China Monthly Antitrust Update: July 2025

[co-author: Ken Dai]

Developments Highlights

Legislation

On June 27, 2025, the Standing Committee of the 14^th National People’s Congress voted to adopt the newly revised Anti-Unfair Competition Law, which will take effect on October 15, 2025. The amended law addresses emerging unfair competition issues in the digital economy, with a particular focus on addressing rat race competition among platforms. It strengthens platform operators’ governance responsibilities and refines the legal standards for commercial bribery, online false advertising, and acts of passing off. The revision marks a significant step toward fostering a fairer, more transparent, and orderly market environment.¹

SAMR Releases Draft Guidelines on the Review of Non-Horizontal Mergers for Public Comment

On June 27, the State Administration for Market Regulation (“SAMR”) released the Draft Guidelines on the Review of Non-Horizontal Mergers for public consultation. The draft guidelines aim to enhance the transparency of merger review procedures and provide businesses with clearer framework for conducting competitive self-assessments in advance of non-horizontal transactions.²

SAMR Solicits Public Comments on the Revised Provisions on the Prohibition of Monopoly Agreements, Refining the “Safe Harbor” Rules for Vertical Restraints

On June 3, to implement the requirements set out in Article 18, Paragraph 3 of the Anti-Monopoly Law (“AML”), SAMR released the draft revision of the Provisions on the Prohibition of Monopoly Agreements for public consultation. The draft establishes specific standards and conditions for applying the “safe harbor” mechanism to monopoly agreements. In particular, it refines the safe harbor framework for vertical restraints by adopting differentiated criteria based on both market share and turnover, depending on the type of agreement. The draft further clarifies applicable exemptions, burden of proof, documentation requirements, review procedures, and legal consequences.³

Authorities

On June 27, 2025, as part of the broader campaign to address rat race competition, the SAMR released five representative cases of online unfair competition. The cases involve misconduct such as unauthorized scraping of commercial data, abuse of platform return policies, operation of fake order platforms, misleading use of software names, and the creation of deceptive livestream scenarios to mislead consumers—practices that disrupt fair market competition.⁴

SAMR Launches Online Database for Unconditionally Approved and Simplified Merger Cases

On June 23, SAMR added two new query features to its online antitrust filing system for merger control. Enterprises can now search the “List of Unconditionally Approved Cases” and the “Simplified Case Disclosure Table,” providing a convenient reference for merger filings. Currently, the system covers 6,461 unconditionally approved cases since the implementation of the AML and 1,828 simplified case disclosures since the launch of the online system.⁵

Beijing AMR Conducts Antitrust Compliance Training for Financial Leasing and Commercial Factoring Industries

On June 16, the Beijing Administration for Market Regulation (“AMR”), in collaboration with the Beijing Local Financial Supervision and Administration, organized a series of antitrust compliance training sessions for over 130 financial leasing and commercial factoring enterprises, aiming to promote fair competition and mitigate systemic financial risks.⁶

SAMR Releases the Annual Report on China’s Anti-Monopoly Enforcement (2024)

On June 6, SAMR released the Annual Report on China’s Anti-Monopoly Enforcement (2024), summarizing key achievements over the past year in antitrust enforcement, legal framework development, and policy implementation. In 2024, SAMR concluded 11 cases involving monopoly agreements and abuse of dominance, imposed penalties in one case for obstruction of investigation, and reviewed 643 merger filings. It also investigated 72 cases involving abuse of administrative power to restrict competition.⁷

SAMR and Zhejiang AMR Jointly Conduct Antitrust Compliance Guidance for Public Utility Operators and Industry Associations in Zhejiang

On June 4, SAMR, together with the Zhejiang AMR, conducted antitrust compliance guidance sessions for operators and industry associations in the public utility sector, with a focus on water supply, electricity, gas, heating, and telecommunications. The initiative aims to encourage relevant entities to identify potential antitrust risks in their daily operations and to strengthen internal compliance mechanisms on a systematic basis.⁸

Merger Control

On June 30, 2025, SAMR conditionally approved ANA Holdings Inc. (“ANA”)’s acquisition of equity in Nippon Cargo Airlines (“NCA”). The transaction involves the market for international air cargo services on China–Japan routes, where the parties have a relatively high combined market share. The deal would further increase market concentration and significantly strengthen the merged entity’s capacity at key cargo hubs, particularly Tokyo Narita International Airport, in a context of limited access and high barriers to entry. To address potential anticompetitive effects, ANA committed to continuing existing ground service agreements, providing services to new market entrants, and transferring certain flight slots.⁹

SAMR Conditionally Approves Bunge’s Acquisition of Viterra’s Equity

On June 16, the SAMR conditionally approved Bunge Global Limited’s acquisition of equity in Viterra Limited. The transaction involves a merger between two of the world’s major agricultural commodity traders. SAMR identified potential anticompetitive effects in the Chinese markets for imported soybeans, barley, and rapeseed, and required the parties to make five commitments, including continuing to perform existing contracts, ensuring stable supply to the Chinese market, and selling within a reasonable price range.¹⁰

Court Litigation

On June 5, 2025, the Zhejiang High People’s Court held a hearing in an abuse of dominance case brought by NetEase Cloud Music against Tencent Music. NetEase Cloud Music alleges that Tencent Music holds a dominant position in the market for online music platforms in China and has abused that position by imposing technical restrictions, engaging in exclusive copyright arrangements, and limiting the cross-platform data interoperability—conduct that allegedly restricts competition and harms consumer interests.¹¹

Academia

From June 12 to 13, the “Beijing-Shanghai Regional Symposium on Competition Policy” was successfully held in Lingang, Shanghai. The event was jointly organized by the Shanghai AMR, the Shanghai Law Society, and the Shanghai Bar Association. The symposium focused on three core topics: antitrust administrative enforcement and public interest litigation; key issues in fair competition review; and merger control in the context of outbound investment by Chinese enterprises.¹²

1. https://www.jiemian.com/article/12960568.html?sessionid=-725997521
2. https://www.samr.gov.cn/hd/zjdc/art/2025/art_67923847f1e54bb3bc5dd5a90c37022b.html?sessionid=-725149940
3. https://www.samr.gov.cn/hd/zjdc/art/2025/art_7f869933359940d4b9dc584536b1072b.html?sessionid=-746609906
4. https://www.samr.gov.cn/xw/zj/art/2025/art_0d043840ec9445a689496bcf30c94820.html?sessionid=-722510504
5. https://jyzjz.samr.gov.cn/publicityIndex?sessionid=-731219726
6. https://scjgj.beijing.gov.cn/zwxx/scjgdt/202506/t20250617_4114890.html?sessionid=-732929387
7. https://www.samr.gov.cn/xw/zj/art/2025/art_315962c04e0547e7866a51d500a865fd.html?sessionid=-743946740

8. https://www.sohu.com/a/901425108_161795?sessionid=-744545776

9. https://www.samr.gov.cn/fldes/tzgg/ftj/art/2025/art_d7752467113c49d1b41168db859e1a67.html?sessionid=-721960072

10. https://www.samr.gov.cn/fldes/tzgg/ftj/art/2025/art_0c6700f56f174bee8fd90dc8ecb6ffcc.html?sessionid=-721914977

11. https://www.100ec.cn/detail--6649847.html?sessionid=-734164659

12. https://www.shanghai.gov.cn/nw31406/20250619/74390a57612943c99368828b649fdf35.html?sessionid=-731450370