EU Merger Guidelines Consultation – Our Views on Public Policy, Security, and Labour Market Considerations

As part of our response to the European Commission’s consultation on possible reforms to its merger control guidelines, we submitted our observations on Topic Paper G – Public Policy, Security, and Labour Market Considerations.

The EUMR sets a clear mandate for the Commission to prevent concentrations causing a significant impediment to effective competition. In applying this standard, the Commission has traditionally not considered non-economic factors, such as impact on media plurality, democracy, or workers. Our submission supports that approach. However, this should not prevent the Commission from applying an analytical framework that facilitates consolidation in strategic sectors that are critical for the EU’s security and resilience, consistent with the broader policy objectives outlined in the Competitiveness Compass and the Draghi Report.

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