Qualified Research

Can Abrasion and Wear Testing Qualify as R&D?

Abrasion and wear testing may constitute qualified research when the testing evaluates alternative materials or coatings to resolve a technical uncertainty about wear performance. Routine wear certification against known standards generally is not qualified research.

A common question from manufacturers is whether abrasion and wear testing can qualify as research and development for the federal R&D tax credit under Section 41. The short answer is that abrasion and wear testing may constitute qualified research when the testing evaluates alternative materials or coatings to resolve a technical uncertainty about wear performance. Routine wear certification against known standards generally is not qualified research. This page explains the framework in general terms. It is educational and is not individualized advice. For the foundational framework, see our page on qualified research.

When Abrasion and Wear Testing May Warrant Review

Abrasion and wear testing may warrant review when the work involves a genuine technical uncertainty and a process of experimentation. Under the four-part test, the work must be for a permitted purpose, be technological in nature, be intended to eliminate uncertainty, and be conducted through a process of experimentation.

Common scenarios that may warrant review include:

  • New material wear performance — evaluating alternative materials to resolve uncertainty about whether a new material can achieve the required wear life.
  • New coating wear performance — testing alternative coatings to resolve uncertainty about whether a new coating can achieve the required wear performance.
  • Wear prediction — evaluating alternative approaches to resolve uncertainty about the wear life of a new design.
  • Wear mechanism — testing alternative approaches to resolve uncertainty about the wear mechanism in a new application.

Routine Certification vs. Development Testing

A central distinction is between routine wear certification and development testing:

  • Routine certification — testing a product to verify that it meets an established wear standard. This is certification, not research.
  • Development testing — testing alternative materials or coatings to resolve a technical uncertainty about wear performance where the performance is not established. This may warrant review.

Hypothetical Example

Consider a manufacturer that is developing a new bearing material for a high-load application and is uncertain whether any available material can achieve the required wear life. The company evaluates alternative materials, tests each for wear performance, and systematically varies the approach to resolve the uncertainty. This systematic evaluation of alternatives may warrant review as qualified research.

By contrast, if the same manufacturer tests a production bearing to certify that it meets an established wear standard, that is routine certification, not research.

This example is illustrative only and does not state that the activity definitely qualifies.

Documentation That May Help

Records that can help support abrasion and wear testing claims include test plans identifying the uncertainty and alternative materials or coatings, wear-test results, and records of how results informed material or coating changes. For more, see our page on R&D tax credit documentation.

Key Takeaway

Abrasion and wear testing may constitute qualified research when the testing evaluates alternative materials or coatings to resolve a technical uncertainty about wear performance. Routine wear certification against known standards generally is not qualified research. Because the distinction is fact-specific, professional review is appropriate before claiming the credit.

Sources

  1. Treasury Regulation §1.41-4

    Cornell Law Institute (LII)

    Defines the process of experimentation as an evaluative process of alternatives and the elimination-of-uncertainty requirement.

  2. Internal Revenue Code §41

    Cornell Law Institute (LII)

    Section 41(d) defines qualified research and the four-part test.

  3. Instructions for Form 6765

    Internal Revenue Service

    Identifies routine testing and inspection among activities generally not treated as qualified research.

  4. Research Credit

    Internal Revenue Service

    IRS landing page for the Credit for Increasing Research Activities.

By R&D Ledger Editorial Team

Last reviewed: August 2026

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