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Manufacturing

Manufacturing is one of the biggest claiming sectors. Production runs are not R&D.

Manufacturing accounts for 27% of R&D claims on HMRC's provisional 2024-25 figures. The skill in a manufacturing claim is drawing the line between development and production, and backing the cost lines with records.

What qualifies

Development work on products, materials and processes.

New materials and formulations

Finding a mix, treatment or specification that works when it was not clear one could.

Process problems without a known answer

Hitting a tolerance, removing a contaminant or stabilising a process where established methods did not do it.

Making equipment do something it was not built to do

Adapting or controlling machinery in a way that required solving a technical problem.

Regulatory change that forces a technical solution

When new rules make an existing product or process unworkable and a compliant version has to be invented.

What usually does not

Production, repetition and routine fixes.

  • Producing more of an established product the same way.
  • Buying and commissioning standard machinery.
  • Routine quality control and compliance testing.
  • Cosmetic design changes and minor variations to existing products.
  • Production runs after the uncertainty has been resolved.
  • Bespoke orders built with known methods.

Costs and traps

Where manufacturing claims go wrong.

  • Consumables: materials, chemicals, fuel, power and water used up in R&D can qualify. Do not include production volumes.
  • Capital items: tooling, plant and prototypes that are kept as assets are capital expenditure, which R&D relief does not cover. A separate allowance may help.
  • Staff: claim only the time spent on R&D, with a sound method of apportioning it.
  • Contracted-out work: 65% of the payment where unconnected, and only for the company that decided the R&D needed doing.
  • Subsidies: no restriction for periods beginning on or after 1 April 2024. Earlier periods had grant-related rules.

See R&D capital allowances and qualifying costs.

What evidence helps

What we ask a manufacturer for.

  • Test plans, trial logs and measurement records.
  • Samples, photographs and reports from external laboratories.
  • Emails and notes where engineers discussed what was going wrong.
  • Purchase records for materials consumed in trials, separate from production stock.
  • A method for apportioning staff time between development and production.
  • The names of the technical leads who can explain each project.

Our record

A manufacturing claim, in detail.

One of our case studies is a UK producer of recycled PET sheeting for food packaging. Four projects, each driven by outside pressure, with cost workings tied back to each one.

  • 30+ R&D claims prepared each year.
  • No R&D claim we have prepared has been rejected or reduced after an HMRC enquiry.
  • Every claim reviewed and signed off by a Chartered Tax Adviser.

FAQs

Frequently asked questions

What manufacturing R&D qualifies?

Work to develop or improve a product, material or process where the outcome was uncertain and a competent professional could not readily have deduced the answer. That might be a new material mix, a process that has to hit a tolerance nobody has hit before, or a method of removing a contaminant. Making more of an existing product the same way is production, not R&D.

Does process improvement count?

It can, if the improvement is an appreciable one that required resolving technological uncertainty. The Government's guidelines include appreciable improvements in the definition of an advance. Tidying a workflow, buying a better machine and installing it as the supplier intended is not. The question is whether you had to work out something that was not known or readily available.

Can trial production runs be claimed?

Yes, where the run is part of the R&D, for example testing whether a new process holds at line speed. The cost of materials consumed and the staff time on the trial can qualify. A run that is just early production for sale does not. We look for a test plan, a measured result and a decision taken because of it.

Are prototype materials consumables?

Materials used up in R&D are consumables and can qualify, along with items such as fuel, chemicals, power and water. Whether the cost of a prototype as an asset can be claimed is a different question, because capital expenditure is excluded. We split the spend between items consumed in testing and anything that is kept as an asset.

When does R&D end and production begin?

The Government's guidelines deal with the start and end of R&D. In broad terms, R&D ends when the uncertainty has been resolved or work to resolve it stops. After that, runs are production. We set the end date with you using the project records, and costs after that date are not claimed under R&D.

Can scrapped batches be claimed?

If the batches were consumed in R&D testing, the materials in them can be consumables. A batch that fails during a trial of an uncertain process is evidence as well as a cost, because it shows the problem was real. Scrap from normal production, or from a process that is already proven, is not R&D.

Does new tooling qualify?

It depends on how the tooling is treated. Capital expenditure is not claimable under R&D tax relief, so tooling that is an asset is generally out. The staff time spent solving a real technical problem in designing it, and materials consumed testing it, can qualify. A separate relief for capital spending on R&D may help with the asset itself.

Can automation projects qualify?

Sometimes. Buying and installing a standard robot is not R&D. Getting a robot or control system to do something that has not been done, such as handling a variable material at speed, can be if the engineers faced real uncertainty. The records need to show what could not be predicted and how it was resolved.

Does adopting Industry 4.0 equipment count?

Adopting existing technology is not an advance, because the Government's guidelines say using technology is not an advance in itself. The work can qualify where you had to resolve uncertainty to make it function in your setting, for example because the data could not be captured by any known method. Installation, licences and training alone are not R&D.

Can we claim for tests at external laboratories?

Payments for contracted-out R&D can qualify if you decided the R&D needed doing and can evidence that decision. For an unconnected laboratory, 65% of the payment is the qualifying amount. For periods beginning on or after 1 April 2024, the work must be done in the UK or meet the overseas exception. Routine compliance testing is a different matter.

Are factory floor staff qualifying employees?

They can be, for the time they spend directly on R&D. Operators who run a trial under the engineers' direction, and technicians who make adjustments and record results, are doing R&D work during that time. The same people on normal production are not. We rely on records or a reasoned method to apportion time.

Does sustainable materials work qualify?

It can, if the work resolves technological uncertainty. A sustainability aim is not itself the test. Replacing a material with a recycled or bio-based one often raises real problems of performance and processing. Our recycled plastics case study is an example of regulation and material shortages forcing a manufacturer to solve new technical problems.

How do we evidence manufacturing uncertainty?

With test plans, trial logs, measurements, samples and photographs, internal reports and emails in which engineers discussed why something was not working. Where a laboratory ran tests, keep its reports. The aim is to show what you did not know, how you set about finding out and what you found, preferably in records made at the time.

Are certification tests R&D?

Testing a finished product to demonstrate that it meets a standard is usually routine. Work to find out whether a product can be made to meet a standard, where the answer was uncertain, may qualify. The line is between proving compliance and resolving a technical problem on the way to it. We look at what the testing was actually for.

Do customer-specific products qualify?

They can, but bespoke does not mean R&D. A one-off built using established methods is routine. A product that the customer needs and nobody knows how to make, which you set out to develop, may be R&D. If the customer pays for the development, check who decided the R&D needed doing before assuming you can claim.

Is your development work R&D, or production?

Tell us what you have been trying to make work. We reply the same working day.

Or write to taxadvisory@aswatax.co.uk

Last reviewed 11 October 2026
Chartered Tax Adviser
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