Articles

Response to the European Commission’s targeted consultation on revising its merger guidelines

December 1, 2025
EU flags at European Competition

CRA experts Alessandro Kadner-Graziano and Serge Moresi submitted comments to the European Commission’s public consultation on revising its merger guidelines, focusing on non-horizontal mergers.

Their recommendations include:

  • Using simultaneous vGUPPIs to account for feedback effects between raising rivals’ costs (RRC) incentives and elimination of double marginalization (EDM).
  • Using two new analytical tools (two margin tests) to identify situations where certain price effects from the merger (RRC or EDM) are unlikely to materialize.

The comments suggest improvements to the framework for assessing potential competitive effects of non-horizontal mergers. Serge Moresi also presented at a workshop on non-horizontal mergers organized by the European Commission in Brussels.

Read the full response to the European Commission’s targeted consultation on revising its merger guidelines here.