Research Tax Credit and Goat Cheese

For cheese lovers interested in learning more about the process of making goat cheese, the Lyon Administrative Court of Appeal has issued a ruling on the production process for these cheeses.

A company that produces raw-milk cheeses had requested a refund of its research tax credit.administration refused the refund, the company brought the matter before the courts, where a debate took place regarding the eligibility of the expenses for the research tax credit.

The expenses claimed by the company relatedto a project aimed at producing "fresh, lactic-type goat cheeses made from raw milk in portions no more than 1.5 centimeters high and no more than 3.5 centimeters in diameter, to be consumed as an appetizer, and the design of a suitable mold block enabling the mass production of cheeses of uniform size while facilitating their removal from the mold without physical damage and preserving the organoleptic qualities of traditional molding."

The Administrative Court will then review the various expert reports and will note, in particular, that:

  • "Pasteurized curds, unlike those made from raw milk, are characterized by a standardized inoculation of lactic acid bacteria and a physicochemical structure that facilitates homogenization; a process was therefore implemented to achieve a dry matter content of 18%, ensuring a cheese with a uniform texture"

  • "The presence of lactic acid bacteria in all raw or pasteurized cheese-making milk does not pose a barrier"

  • "The preliminary salting of the milk, which is essential for obtaining curds with a dry matter content of 18%, is by no means a novel process"

It also determines whether the production of a mold is eligible.

It therefore concluded that "the expenses related to the industrial production of fresh, lactic-type goat cheese made from raw milk in small portions using a specially designed mold were not allocated to research."

It therefore denies the company's request.

CAA Lyon, Feb. 19, 2026, No. 25LY01578

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