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Manufacturing · Recycled plastics

A polymer recycling manufacturer's R&D claim

How a UK recycled plastics manufacturer turned regulatory and supply chain problems into a documented SME scheme R&D claim for the year to 31 March 2024.

The client

A UK producer of recycled PET sheeting for the food packaging industry, with around 25 staff and a turnover of almost £10 million. The company qualified as an SME for the period ended 31 March 2024, and was an established name in its field with a clear ambition to be the leading producer of its kind.

The challenge

  • New food-contact regulations effective in July 2023 prohibited the standard layered structure the company used, so it needed a commercially viable new process and materials mix.
  • Optical anomalies in its sheeting were causing market resistance, even though the material met hygiene standards, and the exact causes were unknown.
  • An existing infrared dryer was designed only to dry flakes. Could it be repurposed to clean material well enough for anticipated tighter food-contact rules?
  • Material shortages introduced new contaminants, such as PVC and rubber, that had to be removed without significant capital expenditure.

What we did

  • Held detailed discussions with the company's competent professionals, challenging the level of detail until the narrative around each project would hold up to HMRC scrutiny.
  • Applied the cost rules carefully. Staff time was assessed fairly and conservatively, only consumed materials, software and packaging were claimed, and utilities were apportioned in line with the staff costs claimed.
  • Wrote a detailed technical report for each project, covering existing industry practice, the advance sought, the uncertainties and how they were resolved.
  • Summarised the figures per project, showed the client the expected tax saving, and submitted the claim with the additional information form after management approved the report.

The outcome

  • A claim of more than £600,000 of qualifying costs: around £175,000 of staff costs, around £400,000 of consumables and around £40,000 of utilities.
  • Four well-evidenced projects, with a technical report approved by the company's management.
  • A claim prepared under the SME scheme rules that applied to that period, with every cost backed by evidence.

What it shows

R&D is not limited to laboratories. Regulation and supply chain pressure can force a manufacturer to solve problems that nobody has solved before. What turns that work into a defensible claim is careful dialogue with the people who did it, conservative cost treatment and records that tie each cost to a project.

FAQs

Frequently asked questions

What did the polymer manufacturer's R&D projects involve?

Four projects, all driven by outside pressures. The company had to adapt its process to new food-contact regulations, find the causes of optical anomalies in its recycled sheeting, test whether an existing dryer could double as a cleaning device, and develop new processes to remove contaminants caused by material shortages, without major capital spend.

Why did new food-contact regulations create R&D?

Regulations effective in July 2023 prohibited the standard layered structure the company used, so it had to develop a commercially viable process and materials mix that still met the rules. Whether and how that could be done was not readily deducible from existing knowledge, which is what made the work uncertain rather than routine.

Can trial-and-error testing count as R&D?

Yes, where it is a systematic way of resolving genuine technological uncertainty. In this case the company ran challenge tests with a laboratory to establish the temperatures and minimum times needed, and used microscopic analysis and iterative trials. The key is records showing what was tried, what failed and what was learned.

How were the staff, consumables and utilities costs treated?

Staff time came from a fair and reasonable assessment by the technical leads, including qualifying indirect activities, taking a conservative approach where needed. Only materials, software and packaging consumed in resolving the uncertainties were claimed. Utilities were apportioned as a percentage of the employee costs claimed. Each cost head was tied back to the projects it supported.

How much qualifying expenditure did the claim include?

More than £600,000 of qualifying costs for the period: around £175,000 of staff costs, around £400,000 of consumables and around £40,000 of utilities. The company had about 25 staff and a turnover of almost £10m, so it qualified as an SME for the period ended 31 March 2024. The totals were arranged project by project.

Which scheme rules applied to this claim?

The period ended on 31 March 2024, and began before 1 April 2024, so the claim was made under the SME scheme rules that applied to that period. Periods beginning on or after 1 April 2024 fall under the merged scheme or ERIS instead. The same evidence principles apply under both.

Why did it matter that the company received no grants?

Under the SME scheme rules that applied to this period, subsidised expenditure was restricted. The company confirmed it had received no subsidies or grants for these projects, which kept the enhanced relief open. Checking subsidy status early is part of any claim, since it can change what is claimable. For periods beginning on or after 1 April 2024, this restriction no longer applies.

What did it mean that the company kept the IP and bore the risk?

It showed that the company itself decided the work needed doing, owned what resulted and carried the financial risk, which supports the claim being its own. The company worked with the machine manufacturer on the approval, but it kept the intellectual property specific to its machine and process. These points go to who the claimant is, and they are part of what we confirm.

Why was a conservative approach taken to the figures?

Because every cost in a claim has to be defended if HMRC asks. Erring on the cautious side avoids any risk of overclaiming and makes the submission more credible. The numbers were also arranged per project, so the technical report and the financial summary reinforced one another. It is the habit we bring to every claim.

What does this case show about preparing an R&D claim?

That regulation and supply chain problems can generate genuine R&D, and that detail wins claims. Repeated conversations with the competent professionals, a technical report that explained existing practice and the advance sought, and cost workings tied to evidence are what make a claim hold up if it is checked. Our approach is built around that.

Talk to an R&D tax specialist.

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Or write to taxadvisory@aswatax.co.uk

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