Eligible consumables spending in ELIDEK, ESPA and Horizon projects
What an invoice for laboratory consumables must show, and what file the verifier asks for, so that the cost passes the eligibility check of a funded project.
What must an invoice for research materials show to pass the eligibility check of a funded project?
An invoice for laboratory consumables passes an eligibility check when it can prove four things: the cost arose within the project period, it was needed for the project, it was paid by the beneficiary institution, and it was recorded in that institution's accounts. The three funders a Greek research body meets, ELIDEK, ESPA 2021-2027 and Horizon Europe, phrase these conditions differently, but the verifier looks for the same file.
Most problems do not come from the product. They come from an invoice issued in the wrong name, a payment that cannot be tied to the document, or an order placed in the last week before the project ends. This article sets out the common principles and the file that evidences them. It does not replace the call or guide of the specific project, which always prevail.

The principles common to the three funders
For ESPA 2021-2027 the frame is Regulation 2021/1060, which contains an article titled «Eligibility» (Article 63), one on «Non-eligible costs» (Article 64), and provisions on the availability of documents (Article 82) [2]. The detail, such as which cost categories apply and with which supporting documents, is set by national rules and by the managing authority's call. The exact wording of the articles should be read in the text in force.
In Horizon Europe the grant agreement sets general eligibility conditions for costs: actual costs, incurred during the action, included in the budget, recorded in the beneficiary's accounts, connected with the action, and identifiable and verifiable. The model text with commentary (the Annotated Model Grant Agreement) is published on the Funding & Tenders portal and is the document to read before any doubt [4]. The programme itself is established by Regulation 2021/695 [3].
At ELIDEK the terms are written in each call and in the template documents that accompany it, such as the management and financial-monitoring guide [1]. There is no value in paraphrasing them from memory: calls differ by programme and by year, and the current version sits on the funder's website.
| Condition | What it means for a consumable | What evidences it |
|---|---|---|
| Time window | The cost was incurred and paid within the project period | Date of invoice, delivery and payment |
| Necessity | The material is used in a project activity | Link to a work package, laboratory note or assignment memo |
| Beneficiary | The paying institution is the project beneficiary | Tax number and name on the invoice, payment from the institution's account |
| Recording | The cost appears in the institution's accounts | Ledger entry or project-specific register |
| Documentation | There is a complete trail from order to payment | Expenditure file with every document |
What the invoice must show
The first thing checked is the addressee. The invoice must carry the name and tax number (ΑΦΜ) of the institution that is the project beneficiary. If the implementing body is a university's special research-funds account rather than the university itself, the addressee must be the one named in the funding agreement. An invoice in a researcher's name, or in a laboratory's name with no tax number, does not tie into the institution's books.
The second is the description. A line reading «assorted laboratory items» or a bare code with no name does not let the verifier judge necessity. Ask the supplier for a description with name, quantity, unit and, where one exists, catalogue number and lot. The article on what an invoice must state and on intra-EU acquisition covers the mandatory fields; what matters here is the extra: whatever makes the document recognisable as part of the project.
The third is the project reference. Many calls ask for the project code or title and the funding reference to appear on the document or on an accompanying note. Where that is required, it is written before issue: correcting an invoice afterwards is difficult, and the verifier may not accept it. Check the call before placing the order, not after delivery.
- Name and tax number of the beneficiary institution as addressee.
- Issue date inside the project period.
- Item description with name, quantity and unit.
- Net amount, VAT and total, with the VAT shown separately.
- Project reference, if the call requires one.
- Order or procurement contract number, tying the document to the award.
Proof of payment and its link to the document
An eligible cost is one that has been paid, not merely invoiced. Proof of payment is usually the bank-account statement line or the transfer order stamped by the bank. It must show the payee, the amount, the date and, preferably, the invoice number in the payment reference.
Where one payment covers several invoices, or one invoice is paid in instalments, the verifier needs the amounts to reconcile. Build a matching table: invoice, amount, payment. That table is the document that saves hours of questions.
The time window and orders near the end
The cost must belong to the project period in the way the funder defines it: for ESPA the regulation speaks of expenditure incurred and paid by the beneficiary within a defined eligibility period [2], while in Horizon the cost must arise during the action [4]. In practice the point needing care is whether the date that counts is that of the invoice, the delivery or the payment. The call answers this, and the answers are not the same across programmes.
An order placed in the final days of a project raises two questions: when was the material delivered, and was there time to use it. Consumables bought to cover needs after the project ends, in effect stock, risk being treated as a cost that does not relate to the period. If the purchase is justified, keep a written reason and the work plan that shows the use.
Consumables versus equipment
The distinction is not cosmetic, because each category has its own budget line and often its own limit or recognition method. Equipment is usually the durable asset that lasts and is depreciated; a consumable is what is used up or worn out in use: pipette tips, filters, vials, reagents, single-use columns. The boundary between the two is set by the institution and the call, not by the supplier's commercial description.
If an item sits on the border, for example a chromatography column with a long service life or a small handheld instrument, decide the category before purchase and record it. Changing the category at verification stage usually means a budget amendment and a delay in payment.
Purchases from abroad and VAT in the project
When the supplier is in another member state, the document is normally an invoice without Greek VAT, and the institution declares the intra-EU acquisition. The VAT that appears in the declaration is not automatically eligible: the standard position is that VAT the beneficiary recovers or offsets is not funded. The call states whether and when VAT is eligible [2][4].
A purchase from a third country adds customs documents, duty and clearance charges. The file should include the supplier's invoice, the customs document and the carrier's or broker's invoices. Transport and clearance costs fall in a cost category the call defines; check whether they are allowed separately or only as part of the material's value.
The expenditure file the verifier asks for
The expenditure file is the chain of documents from the need to the payment. To be checkable years later it must be kept for the period the funder sets: ESPA has express provisions on the availability of documents [2], and Horizon agreements provide for checks after the action ends [4]. The specific retention period is written in the funding agreement and must not be guessed.
- A need or assignment note, tied to the work package or activity.
- Quotations or price comparison, where the institution's procurement rules require them.
- The order or procurement contract.
- Delivery note and goods-received record with a date.
- The invoice.
- Proof of payment and the matching table to the invoice.
- The ledger entry or project register entry.
- For lot-tracked materials: a record tying the lot to its use in the project.
What to check before each order
Before placing any order in a funded project, read the call in force and answer four questions: who is the addressee of the invoice, which date counts, what must the document state, and which budget line does the item go into. If the call does not answer, ask the project management unit in writing and keep the reply in the file.
References
- Ελληνικό Ίδρυμα Έρευνας και Καινοτομίας (ΕΛ.ΙΔ.Ε.Κ.) – προσκλήσεις και πρότυπα έγγραφαΕΛ.ΙΔ.Ε.Κ., 2026
- Κανονισμός (ΕΕ) 2021/1060 – Κοινές διατάξεις για τα ταμεία (ΕΣΠΑ 2021-2027)EUR-Lex, 2021
- Κανονισμός (ΕΕ) 2021/695 για τη θέσπιση του προγράμματος Ορίζων ΕυρώπηEUR-Lex, 2021
- EU Funding & Tenders Portal – Reference documents (Annotated Model Grant Agreement)European Commission, 2026
