpose of Export: Temporary export for painting service only. No transfer of ownership.

Signature: ________________________
Name: [Your Name]
Date: [MM/DD/YYYY]

2. Foreign Processor's Declaration (Painter – UK/Sri Lanka) should do this

Foreign Processor's Declaration

I, [Painter's Full Name / Business], certify that the following articles were received from [Your Name / Company] for alteration (painting) only. No change was made to the essential character of the goods. The articles remain the property of [Your Name / Company] and are being returned upon completion of the service.

Description of Goods: [# of Miniatures, same as above]
Service Performed: Hand painting of miniatures
Service Fee: [$XXX]

Signature: ________________________
Name: [Painter's Name / Company]
Date: [MM/DD/YYYY]

3. Importer's Declaration (You) – at Time of Re-Import

Importer's Declaration for U.S. Goods Returned (HTSUS 9802.00.50)

I, [Your Full Name / Company], declare that the articles described below were originally exported from the United States, remain my property, and are now being returned after alteration (painting). No change has been made to the name, character, or intended use of the goods.

Description of Goods: [# of Miniatures, material, scale]
Original Value at Export: [$XXX]
Value of Alteration Abroad (Painting Fee): [$XXX]
Country Where Alteration Occurred: [UK / Sri Lanka]

I request duty be assessed only on the value of the alteration abroad under HTSUS 9802.00.50.

Signature: ________________________
Name: [Your Name]
Date: [MM/DD/YYYY]

4. Cover Letter to CBP (Attach to Return Shipment) From Painting Service

To: U.S. Customs and Border Protection
Port of Entry: [Insert Port]

Subject: U.S. Goods Returned – Claim for HTSUS 9802.00.50 Treatment

Dear Officer,

Enclosed are U.S.-origin miniature figures exported temporarily for painting and now returned. The goods qualify for entry under HTSUS 9802.00.50 (articles exported for alterations and returned). Duty should be assessed only on the value of the painting service performed abroad.

Supporting Documents Provided:
1. Exporter's Statement (proof of export from U.S.)
2. Foreign Processor's Declaration (painting service invoice)
3. Importer's Declaration
4. Photographs and/or invoices confirming original ownership

Thank you for your consideration.

Sincerely,
[Your Name / Company]
[Address]
[Phone / Email]

Yes, it will be subject to some form of tariff. Because the service in this case is the product. The painting being performed is the "product." And that painting service, namely the paint that is now on the minis., has to be shipped back to you.

Notwithstanding SBminisguy's endless, exhausting and desperate page-long explanations and paste and copy of shipping documents that attempts to justify Trump's authoritarian insanity.

Yes, painting services will be subject to tariffs. However you already paid for the minis. and paid tariffs on those the first time you bought them. Now it's just the service will be tariffed.

And apparently, SBminisguy thinks that that's great news somehow.

The number of countries that have suspended shipments to the U.S. is now over THIRTY, with more being added. That's thirty economies with millions of small businesses that can now not ship small packages to customers in the U.S. who previously were buying millions of different products from those companies. How much revenue is being lost? A lot.

Down below, SBminisguy posted this technical mini-novel which is supposed to somehow = Trump is doing an amazing job making the world great again.

I would like everyone to look at that tech. novel down below, and ask yourself a question.

I thought that Trump represented the party of SMALL GOVERNMENT. I thought traditionally that Conservativism was about keeping government out of people's lives as much as possible? I thought that the Right was all about the right to live our lives without the red tape and obstruction of government?

And yet, all this regime has done is bring government into our lives at every turn. Economically, medically, socially, government is now shoving itself through every door and window, and imposing its reckless will on us. And Trump openly says "well maybe people want a dictator!"

I use SBminisguy's post as an example not because I'm picking on him personally, but because he thinks that by posting a gigantic technical explanation about the massive disruptions that Trump is causing, will somehow justify it. Af if I'm going to go "OHHHHH, well since that's how it works, well now that changes my entire outlook on Trump, I was so wrong!!"

Get real. Showing me the new, pages long red tape of procedures that small businesses now have to go through to do something as simple as shipping out small packages during their business day.

And by the way SBminisguy, you DO understand that small businesses, like all businesses, need to be able to ship out packages QUICKLY and EFFICIENTLY in order to maintain a constant strem of revenue, as well as keeping pace with customer's amount of orders on any given day.

Suddenly throwing these page long procedures onto the desks of small businesses makes their business run slower. And less efficiently. Which means even if they do manage to navigate this mess that you cited – the businesses will lose money.

You let me know when the Greatness starts. :)
______________________________________________

SBMINISGUY wrote:

The short answer is not if you do it right though the "change in value" can be tariffed at a small percent. Consulting ChatGPT for 1) Do you have to pay the tariff, 2) how to set up your order to avoid it and what your painting services need to do to help, and 3) sources and 4) Sample letters

1) 1. Tariffs apply only to imported goods, not services

Tariffs are duties on physical goods crossing a border.

Services (like painting, assembling, or customizing) are not taxed directly under U.S. customs law — there's no tariff on labor done overseas.

So if you are just paying a Sri Lankan or UK painter for their service, that payment isn't subject to a tariff.

2. The problem is when the painted figures come back into the U.S.

Customs sees them as a new importation, even though you originally bought the figures in the U.S. and already paid duties.

Unless you can prove they are your own goods being returned after processing, they could be dutiable again.

3. The U.S. has a rule for this: HTSUS 9802.00

Under HTSUS subheading 9802.00.50 ("Articles exported for repairs or alterations and returned"), goods can re-enter with duty applied only on the value of the foreign processing, not the whole item.

Example:

You export $200 USD USD worth of unpainted minis.

Pay a painter in Sri Lanka $100 USD USD to paint them.

When they come back, U.S. Customs should only assess duty on the $100 USD USD painting service, not the $200 USD USD figures.

Requirements:

You need to show proof that you exported the goods from the U.S. (shipping docs).

The importer (you or a forwarder) must declare them under 9802.00 with documentation of the service fee.

4. Special note for the UK vs. Sri Lanka

UK/EU shipments (post-Brexit) → normally tariff-free on wargame figures (HS 9503/9504), so if declared correctly, you may owe little or nothing on re-entry beyond processing value.

Sri Lanka → same principle, but CBP may scrutinize more closely, so proper paperwork is crucial.

✅

Bottom Line

No, you don't pay a tariff on the service itself.

Yes, when the painted minis come back into the U.S., CBP can apply duty on the value added abroad (the painting fee), not on the original figures — if you declare under HTS 9802.

Without correct paperwork, Customs might mistakenly assess duty on the full value again, so documentation is critical.

Will the painting services be they Sri Lanka, UK or Ukraine handle the paperwork and presumably add the cost into the fee?

It is nothing short of hysterical that "the party of small government" has, in six months seen fit to bring government directly into our lives with regard to disrupting reproductive care, vaccine care, independent universities, private law firms, farms, replacement of local police with federal military, and now with the normal flow of shipping and commerce.

For a party and movement that brags about "loving small government and state's rights", you got a funny way of showing it.

YES I'm now convinced!! Your only hope is the secession of the NE states from the Union. Possibly Canada will take you in. Might even be willing to trade a few Western Provinces for you. Yes the Constitution is in Crises! Fascism arising on our home shores! Our liberties are in peril!! 😱😱😱😱

And DA#N IT!!, My toy soldiers from Europe might cost more!! The Sky is Falling.

Sung to the tune of: ("The Bible Tells me So")

And how do I know? The MSM tells me it's so.

I won't worry about tomorrow cause it's so dam# bad today.
The Lord won't bless and keep me, because the evil Trump is in his way.
We have no faith, hope and charity, With Trump that's the way it has to be.
How do I know? The MSM tells me it's so.

SECEDE! My brothers!! We've already tried notification in blue states and cities. To no avail!

+1 35OVI. Although exhaustive, I certainly didn't get the vibe from SBminisbuy that Baronovich did?

No I thought he was trying to be helpful. But never let that get in the way of a true TDS rant.

As that famous Civil War admiral said:

"Dam% the facts man! Full rant ahead!!"

🤔
Or something like that.
😉

Are you sure that tin miniatures are HS 9503 and not HS 8007 ?

Thank you.

Notwithstanding SBminisguy's endless, exhausting and desperate page-long explanations and paste and copy of shipping documents that attempts to justify Trump's authoritarian insanity….Down below, SBminisguy posted this technical mini-novel which is supposed to somehow = Trump is doing an amazing job making the world great again.

LOL, whatever -- man asked a question and rather than force him to wade through multiple websites I posted a complete NON POLITICAL FACTUAL answer here.

Besides, I used Fernando sometimes, be good to know how to classify things.

so, what if you send the mini's with a value of $1. USD Then you don't have to worry about whether they apply the tariff to the value of the minis plus the value of the painting service.

Are you sure that tin miniatures are HS 9503 and not HS 8007 ?

Yes, see complete answer.

HS 9503 → "Other toys; reduced-size (scale) models and similar recreational models, working or not; puzzles of all kinds."

This is the heading used worldwide for plastic, metal, or resin toy soldiers, wargaming miniatures, model kits, etc.

Subheadings:

9503.00.00 – "Tricycles, scooters, pedal cars and similar wheeled toys; dolls; other toys; scale models; puzzles."

HS 8007 → "Articles of tin."

This is a base metal classification, used for non-toy functional tin products (like tin containers, hardware, structural tin components).

It does not cover figurines or models — unless you're literally importing generic tin castings with no play/collectible/game function.

Even if wargame figures are cast in pewter or white metal (often tin-based alloys), Customs classifies them by their function/use (toy/model), not by their raw material.

so, what if you send the mini's with a value of $1. USD USD Then you don't have to worry about whether they apply the tariff to the value of the minis plus the value of the painting service.

I think right now that would get nailed by the current interim tariff regime which could be $80. USD The way my research indicates is that you claim these are not originally imported or exported minis, but already owned and being shipped strictly for a service (painting) and returned, so you only pay a small fee on the paint job service (which is essentially claimed as the change in value).

SBminisguy thank you for assisting those that have questions.

The money I save every month at the gas pump is more than the increased cost of hobby stuff.

so, what if you send the mini's with a value of $1.00 USD USD Then you don't have to worry about whether they apply the tariff to the value of the minis plus the value of the painting service.

Careful, Dan. If the parcel goes missing you can only claim $1.00 USD back for the loss (I've been told the rules about this are similar in most countries). I had 60+ 18mm SYW cavalry go missing on return from Fernando Enterprises. DHL was the carrier and because Fernando marked the value as "$30AUD", DHL only refunded that amount, less a "Handling" charge. Fernando, of course, took no responsibility.

So down valuing a package may cost you a lot more than any tariff, mate.

And right now it's a flat $80 USD fee until things are settled out, so claiming your minis are $1 USD won't help.

We have just sent our first shipment to USA. We have mentioned all details mentioned above to prove that is a re-export. I will come back to the forum when my customer receives the parcel.

According to the Royal Mail US customs require the taxable value of the goods to include the cost of shipping. This means that they think that services ARE taxable.

Another issue that doesn't seem to have been clarified properly.

A tariff is a duty on goods, not services, yet the moment paint is physically on a miniature, Customs treats it as a good again. Pretending this is all ‘just services' ignores that U.S. Customs explicitly includes the value of shipping and processing in the taxable base. That's not ideology, that's black-letter regulation.

And while one can admire the enthusiasm of writing a mini-novel of procedural detail, or making light of it with parody hymns, the reality for small shippers is neither comic nor optional. The rules exist, they apply every time, and glossing over the difference between theory and how CBP actually assesses value leaves people surprised when the bill arrives.

@fernandopainting Thanks, please let us know how that goes and what you find to be the best process (documents and so on)

Keep in mind that we can do all of the research to back up what we think we know, but it will likely differ from how the US government applies it. Just saying.