Qualified Research

Can Water-Resistance Testing Qualify as R&D?

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

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

Water-resistance 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 seal development — evaluating alternative seal designs to resolve uncertainty about whether a new product can achieve the required water resistance.
  • New material water performance — testing alternative materials to resolve uncertainty about whether a new material can resist water ingress.
  • Ingress protection — evaluating alternative approaches to resolve uncertainty about whether a product can achieve a new ingress-protection rating.
  • Water pressure — testing alternative designs to resolve uncertainty about whether a product can resist water at a new pressure level.

Routine Certification vs. Development Testing

A central distinction is between routine water-resistance certification and development testing:

  • Routine certification — testing a product to verify that it meets an established water-resistance standard (e.g., IP rating). This is certification, not research.
  • Development testing — testing alternative designs or materials to resolve a technical uncertainty about water performance where the performance is not established. This may warrant review.

Hypothetical Example

Consider a manufacturer that is developing a new electronic enclosure for an underwater application and is uncertain whether any available seal design can maintain the required water resistance at the target depth. The company evaluates alternative seal designs, tests each for water resistance, 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 enclosure to certify that it meets an established IP rating, 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 water-resistance testing claims include test plans identifying the uncertainty and alternative designs or materials, water-resistance test results, and records of how results informed design changes. For more, see our page on R&D tax credit documentation.

Key Takeaway

Water-resistance testing may constitute qualified research when the testing evaluates alternative designs or materials to resolve a technical uncertainty about water performance. Routine water-resistance 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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