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Competitive Edge Retail & Consumer COMPETITIVE EDGE RETAIL & CONSUMER December 2015 RECENT COMPETITION LAW TRENDS ► Restrictions on online selling continue to be a focus for competition authorities, with the House of Lords launching an inquiry into online platform regulation which will contribute to the Digital Single Market Strategy and 25 authorities across Europe now monitoring the effect of Expedia and Booking.com's agreement to drop broad parity clauses from their contracts with hotels. These developments in the R&C sector form part of the wider scrutiny of digital markets, for example the FCA has recently launched a Call for Inputs on the use of Big Data in the retail general insurance sector. ► Online restrictions in the sports industry have also been in the spotlight – the European Commission ( Commission) has been asked to review geo-blocking techniques in relation to the screening of Rugby World Cup matches and there have been concerns about the possible impact of the Commission's review of pay TV on revenues of sports clubs. This week, the Commission has also presented its proposal on broadening access to online content. ► In addition, the Competition and Markets Authority (CMA) has launched investigations into possible anti-competitive arrangements in the sports equipment sector and online sales of licensed sport and entertainment merchandise (the latter in connection with an investigation by the US Department of Justice ( DoJ)). ► Elsewhere in Europe, the French competition authority has closed an investigation following Adidas' agreement to allow authorised retailers to sell on online marketplaces. This investigation was carried out in conjunction with the German competition authority, which reached a similar result earlier in the year. Interestingly, Asics was also the subject of a similar investigation in Germany and is understood to be taking action against the decision that its policy restricted online commerce. COMMERCIAL LEASE RESTRICTIONS ► The European Court of Justice (ECJ) has ruled that the mere existence of a restrictive covenant in a commercial lease between a Latvian supermarket chain and multiple shopping centres does not mean that the object of that agreement is to restrict competition.1 The judgment provides some guidance on the factors relevant to an effects-based analysis of these types of restriction and does not appear to require any changes to the way in which we currently analyse such restrictions. ► The court was analysing a series of commercial leases which gave the anchor tenant, Latvian supermarket chain Maxima Latvija, the "right to agree" to shopping centres letting further premises to rival retailers. The case was referred to the ECJ to ascertain whether such contracts were anticompetitive, with the Latvian Competition Council having previously decided that such leases were automatically anticompetitive. This has now been reversed. ► The ECJ held that such clauses require a thorough analysis of the economic and legal context, taking into account: ► All factors which determine access to the relevant market (availability and accessibility of commercial land and the existence of economic, administrative or regulatory barriers to entry i.e. whether there is a real possibility for a competitor to establish itself through alternative premises); ► The conditions under which competitive forces operate in the market (the number and size of competitors, the degree of concentration, customer fidelity and consumer habits); and ► Where access to the market is made difficult by the restriction and similar agreements, the extent to which they contribute to the closing-off of the market (based on each agreement's contribution, the position of the contracting parties in the market, and the duration of the agreement). ► The ECJ judgment is broadly consistent with the approach already taken in the UK (i.e. an effects based approach to restrictions), although the OFT land agreements guideline provides more detail on market definition and fascia counting thresholds (as does the Groceries Market Investigation (Controlled Land) Order 2010 in the context of grocery retail). This case is, nevertheless, a useful precedent for commercial retail leases, and provides broader signs of the effects-based treatment of such restrictive covenants in commercial contracts. 1 Case C-345/14, Maxima Latvija. ROUND UP OF RECENT DEVELOPMENTS MATTER UPDATE Price parity provisions – Online Twenty five authorities across Europe have closed preliminary investigations into online hotel booking probes across accommodation booking, most recently including the CMA in the UK and the authorities Europe in Poland, Switzerland, Ireland and Greece. As a result of a number of the investigations, Expedia and Booking.com voluntarily agreed to drop certain restrictive pricing clauses (broad parity clauses) from their contracts with hotels and online travel agencies. The authorities, together with the Commission, will now monitor the effect of these changes and will not start any new probes while the monitoring exercise continues, although the need to look at the sector again has not been ruled out. However, the discrepancies in the treatment of price parity clauses in this sector across the EU has resulted in a number of challenges. Booking.com has announced it is to challenge a draft German decision which preliminary ruled that "best price" clauses were anticompetitive. Online booking companies are also challenging a new French law which outlaws all forms of price parity and means hotels now have full control over pricing and can dictate the final price to online agencies. Italy is understood to be considering introducing similar legislation. Access to online content and The Commission has proposed a Regulation on the cross-border portability of online modernisation of EU copyright content services to allow Europeans to travel with their online content. At present, rules Europeans travelling within the EU may be cut off from online services providing films, sports broadcasts, music, e-books or games that they have paid for in their home country. The Commission has also outlined an action plan to modernise EU copyright rules. To read the press release click here. Geo-blocking in the audio-visual BEUC, the European Consumer Organisation, has asked the Commission to sector investigate the lack of cross-border access to audiovisual offers for the Rugby World Cup 2015 due to geo-blocking techniques applied to the online distribution of content. To read the press release click here. Pay-TV investigation could have In a SEC filing Manchester United has raised concerns that its broadcasting revenue effects in the sports sector could be affected by changes that may be introduced when the Commission concludes its investigation into various Hollywood studios and the sales model for TV rights. There are fears that any amendments to copyright rules which would enable wider access to online content across the EU would damage the copyright holders such as the Premier League who are currently able to derive large revenues from the exploitation of such rights within the EU. To read the SEC filing click here. Food packaging cartel In June the Commission fined eight manufacturers and two distributors of retail food packaging trays a total of €115,865,000 for having participated in at least one of five separate cartels. A number of appeals have now been brought against the Commission's decision by Consorzio Cooperative di Produzione e Lavoro SC, Italmobiliare, Huhtamaki and Coveris Rigid. The various grounds of challenge include that the Commission erred in its calculation of fines and attribution of joint and several parental liability, as well as that the Commission infringed the principles of MATTER UPDATE proportionality, equal treatment and its duty to give reasons. To read the case page click here. Restrictive clauses in commercial The ECJ has ruled that the mere existence of a restrictive covenant in a commercial leases lease between a Latvian supermarket chain and multiple shopping centres does not mean that the object of that agreement is to restrict competition. Whilst the judgment contains limited detail, it does provide some guidance on the factors relevant to an effects-based analysis of these types of restriction. To read the full judgment click here. Acquisition of Rexam by Ball The Commission is understood to have concerns that remaining competitors would not pose a sufficient competitive constraint on the merged entity, which would own approximately two thirds of the beverage can manufacturing plants in Europe. To remedy these concerns Ball has offered to sell 11 factories; equating to more than $1.58 billion worth of assets. Ball is understood to be seeking a single purchaser. The Commission is market testing the proposed divestments and has extended the deadline of the investigation to 22 January 2015. To read the latest press release click here. Anheuser-Busch InBev / SABMiller Anheuser-Busch InBev has agreed the terms of its £71bn takeover of rival SABMiller, in a deal that will combine the world's two largest beer makers. The newly-created firm will produce about 30% of the world's beer. AB InBev's brands include Stella Artois and Corona, while SABMiller produces Peroni and Grolsch. The two firms are predicting cost savings of at least $1.4bn a year. To clear the way for the takeover, SABMiller is to sell its 58% stake in its US joint venture MillerCoors to Molson Coors for $12bn (£7.9bn). AB InBev is also exploring the sale of a number of SABMiller’s European premium brands (Peroni and Grolsch) and related businesses. To read the latest press release click here. Online platform regulation Alex Chisholm, Chief Executive of the CMA, has stated that blanket solutions should be avoided in relation to online platform regulation; there is no "digital one size fits all". Instead, assessments should be made based on evidence of the potential adverse effects of specific industry features or practices before other tools are deployed. This should avoid disproportionate actions and side-effects. To read the full speech click here.
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