Only the Client doesn't know it. If the Research Organisation can give a warranty, the project must have an exceedingly low risk element. Indeed, the whole project may be too trivial to bother with. A development project carries a much lower risk. Sometimes a warranty is appropriate.
Many companies sell development services.
Take, for example, the engineering and consulting firms based in Newmarket. The development project may involve electrical engineers, civil engineers or mechanical engineers. It is not unreasonable to ask an engineer to warrant his performance. So ask yourself. I will admit that sometimes the distinction between research and development can be quite fuzzy.