Qualified Research

Can Window-System Development Qualify as R&D?

Window-system development may constitute qualified research when the work evaluates alternatives to resolve a technical uncertainty. Routine window manufacturing generally is not qualified research.

A common question from window manufacturers is whether window-system development can qualify as research and development for the federal R&D tax credit under Section 41. The short answer is that window-system development may constitute qualified research when the work evaluates alternatives to resolve a technical uncertainty about system performance. Routine window manufacturing 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 Window-System Development May Warrant Review

Window-system development 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 window system — evaluating alternative designs to resolve uncertainty about whether a new window system can achieve the required thermal performance.
  • New frame material — testing alternative frame materials to resolve uncertainty about whether a new material can achieve the required structural and thermal performance.
  • New glazing — evaluating alternative glazing approaches to resolve uncertainty about whether a new glazing system can achieve the required performance.
  • New seal system — testing alternative seal approaches to resolve uncertainty about whether a new seal can achieve the required weather resistance.

Routine Manufacturing vs. System Development

A central distinction is between routine window manufacturing and system development:

  • Routine manufacturing — manufacturing known window systems using established methods. There is no technical uncertainty. This is production, not research.
  • System development — developing new window systems where there is a technical uncertainty about whether the system can achieve the required performance. This may warrant review.

Hypothetical Example

Consider a manufacturer that is developing a new high-performance window system and is uncertain whether any available frame and glazing combination can achieve the required U-factor. The company evaluates alternative approaches, tests each for thermal performance, and systematically varies the approach to resolve the uncertainty. This may warrant review as qualified research.

By contrast, if the same manufacturer produces a standard window using an established process, that is routine production, 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 window-system development claims include system development records identifying the uncertainty and alternative approaches, thermal and structural test results, and records of how results informed design decisions. For more, see our page on R&D tax credit documentation.

Key Takeaway

Window-system development may constitute qualified research when the work evaluates alternatives to resolve a technical uncertainty about system performance. Routine window manufacturing 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

    Summarizes qualified research and excluded activities.

  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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