China Monthly Antitrust Update: August 2025

This monthly report outlines key developments in China’s antitrust sector for August. The following events merit special attention:

• SAMR Suspends Antitrust Investigation into DuPont China: In April 2025, SAMR publicly launched an antitrust investigation into DuPont China Holding Co., Ltd. over suspected violations of the AML. On July 22, SAMR announced the suspension of the investigation—marking the first time the authority has publicly disclosed the suspension of an ongoing antitrust probe.
• SAMR Concludes 339 Merger Review Cases in H1 2025, with 90% Handled Under Simplified Procedure: In the first half of 2025, SAMR concluded 339 merger review cases, including 296 cases handled under the simplified procedure, most of which were cleared during the initial review phase (within 30 days of acceptance).
• SAMR Prohibits Fourth Merger Since Implementation of the Anti-Monopoly Law: In July 2025, SAMR prohibited Wuhan Yongtong Pharmaceutical Co., Ltd. from acquiring a 50% equity stake in Shandong Beida GaoKe Huatai Pharmaceutical Co., Ltd. This marks the fourth prohibition decision on a concentration since the AML came into effect in 2008, and notably the first case involving a transaction below the filing thresholds that was blocked on the grounds of having or potentially having anti-competitive effects. The transaction was completed in 2019. SAMR identified potential competition concerns during its post-transaction monitoring, required a retroactive filing in January 2025, and issued a prohibition decision in July. The parties were ordered to unwind the transaction, including divesting the acquired shares and terminating an exclusive active pharmaceutical ingredient supply agreement.

Public Enforcement

In April 2025, the State Administration for Market Regulation (“SAMR”) publicly launched an antitrust investigation into DuPont China Holding Co., Ltd. over suspected violations of the Anti-Monopoly Law (“AML”). On July 22, SAMR announced the suspension of the investigation—marking the first time the authority has publicly disclosed the suspension of an ongoing antitrust probe.

SAMR Discloses Penalties for Horizontal Monopoly Agreement Among Telecom Operators

On July 18, SAMR released penalty decisions issued by the Zhejiang AMR against the local branches of China Telecom, China Mobile, and China Unicom in Zhuji City, along with two construction contractors. Each of the five companies was fined RMB 500,000 for entering into a horizontal monopoly agreement. The investigation found that between July and September 2020, the three telecom operators and the two contractors coordinated through meetings and unified documentation to fix prices for telecom infrastructure in residential developments, allocate geographic markets, and impose restrictive measures on uncooperative property developers—conduct that constituted both market division and price-fixing under the AML.

API Distributor Fined RMB 37.65 Million for Abuse of Market Dominance Through Exclusive Distribution

On July 18, SAMR published the penalty decision against Weifang Zhongyuan Pharmaceutical Co., Ltd. for abusing its dominant position in the market for magnesium trisilicate active pharmaceutical ingredients (APIs). From 2014 to September 2019, the company implemented exclusive distribution arrangements and engaged in conduct including unfairly high pricing, refusal to deal, and the imposition of unreasonable trading conditions—practices that excluded or restricted competition and harmed downstream manufacturers and patients. These actions violated Article 17 of the pre-amendment AML. In March 2025, the Shandong Provincial AMR imposed administrative penalties totaling over RMB 37.65 million, including confiscation of approximately RMB 15.89 million in illegal gains and a fine equivalent to 7% of the company’s 2018 sales revenue.

API Manufacturer and Three Distributors Fined for Obstructing Antitrust Investigation

On July 18, SAMR published penalty decisions against four pharmaceutical companies—Weifang Jinkaiseng Pharmaceutical, Shanghai Qingping Pharmaceutical, Chongqing Mingbo Pharmaceutical, and Weifang Longhaicheng Pharmaceutical—for refusing to cooperate with an antitrust investigation. The case was initiated by the Shandong Provincial AMR in July 2023 and concluded with administrative penalties in October 2024. All four companies had business dealings with Weifang Zhongyuan, the subject of a previously disclosed abuse of dominance case in the market for magnesium trisilicate APIs. Investigators found that the companies submitted false information, denied the existence of profit-sharing arrangements, and provided inconsistent statements during the investigation and hearings, thereby obstructing enforcement efforts. Each company was fined RMB 200,000 under the applicable provisions of the pre-amendment AML.

Seven Driving Schools in Chongqing Fined for Entering into Horizontal Monopoly Agreement

On July 17, SAMR published the penalty decision against seven driver training institutions in Tongliang District, Chongqing, for entering into and implementing a horizontal monopoly agreement. The investigation revealed that the seven entities were the only registered providers of small vehicle driver training in the district and were in direct competition with one another. Between March and May 2023, the companies coordinated to fix minimum prices for certain training modules (subject two and subject three), collected security deposits, and allocated portions of tuition fees through a pooled fund arrangement—constituting illegal conduct under China’s AML, including price-fixing and revenue allocation. In July 2025, the Chongqing AMR imposed a total fine of RMB 172,500 on the seven companies.

Heilongjiang AMR Fines Industry Association and 31 Vehicle Inspection Firms for Price-Fixing

On July 7, SAMR published an administrative penalty decision against the Daqing Motor Vehicle Inspection Industry Association and 31 affiliated inspection agencies for entering into and implementing a monopoly agreement. The association organized its members to fix and coordinate adjustments to the pricing of small vehicle inspection services. The agreement was implemented through WeChat groups used to coordinate pricing, the establishment of a monitoring and penalty mechanism, and the distribution of a support fund tied to inspection volumes. The Heilongjiang AMR imposed a fine of RMB 300,000 on the association.

SAMR Issues First Gun-Jumping Penalty Under New Discretionary Guidelines

On June 25, SAMR imposed an administrative fine of RMB 1.75 million on Guangzhou Construction Group Co., Ltd. for implementing a concentration without prior clearance. The company submitted a merger filing on December 20, 2023, for its acquisition of Guangdong Hongye Investment & Development Group Co., Ltd., but proceeded to complete the share transfer the very next day—constituting a clear case of "gun-jumping" in violation of Article 30 of the AML. This marks the first case enforced under the Interim Guidelines on Discretion in Administrative Penalties for Unnotified Concentrations. SAMR found that the transaction did not have the effect of eliminating or restricting competition and imposed a reduced fine after considering several mitigating factors, including the parties’ cooperation with the investigation, the establishment of an effective antitrust compliance program, and the fact that this was a first-time offense.

Authorities

On July 23, 2025, the First Antitrust Enforcement Division of SAMR, together with the Chongqing AMR, held the sixth session of the 2025 Antitrust Compliance Lecture Series in Chongqing. The seminar focused on the AML and its supporting regulations, with antitrust experts providing in-depth guidance on corporate compliance risk management. The event was attended by representatives from over 80 industry associations and various business entities in the region, with tailored recommendations offered on how associations can strengthen internal compliance frameworks.

Haikou Launches AI-Powered System for Fair Competition Review

In June 2025, the Haikou AMR launched an AI-driven platform to enhance the fair competition review of local policy measures. The system applies big data and artificial intelligence to automatically identify potentially anti-competitive clauses in draft and existing regulations, including local protectionism, designated transactions, and discriminatory subsidies. It supports policy reviewers by improving the efficiency and consistency of the review process. As of July 7, the system had been adopted by 37 municipal departments and used to review a cumulative total of 327 policy documents, generating 198 risk alerts. These led to 24 instances of policy revision and 102 referrals for third-party evaluation. Authorities plan to continue leveraging the system to identify and eliminate policy barriers to market unification and fair competition.

SAMR Holds Administrative Meeting with Food Delivery Platforms, Urges Fair Competition

On July 18, SAMR held an administrative meeting with three major food delivery platforms—Ele.me, Meituan, and JD.com—urging them to engage in rational competition and comply with applicable laws and regulations, including the E-Commerce Law, the Anti-Unfair Competition Law, and the Food Safety Law. SAMR emphasized the need for platforms to assume primary responsibility, standardize promotional practices, and foster a fair and transparent market environment. The authority called on the companies to support the sustainable and orderly development of the food service industry.

SAMR Holds Fair Competition Forum with Private Sector Representatives from Key Industries

On July 9, SAMR convened its fourth Fair Competition Forum of the year, bringing together representatives from eight major private companies—including Goldwind, Teld, Great Wall Motors, Du Xiaoman, Vipshop, NetEase, SF Express, and Neusoft—across the new energy, internet, logistics, and information technology sectors. The participants offered recommendations on enhancing fair competition governance. Deputy Commissioner Meng Yang addressed the forum, highlighting SAMR’s recent policy initiatives and enforcement efforts targeting practices that undermine fair competition for private enterprises. He emphasized SAMR’s commitment to strengthening competition review, intensifying antitrust enforcement, and improving merger review efficiency to foster a healthier and more open market environment for the private sector.

Merger Control

In the first half of 2025, SAMR concluded 339 merger review cases, with approximately 90% processed under the simplified procedure and cleared during the initial review phase (within 30 days of acceptance). By industry, manufacturing accounted for the largest number of transactions (115 cases), followed by sectors such as utilities (water, electricity, gas, and heat), finance, transportation, wholesale and retail, IT services, real estate, and leasing and business services. By transaction type, there were 181 horizontal mergers involving competitors, 138 vertical mergers involving upstream or downstream relationships, and 97 conglomerate (mixed) mergers.

SAMR Prohibits Fourth Merger Since Implementation of the Anti-Monopoly Law

On July 22, SAMR prohibited Wuhan Yongtong Pharmaceutical Co., Ltd. from acquiring a 50% equity stake in Shandong Beida GaoKe Huatai Pharmaceutical Co., Ltd. This marks the fourth prohibition decision on a concentration since the AML came into effect in 2008, and notably the first case involving a transaction below the filing thresholds that was blocked on the grounds of having or potentially having anti-competitive effects. The transaction, which involved papaverine hydrochloride injection—a drug of public health relevance—was completed in 2019. SAMR identified potential competition concerns during its post-transaction monitoring, required a retroactive filing in January 2025, and issued a prohibition decision in July. The parties were ordered to unwind the transaction, including divesting the acquired shares and terminating an exclusive active pharmaceutical ingredient supply agreement.

SAMR Conditionally Clears Synopsys’ Acquisition of Ansys in First Ex Officio Review of a Below-Threshold Transaction

On July 14, SAMR conditionally approved Synopsys’ acquisition of Ansys, marking the first case in which SAMR conducted an ex officio antitrust review and imposed remedies on a transaction that did not meet the mandatory filing thresholds. The transaction involves two major global suppliers in the markets for electronic design automation (EDA) software and semiconductor design IP. During its review, SAMR assessed the potential impact of the deal on competition in both global and Chinese markets. To address identified concerns, the authority imposed structural and behavioral remedies, including divestiture of overlapping businesses, ensuring product interoperability, maintaining service quality, and prohibiting bundling practices. The decision reflects SAMR’s active role in safeguarding fair competition in the EDA and design IP sectors both within China and globally.

Court Litigation

On July 14, 2025, the Central Committee of the Communist Party of China released the Opinion on Strengthening Judicial Work in the New Era, which calls for enhanced regulation of monopolistic conduct and unfair competition to safeguard market fairness. The Opinion also emphasizes the need to strengthen bankruptcy adjudication to improve market exit mechanisms and promote efficient resource allocation. In addition, it urges courts to handle disputes involving data ownership, market transactions, rights allocation, and benefit protection in accordance with the law, with the goal of facilitating the efficient circulation and trading of data as a production factor.