China Monthly Antitrust Update: March 2025

[co-author: Ken Dai]

Developments Highlights

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

Antitrust Highlights

• SAMR Holds Symposium with Enterprises on Rectifying “Neijuan” Style Competition: On February 25, 2025, SAMR held a symposium on fair competition, attended by seven enterprises from industries including photovoltaic, e-commerce, and automotive. These companies held in-depth discussions on rectifying “rat-race” style competition.

• SAMR Launches Investigation into Google for Suspected Monopolistic Behavior and Is Reportedly Considering Probes into Apple and Intel: On February 4, SAMR announced that it had initiated a formal investigation into Google for alleged violations of China’s Anti-Monopoly Law. According to foreign media reports, SAMR is also evaluating a potential antitrust investigation into Apple and Intel.

• SAMR Holds 2025 National Anti-Monopoly Work Conference: On February 20, SAMR held the National Anti-Monopoly Work Conference. The conference pointed out that in 2024, a total of 72 cases of abuse of administrative power to exclude or restrict competition were filed and investigated; 22 cases of monopoly agreements and abuse of market dominance were filed and investigated; and 643 cases of concentration of undertakings were concluded.

For more details, please refer to the main text of the report and the links of the complete coverage.

Authorities

Guangdong, Guangxi and Hainan AMR Jointly Signs Framework Agreement on Collaborative Cooperation in Anti-Monopoly Work

On February 28, 2025, the Administration for Market Supervision (“AMR”) of Guangdong, Guangxi and Hainan province jointly signed the Framework Agreement on Collaborative Cooperation in Anti-Monopoly Work. According to the agreement, the AMR of the three provinces will carry out cross-provincial anti-monopoly cooperation in eight aspects for a period of three years, and jointly establish and improve the cross-regional anti-monopoly cooperation mechanism.1

SAMR Releases 2024 Review of Achievements in Antitrust Regulation on Concentration of Undertakings

On February 27, the State Administration for Market Regulation (“SAMR”) announced that a total of 643 concentrations of undertakings were concluded in 2024, with 623 unconditionally approved and 1 approved with restrictive conditions. These efforts have created a favorable environment for investment and mergers and acquisitions of various business entities, and injected strong momentum into high-quality economic development.2

SAMR Holds Symposium with Enterprises on Rectifying “Neijuan” Style Competition

On February 25, SAMR held a symposium on fair competition, attended by seven enterprises from industries including photovoltaic, e-commerce, and automotive. These companies engaged in in-depth discussions on addressing “rat-race” style competition. Participants shared insights into their current market environments, competitive challenges, and operational difficulties, while proposing concrete recommendations in areas such as anti-monopoly and anti-unfair competition enforcement, fair competition reviews, and corporate compliance guidance. Officials from relevant departments responded point-by-point to the issues and suggestions raised by the enterprises.3

SAMR Holds 2025 National Conference on Anti-Monopoly Work

On February 20, SAMR held the National Conference on Anti-Monopoly Work. The conference highlighted out that in 2024, anti-monopoly work achieved significant progress and results. A total of 72 cases of abuse of administrative power to exclude or restrict competition were filed and investigated; 22 cases of monopoly agreements and abuse of market dominance were filed and investigated; and 643 cases of concentration of undertakings were concluded.4

SAMR and Other Four Departments to Strengthen and Improve Antitrust Enforcement in Consumer Markets

On February 19, 2025, SAMR and four other departments jointly issued the “Three-Year Action Plan for Optimizing the Consumer Environment (2025-2027)”. The plan proposes to strengthen and improve antitrust enforcement in the consumer market and crack down on anti-competitive practices in the pharmaceutical, utilities, and automotive industries.5

SAMR to Refine Antitrust Guidelines for Guiding and Regulating Business Competition

On February 19, SAMR stated in an interview that it will improve antitrust guidelines, focus on solving problems such as difficulties in business relocation and local hidden barriers, strive to create a fair and just market environment, and provide compliance guidance and regulatory norms for excessive competition among enterprises.6

Beijing AMR Releases Findings from 2023 Fair Competition Review Spot Checks

On February 12, Beijing AMR issued a notice regarding problematic documents identified during the 2023 spot checks on fair competition review. According to the spot check, a total of 7 policy documents violated the relevant provisions of the Implementing Rules for the Fair Competition Review System, with issues that hindered the unified market and fair competition. Currently, all relevant units have completed the rectifications as required.7

SAMR to Leverage “Three Notices and One Letter” Mechanism and Fair Competition Review System in Rectifying “Neijuan” Style Competition

On February 7, the Deputy Director of the Competition Policy Coordination Department of SAMR responded to a journalist’s question about “Neijuan” style competition, stating that involutionary investment attraction affects the fair competition in markets. Market supervision departments will use the “Three Notices and One Letter” mechanism and the Fair Competition Review system to comprehensively address such issues and maintain a fair and just market environment.8

Public Enforcement

MOFA Responds to Whether China Is Developing a List of Antitrust Investigations Targeting U.S. Tech Companies

On February 10, 2025, the spokesperson of the Ministry of Foreign Affairs (“MOFA”) responded to the question raised by a journalist about whether China is formulating a list of antitrust investigations targeting U.S. tech companies. The spokesperson stated that they could not confirm the specific details, and emphasized that China has always opposed the over-politicization of the concept of national security and the practice of politicizing economic, trade, science and technology issues.9

SAMR May Consider Antitrust Investigation into Apple

On February 7, Bloomberg reported that SAMR is evaluating a potential antitrust investigation into Apple, focusing on its 30% commission fee for in-app purchases and policies prohibiting third-party payment services and alternative app stores. On the same day, when asked about whether China is investigating Apple, a Chinese Foreign Ministry spokesperson stated they were “unable to confirm specifics” and directed inquiries to the relevant Chinese authorities.10

SAMR May Consider Investigation into Intel

On February 4, Financial Times reported that SAMR is evaluating a potential investigation into Intel, though the specific nature of the investigation remains unclear.11

SAMR Launches Investigation into Google for Suspected Monopolistic Behavior

On February 4, SAMR announced that it had launched an investigation into Google due to suspected violations of the Anti-Monopoly Law of the People’s Republic of China.12

Academia

Professor Zhang Chenying Publishes Article on Regulating Monopolistic Practices of Multinational Corporations

On February 5, 2025, Professor Zhang Chenying from Tsinghua University published an article titled “Regulating the Monopolistic Practices of Multinational Corporations in Accordance with the Law Contributes to Maintaining Fair Competition in the International Market and Promoting Industrial Innovation and Development”.13

Seminar on Further Comprehensively Deepening Reform and the Implementation of the Anti-Monopoly Law Held in Beijing

On January 10, a seminar titled “Further Comprehensively Deepening Reform and the Implementation of the Anti-Monopoly Law” was held in Beijing. The seminar was hosted by the Institute of Law of the Chinese Academy of Social Sciences. More than 40 experts from the Supreme People’s Court (“SPC”), SAMR, and other institutions conducted in-depth discussions on the major theoretical and practical issues related to the implementation of the Anti-Monopoly Law in the context of further comprehensively deepening reform.14

Endnotes

1. https://news.southcn.com/node_d16fadb650/5fb9c48151.shtml

2. https://www.samr.gov.cn/xw/zj/art/2025/art_21f523302be74c22922ad59b925bdfa3.html

3. https://mp.weixin.qq.com/s/HSOLVtJXsBHVbTjP9rhiqQ?scene=25#wechat_redirect

4. https://www.samr.gov.cn/xw/zj/art/2025/art_2e376541b13f4429b2afe2e91d50e9f0.html

5. https://www.samr.gov.cn/zw/zfxxgk/fdzdgknr/zfjcs/art/2025/art_d90d10c4df944544a46ce8534bbccca6.html

6. https://m.jstv.com/news/2025/2/19/1341744795096829952.html

7. https://scjgj.beijing.gov.cn/zwxx/gs/202502/t20250212_4009054.html

8. http://paper.people.com.cn/rmrb/pc/attachement/202502/07/991c4ecb-fdc2-456d-9791-186bda135155.pdf

9. https://www.mfa.gov.cn/web/wjdt_674879/fyrbt_674889/202502/t20250210_11552101.shtml

10. https://www.bloomberg.com/news/articles/2025-02-05/china-weighs-investigating-apple-over-app-store-policies-fees-including-30-cut

https://mp.weixin.qq.com/s/M-XamEOlqCz63u4Te9NCZQ? scene=25#wechat_redirect

11. https://3g.china.com/act/news/10000169/20250205/47932209.html

12. https://www.samr.gov.cn/xw/zj/art/2025/art_396a9ab3aa6d4c4bbd40833815afd245.html

13. https://www.peopleapp.com/column/30048179136-500006078037

14. https://mp.weixin.qq.com/s/N0vlm1jONwPRYw3KLgpFYg?scene=25#wechat_redirect