Rethinking the As-Efficient Competitor Test: Assessing the wider impact of the CJEU’s Judgment in Unilever and its Implications in Shaping the European Commission's agenda to Reform Article 102 TFEU


October 28, 2024

Rethinking the As-Efficient Competitor Test: Assessing the wider impact of the CJEU’s Judgment in Unilever and its Implications in Shaping the European Commission's agenda to Reform Article 102 TFEU

Recently, the European Commission published a communication indicating amendments to its

Article 102 TFEU Guidance Paper in light of the latest EU Courts’ judgments on exclusionary

abuses. In the Amended Guidance and the Policy Brief, the Commission provides some

guidance related to changes in four main areas: the anti-competitive foreclosure definition, the

as efficient competitor (AEC) test, the assessment of loyalty rebates, treatment of refusals to

supply and margin squeezes. The analysis in this article reflects on the evolution of the

application of the AEC test, focused on the most recent CJEU judgment in Unilever Italia. The

article discusses the extent to which the Competition Authorities must examine economic

evidence submitted by the dominant company, and whether they can be refuted without in-

depth analysis. The paper concludes that further clarification is imperative regarding

outstanding ambiguities surrounding the appropriate role and use of the AEC price-cost test in assessing potentially abusive conduct under Article 102 TFEU.

 

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