Qualified Research

Can Structural Testing Qualify as R&D?

Structural testing may constitute qualified research when the testing evaluates alternative designs or materials to resolve a technical uncertainty about structural performance. Routine certification testing against known standards generally is not qualified research.

A common question from manufacturers is whether structural testing can qualify as research and development for the federal R&D tax credit under Section 41. The short answer is that structural testing may constitute qualified research when the testing evaluates alternative designs or materials to resolve a technical uncertainty about structural performance. Routine certification testing 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 Structural Testing May Warrant Review

Structural 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 (relying on engineering), be intended to eliminate uncertainty, and be conducted through a process of experimentation.

Common scenarios that may warrant review include:

  • New design structural performance — evaluating alternative designs to resolve uncertainty about whether a new structure can achieve the required strength or stiffness.
  • New material structural performance — testing alternative materials to resolve uncertainty about whether a new material can achieve the required structural performance.
  • Load-path development — evaluating alternative load-path approaches to resolve uncertainty about how loads are transferred through a structure.
  • Failure-mode investigation — testing alternative approaches to resolve uncertainty about why a structure failed and how to prevent it.

Routine Certification vs. Development Testing

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

  • Routine certification — testing a product to verify that it meets an established structural standard using a standard test method. This is certification, not research.
  • Development testing — testing alternative designs or materials to resolve a technical uncertainty about structural performance where the performance is not established at the outset. This may warrant review.

Hypothetical Example

Consider a manufacturer that is developing a new structural composite panel and is uncertain whether any available layup configuration can achieve the required strength-to-weight ratio. The company evaluates alternative layup configurations, tests each for structural performance, and systematically varies the design to resolve the uncertainty. This systematic evaluation of alternatives may warrant review as qualified research.

By contrast, if the same manufacturer tests a production panel to certify that it meets an established structural 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 structural testing claims include test plans identifying the uncertainty and alternative designs or materials, structural test results, and records of how results informed design changes. For more, see our page on R&D tax credit documentation.

Key Takeaway

Structural testing may constitute qualified research when the testing evaluates alternative designs or materials to resolve a technical uncertainty about structural performance. Routine certification testing 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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