Qualified Research Expenses

Do Tooling Costs Count for the R&D Tax Credit?

Tooling costs may relate to the R&D tax credit when the tooling is experimental — used and consumed in qualified research — but dies, molds, fixtures, and jigs that are capital property generally are not supplies. The wages and contract research associated with developing tooling through a process of experimentation may warrant separate review.

A common question is whether tooling costs — dies, molds, fixtures, jigs, and test tooling — count for the federal R&D tax credit under Section 41. The short answer is that tooling costs require careful treatment rather than broad inclusion: tooling that is experimental and consumed in qualified research may warrant review as supplies, but tooling that is capital or depreciable property generally is not a supply. The wages and contract research associated with developing tooling through a process of experimentation may warrant separate review. This page explains the framework in general terms. It is educational and is not individualized advice. For the foundational supply rules, see our page on R&D tax credit supplies.

The Supply Framework and Depreciable Property

Under Section 41(b)(2)(C), "supplies" are tangible property other than (i) land and (ii) property subject to the allowance for depreciation. Dies, molds, fixtures, and jigs that have a useful life beyond the research period and are capitalized and depreciated generally are depreciable property, not supplies. Tooling that is consumed or used up in the conduct of qualified research — for example, a test fixture that is destroyed during testing — may fall within the supply category, provided the other requirements are met.

The distinction between a consumed supply and a capital asset is central to the tooling analysis. A die or mold that is used in production for years is generally depreciable property; a disposable test jig that is consumed during a specific series of experiments may be a supply. The specific facts control.

Experimental Tooling vs. Production Tooling

Experimental tooling — tooling designed and used specifically for a process of experimentation — may be distinct from production tooling. Tooling built to test alternative designs or processes, where the tooling itself is part of the evaluative process, may warrant review. Production tooling — tooling used in commercial manufacturing — generally falls outside the qualified-research framework, particularly after commercial production begins. For more on the commercial-production boundary, see our page on qualified research.

Wages Associated With Developing Tooling

Even where the tooling itself is capital property, the wages of employees who design and develop tooling through a process of experimentation may warrant review. If the tooling development constitutes qualified research — for example, designing a new type of mold where the capability or method is uncertain and the design is evaluated through testing — the wages of the engineers and technicians involved may be qualified research expenses, subject to the qualified-services rules. For more, see our page on employee wages, and for the activity of developing new tools, see our page on new tools and equipment development.

Contractor Costs for Tooling Development

Amounts paid to outside firms to develop tooling on behalf of the taxpayer may warrant review as contract research, subject to the contract-research rules — including the requirements that the research be performed on behalf of the taxpayer, that the taxpayer bear the economic risk, and that the taxpayer retain substantial rights to the results. The reduced inclusion percentage (65 percent) applies to contract research. For more, see our page on contractor costs.

Hypothetical Example

Consider a company that manufactures injection-molded parts and is developing a new molding process to achieve a tighter dimensional tolerance. The company is uncertain whether a modified mold design can maintain the tolerance across a range of polymer grades. The company designs and machines a test mold, runs trial shots with alternative polymers, and measures the results. The test mold itself — if it is a disposable fixture consumed in the testing — may warrant review as a supply. The wages of the engineers designing and testing the mold may warrant review as qualified research expenses. The cost of a production mold later used in commercial manufacturing, however, generally would be capital equipment, not a supply.

This example is illustrative only and does not state that the costs definitely qualify.

What Generally Does Not Fit

Several categories of tooling costs generally do not fit the supply category:

  • Production dies and molds — capital tooling used in commercial production is generally depreciable property.
  • Tooling used after commercial production — the post-commercial-production exclusion may apply.
  • Off-the-shelf tooling — purchased tooling that is not consumed in research and is capital in nature is generally not a supply.
  • General tooling overhead — tooling not connected to specific qualified research generally is not automatically includable.

Documentation That May Help

Records that can help support tooling-cost claims include design documents for experimental tooling, records showing whether the tooling was consumed or is capital property, records connecting tooling to specific qualified research projects, and wage records for personnel involved in tooling development. For more, see our page on R&D tax credit documentation.

Key Takeaway

Tooling costs may relate to the R&D tax credit when the tooling is experimental and consumed in qualified research, but tooling that is capital or depreciable property generally is not a supply. The wages and contract research associated with developing tooling through a process of experimentation may warrant separate review. Because these determinations are fact-specific and the line between a supply and capital property can be nuanced, professional review is appropriate before claiming the credit.

Sources

  1. Internal Revenue Code §41

    Cornell Law Institute (LII)

    Section 41(b)(2)(C) defines supplies as tangible property other than land and depreciable property; §41(b)(3) addresses contract research.

  2. Treasury Regulation §1.41-2

    Cornell Law Institute (LII)

    Regulatory rules for in-house research expenses, supplies, and contract research.

  3. Treasury Regulation §1.41-4

    Cornell Law Institute (LII)

    Defines qualified research, the four-part test, and the commercial-production exclusion.

  4. Instructions for Form 6765

    Internal Revenue Service

    Describes reporting of qualified research expenses, including supplies and contract research.

By R&D Ledger Editorial Team

Last reviewed: August 2026

Related educational pages

R&D Ledger

Organize your R&D documentation throughout the year.

Explore R&D Ledger