On June 7, 2025, the National Anti-Monopoly Bureau under the State Administration for Market Regulation (SAMR) officially released the Annual Report on China’s Anti-Monopoly Enforcement (2024). The report aims to:
1. Fully and promptly disclose antitrust enforcement data and typical enforcement developments in 2024 to the public, enhancing policy transparency and credibility;2. Use typical cases to demarcate “red lines,” strengthening ex-ante compliance guidance and deterrence for business operators and industry associations;3. Provide policy basis for the development of a unified national market and the optimization of the business environment through institutional innovation and experience sharing;4. Support innovation-driven and high-quality development by achieving a dynamic balance between protecting people’s livelihood, encouraging competition, and safeguarding fair market order.
This article summarizes the achievements in China’s antitrust regulatory enforcement in 2024 and analyzes selected representative cases.
Overall Enforcement Performance and Representative Cases
In 2024, four key enforcement sectors advanced in coordination, achieving record highs in both case numbers and total fines in recent years. Enforcement methods became increasingly intelligent and refined, with a particular focus on “people’s livelihood pain points” and “factor market hubs,” leading to replicable and scalable governance practices. The specific summaries are as follows:
I. Enforcement Against Monopoly Agreements
General Overview
In 2024, 17 new cases were filed, 6 cases were concluded, with a total of RMB 11.1034 million in fines and confiscations. Of the resolved cases: 1. 50% involved pure horizontal price-fixing;2. 33.3% also involved market division;3. 16.7% further involved output restrictions. These cases involve 1 industry association and 78 companies, with industries concentrated in typical areas of infrastructure sectors such as motor vehicle inspection, driver training, construction materials, and liquefied gas. 1. Ongoing Intensification of Antitrust Enforcement in the Vehicle Inspection Industry Typical Cases: (1) Price-Fixing by 13 Vehicle Inspection Agencies in Xiangxi, Hunana) Case Summary: On March 13, 2021, Xiangxi Jingtian Vehicle Inspection Co., Ltd. (as the main organizer) convened 12 local inspection agencies for a closed-door meeting to “uniformly raise” the inspection fee for 5- and 7-seat small passenger cars. Following the meeting, the fee was gradually increased from RMB 220 to between RMB 260–280.b) Investigation Process: The Hunan Provincial Administration for Market Regulation opened the case in June 2022, collecting over 180,000 inspection transaction records, bank transfer slips, and WeChat group chat screenshots. During multiple interrogations, participants admitted the price-fixing was motivated by low profit margins and intense price competition.c) Decision Highlights: The 13 institutions were found to be “competing undertakings” under Article 13 of the 2007 Anti-Monopoly Law, and their coordinated pricing excluded and restricted competition. Penalties totaling RMB 2.3283 million were imposed, with aggravated fines (6% of turnover) on Jingtian as the ringleader.d) Remediation and Demonstrative Effect: All inspection institutions in Xiangxi were ordered to re-disclose self-determined prices within 30 days and accept cost audits. The case became a model for local price governance, prompting cities like Guiyang and Lanzhou to introduce early warning mechanisms at signs of price fluctuation. (2) Collusive Price Increase by 10 Vehicle Inspection Companies in Tianjina) Agreement Model: In August 2023, 10 companies signed a “Self-Discipline Cooperation Guarantee Clause,” stipulating a minimum fee of RMB 150 per inspection for small blue-plate vehicles, and setting up a “public account” to redistribute RMB 20 per car weekly, thereby forming a de facto pricing alliance. Some companies later proposed raising the base price to RMB 180 in April 2024.b) Enforcement Breakthrough: During surprise inspections from May to July 2024, the Tianjin Municipal Administration for Market Regulation directly seized meeting minutes, transfer records, and account ledgers confirming horizontal price-fixing.c) Penalty Result: The agreement was immediately terminated, cooperative funds refunded, and a total fine of RMB 675,100 was imposed on all 10 entities. 2. Strengthening Antitrust Enforcement in the Construction Materials Industry Representative Case: Five Rock Wool Manufacturers in Xinjiang Collude to “Cut Production and Stabilize Market”a) Industry Background: Rock wool, a thermal insulation material, faced oversupply and fierce competition in Northern Xinjiang due to environmental restrictions and infrastructure market fluctuations in 2021.b) Agreement Details: Five companies including Dingchen Technology twice signed a “Cooperation Agreement on Production Cut to Stabilize the Market,” each contributing RMB 500,000 in performance bonds, sealing production lines using physical lock lines, and agreeing not to sell below RMB 1,000 per ton for mainstream products.c) Implementation: From June 20 to September 20, 2021, the five companies conducted daily mutual inspections of sealed lines and publicized suspension durations. During this period, market prices rebounded by 22%, significantly increasing costs for downstream insulation projects.d) Penalties and Significance: On May 31, 2024, the Xinjiang AMR imposed fines and confiscations totaling RMB 5.2055 million and ordered the dissolution of the agreement and removal of seals. The case joined the 2019 cement and 2020 concrete additive cases as one of the “three typical cases” in construction materials, delivering a systemic deterrent against similar “production-cut stabilization” schemes. 3. Enhancing Antitrust Oversight in the Driver Training Market Representative Case: XiuShan Transport Association in Chongqing Orchestrates Price-Fixing Among Nine Driving Schoolsa) Organizational Structure: Although nominally an industry self-regulator, the association convened nine schools between March 2022 and May 2023 to sign unified price-hike proposals, centrally collecting student registration fees (RMB 2,800 per person) and redistributing funds monthly based on enrollment.b) Monopolistic Practices: The arrangement fixed training fees, split revenues, and excluded non-participating schools. A fine of RMB 30,000 and blacklisting were imposed on schools that undercut the agreed price.c) Legal Assessment: The association violated Article 21 of the Anti-Monopoly Law by organizing business operators to reach a monopoly agreement; the schools violated Article 17 by fixing prices and dividing markets. On September 3, 2024, the Chongqing AMR imposed combined penalties of RMB 391,500, fined the association’s leader personally, and revoked his professional qualifications for two years.d) Follow-Up Measures: Local authorities jointly issued new rules for transparent driver training pricing, introducing third-party cost audits and dynamic monitoring. 4. Compliance Reminder in the Automotive Distribution Sector In January 2024, facing risks of vertical price restrictions by luxury auto brands, SAMR delivered on-site Compliance Reminder Letters to Jaguar Land Rover, Audi, Volkswagen China, BMW China, and Mercedes-Benz China, urging self-inspection for issues such as resale price maintenance, tying, and regional restrictions. Though no fines were issued, this marked the first time administrative reminders were formally included in the annual enforcement report—demonstrating a proactive compliance governance approach. II. Enforcement Against Abuse of Market Dominance In 2024, a total of 5 cases were investigated, with fines and confiscations reaching RMB 1.069 billion, mainly concentrated in public utilities (water and gas supply) and financial data services. Representative cases are as follows: 1. Weihai Water Group: Tying and Imposing Unreasonable Conditions a) Period of Violation: From January 2018 to September 2023, Weihai Water Group forced real estate developers to use designated design and construction units during pipeline installation. Additionally, it charged off-red-line connection and drainage fees based on its own cost estimates, totaling over RMB 38 million.b) Enforcement Outcome: In September 2024, the Shandong AMR ordered the company to cease illegal behavior, confiscated RMB 34.9956 million in unlawful gains, and imposed an administrative fine of RMB 30.2056 million (3% of its 2022 sales revenue), for a total penalty of RMB 65.2012 million.c) Rectification: Weihai Water was also required to refund affected parties from 137 projects and issue a public apology. 2. Hainan Kunlun Ganghua Gas: Tying and Restrictive Practices a) Period of Violation: From 2014 to May 2018, leveraging its exclusive position in urban gas supply, the company forced property developers to contract pipeline installation with itself and procure materials only from its designated suppliers. It also restricted old neighborhoods from using non-designated brands of pipes and valves.b) Penalty: In May 2024, the Hainan AMR imposed a fine and confiscation totaling RMB 7.1283 million, ordered the termination of exclusive agreements within 60 days, and required the establishment of a third-party assessment system. This was the first abuse of dominance case in public utilities in the Hainan Free Trade Port. 3. Ningbo Senpu Information Technology: Refusal to Deal and Unfair Conditions a) Conduct: Senpu held exclusive agency rights to China’s largest interdealer broker’s real-time bond trading data. It refused without justification to share data with competing information service providers and imposed unreasonably high pricing packages (starting from RMB 700,000/year, far above the industry average of RMB 100,000/year).b) Enforcement Outcome: In August 2024, the Shanghai AMR imposed a fine of RMB 4.5328 million (2% of its 2022 sales) and ordered the company to offer data services on fair, reasonable, and non-discriminatory (FRAND) terms.c) Significance: Recognized as China’s first anti-monopoly case in the financial data sector, this case sets a precedent for antitrust enforcement in data factor markets. III. Merger Control Enforcement In 2024, SAMR received and reviewed 643 merger notifications: 1. 623 were unconditionally approved,2. 1 was conditionally approved (JX Nippon Mining & Metals’ acquisition of Taki Chemical),3. Average case review time was shortened to 24.7 days. Key Developments in Institutional Reform: 1. The new “Notification Threshold Regulation” raised revenue thresholds, reducing the number of filings by 15% year-on-year, thereby directly lowering compliance costs for enterprises;2. The issuance of the “Guidelines for the Review of Horizontal Mergers” and the launch of updated forms for simplified case filings and public notices reduced document sets from 3 to 2 and information items from 44 to 38; 3. A new “1+3+7” integrated system was built, enabling digital interaction across: 1) enterprise filing portal (“1”),2) central SAMR review portal (“3”),3) delegated provincial AMR portals (“7”). Representative Case: Tobishi vs. SAMR – Administrative Litigation on Conditional Merger Approval 1. Background: 1) Parties & Transaction: Simcere Pharmaceutical sought to acquire 100% equity in Beijing Tobishi Pharmaceutical, aiming to consolidate resources for the thrombolytic drug batroxobin injection.2) Timeline: Tobishi submitted a simplified notification on June 29, 2022. On July 20, Simcere submitted supplementary materials; SAMR formally accepted the case on November 23, 2022. 2. Competitive Concerns:Post-merger, the combined market share for batroxobin injections would approach monopoly, and Simcere had tight affiliations with hospitals and distributors, raising concerns of exclusivity, price hikes, and innovation stagnation. 3. SAMR Decision: On September 22, 2023, SAMR issued Decision No. 42 (2023), conditionally approving the transaction. The commitments required:1) Terminating all exclusive agreements involving Tobishi products;2) Divesting an ongoing R&D project to an independent third party (including IP and data);3) Lowering batroxobin ex-factory prices by 15% and maintaining them for at least three years;4) Semi-annual compliance reporting monitored by an independent trustee. 4. Administrative Reconsideration & Litigation: Tobishi challenged the decision as an “excessive intervention in commercial autonomy.” After SAMR reaffirmed its decision in February 2024, Tobishi filed a lawsuit in March 2024 with the Beijing IP Court. 5. Judgment: On December 30, 2024, the court ruled:1) Facts were clearly established,2) Legal application was correct,3) Procedures were lawful. The court dismissed all claims, and Tobishi did not appeal, making the decision legally binding. 6. Key Legal Principles Established: 1) Scope of Justiciable Interest: Only prohibitions or conditional approvals change legal obligations and are thus subject to judicial review; unconditional approvals are not.2) Voluntary Filings Are Fully Reviewable: SAMR retains authority to issue conditional or prohibitive rulings even in voluntary filings.3) Prohibition Is Not Default Remedy: Conditional approvals are preferred when commitments can effectively resolve competition concerns.4) Focus on Structural Effects: The review addresses structural competition harm from the transaction itself, not all market imperfections.5) Three Benchmarks for Commitments: Effectiveness, feasibility, and timeliness are sufficient to validate a commitment plan. 7. Impact and Demonstrative Effect: 1) First Full Judicial Review: This was the first judicial case involving merger review since the 2008 Anti-Monopoly Law came into force, establishing a tripartite remedy path: administrative review → reconsideration → litigation.2) Clarified Key Doctrines: The judgment confirms SAMR’s discretion over voluntary filings and affirms conditional approvals as the primary regulatory solution.3) Enhanced Predictability: Public access to the court ruling offers valuable reference for merger planning, risk evaluation, and commitment design.4) Rule-of-Law Assurance: The case demonstrates transparency, procedural rigor, and legal oversight—enhancing investor confidence in the fairness and predictability of China’s antitrust regime. IV. Enforcement Against Abuse of Administrative Power to Eliminate or Restrict Competition In 2024, 72 cases were filed and 57 cases were concluded, with a focus on exclusive dealing, obstruction of free circulation of goods, and local protectionism (i.e., “local-first” barriers). Key enforcement highlights include: 1. Dismantling Market Barriers 1) Targeted actions addressed exclusionary practices in construction project bidding, government procurement favoring designated brands, and exclusive public utility concessions.2) 23 local red-letter policy documents at the municipal and county levels were corrected under direct supervision. 2. Protecting People’s Livelihood 1) In the healthcare sector, enforcement corrected mandatory procurement of local medical consumables;2) In urban management, it tackled exclusive cooperation agreements for municipal sanitation services.3) Through special supervision, 46 counties and districts publicly amended or repealed improper local rules. 3. Capacity Building 1) For the first time, a systematic training course was conducted to enhance enforcement effectiveness.2) A full-chain coordination mechanism was established: clue identification → task force investigation → direct supervision. Conclusion In 2024, China’s antitrust enforcement, with a greater volume of cases, more refined standards of discretion, and more comprehensive institutional support, has delineated clearer competitive boundaries for market participants: 1) In the people’s livelihood sector, the principle of “regulation for the people” was transformed into tangible price benefits and improved services through typical cases;2) In the factors market, the first data monopoly case marked a critical step toward the rule of law in digital competition;3) At the institutional level, the first direct confrontation between merger review and judicial adjudication provided enterprises with a predictable avenue for rights-based remedies. Looking ahead, by achieving the “three mores” - more mature institutions, more precise enforcement, and more efficient coordination - China’s antitrust enforcement is rapidly shifting from “high-intensity pressure” to “high-quality development”, continuing to safeguard a fair, just, and predictable competitive ecosystem.
In 2024, 17 new cases were filed, 6 cases were concluded, with a total of RMB 11.1034 million in fines and confiscations. Of the resolved cases: 1. 50% involved pure horizontal price-fixing;2. 33.3% also involved market division;3. 16.7% further involved output restrictions. These cases involve 1 industry association and 78 companies, with industries concentrated in typical areas of infrastructure sectors such as motor vehicle inspection, driver training, construction materials, and liquefied gas. 1. Ongoing Intensification of Antitrust Enforcement in the Vehicle Inspection Industry Typical Cases: (1) Price-Fixing by 13 Vehicle Inspection Agencies in Xiangxi, Hunana) Case Summary: On March 13, 2021, Xiangxi Jingtian Vehicle Inspection Co., Ltd. (as the main organizer) convened 12 local inspection agencies for a closed-door meeting to “uniformly raise” the inspection fee for 5- and 7-seat small passenger cars. Following the meeting, the fee was gradually increased from RMB 220 to between RMB 260–280.b) Investigation Process: The Hunan Provincial Administration for Market Regulation opened the case in June 2022, collecting over 180,000 inspection transaction records, bank transfer slips, and WeChat group chat screenshots. During multiple interrogations, participants admitted the price-fixing was motivated by low profit margins and intense price competition.c) Decision Highlights: The 13 institutions were found to be “competing undertakings” under Article 13 of the 2007 Anti-Monopoly Law, and their coordinated pricing excluded and restricted competition. Penalties totaling RMB 2.3283 million were imposed, with aggravated fines (6% of turnover) on Jingtian as the ringleader.d) Remediation and Demonstrative Effect: All inspection institutions in Xiangxi were ordered to re-disclose self-determined prices within 30 days and accept cost audits. The case became a model for local price governance, prompting cities like Guiyang and Lanzhou to introduce early warning mechanisms at signs of price fluctuation. (2) Collusive Price Increase by 10 Vehicle Inspection Companies in Tianjina) Agreement Model: In August 2023, 10 companies signed a “Self-Discipline Cooperation Guarantee Clause,” stipulating a minimum fee of RMB 150 per inspection for small blue-plate vehicles, and setting up a “public account” to redistribute RMB 20 per car weekly, thereby forming a de facto pricing alliance. Some companies later proposed raising the base price to RMB 180 in April 2024.b) Enforcement Breakthrough: During surprise inspections from May to July 2024, the Tianjin Municipal Administration for Market Regulation directly seized meeting minutes, transfer records, and account ledgers confirming horizontal price-fixing.c) Penalty Result: The agreement was immediately terminated, cooperative funds refunded, and a total fine of RMB 675,100 was imposed on all 10 entities. 2. Strengthening Antitrust Enforcement in the Construction Materials Industry Representative Case: Five Rock Wool Manufacturers in Xinjiang Collude to “Cut Production and Stabilize Market”a) Industry Background: Rock wool, a thermal insulation material, faced oversupply and fierce competition in Northern Xinjiang due to environmental restrictions and infrastructure market fluctuations in 2021.b) Agreement Details: Five companies including Dingchen Technology twice signed a “Cooperation Agreement on Production Cut to Stabilize the Market,” each contributing RMB 500,000 in performance bonds, sealing production lines using physical lock lines, and agreeing not to sell below RMB 1,000 per ton for mainstream products.c) Implementation: From June 20 to September 20, 2021, the five companies conducted daily mutual inspections of sealed lines and publicized suspension durations. During this period, market prices rebounded by 22%, significantly increasing costs for downstream insulation projects.d) Penalties and Significance: On May 31, 2024, the Xinjiang AMR imposed fines and confiscations totaling RMB 5.2055 million and ordered the dissolution of the agreement and removal of seals. The case joined the 2019 cement and 2020 concrete additive cases as one of the “three typical cases” in construction materials, delivering a systemic deterrent against similar “production-cut stabilization” schemes. 3. Enhancing Antitrust Oversight in the Driver Training Market Representative Case: XiuShan Transport Association in Chongqing Orchestrates Price-Fixing Among Nine Driving Schoolsa) Organizational Structure: Although nominally an industry self-regulator, the association convened nine schools between March 2022 and May 2023 to sign unified price-hike proposals, centrally collecting student registration fees (RMB 2,800 per person) and redistributing funds monthly based on enrollment.b) Monopolistic Practices: The arrangement fixed training fees, split revenues, and excluded non-participating schools. A fine of RMB 30,000 and blacklisting were imposed on schools that undercut the agreed price.c) Legal Assessment: The association violated Article 21 of the Anti-Monopoly Law by organizing business operators to reach a monopoly agreement; the schools violated Article 17 by fixing prices and dividing markets. On September 3, 2024, the Chongqing AMR imposed combined penalties of RMB 391,500, fined the association’s leader personally, and revoked his professional qualifications for two years.d) Follow-Up Measures: Local authorities jointly issued new rules for transparent driver training pricing, introducing third-party cost audits and dynamic monitoring. 4. Compliance Reminder in the Automotive Distribution Sector In January 2024, facing risks of vertical price restrictions by luxury auto brands, SAMR delivered on-site Compliance Reminder Letters to Jaguar Land Rover, Audi, Volkswagen China, BMW China, and Mercedes-Benz China, urging self-inspection for issues such as resale price maintenance, tying, and regional restrictions. Though no fines were issued, this marked the first time administrative reminders were formally included in the annual enforcement report—demonstrating a proactive compliance governance approach. II. Enforcement Against Abuse of Market Dominance In 2024, a total of 5 cases were investigated, with fines and confiscations reaching RMB 1.069 billion, mainly concentrated in public utilities (water and gas supply) and financial data services. Representative cases are as follows: 1. Weihai Water Group: Tying and Imposing Unreasonable Conditions a) Period of Violation: From January 2018 to September 2023, Weihai Water Group forced real estate developers to use designated design and construction units during pipeline installation. Additionally, it charged off-red-line connection and drainage fees based on its own cost estimates, totaling over RMB 38 million.b) Enforcement Outcome: In September 2024, the Shandong AMR ordered the company to cease illegal behavior, confiscated RMB 34.9956 million in unlawful gains, and imposed an administrative fine of RMB 30.2056 million (3% of its 2022 sales revenue), for a total penalty of RMB 65.2012 million.c) Rectification: Weihai Water was also required to refund affected parties from 137 projects and issue a public apology. 2. Hainan Kunlun Ganghua Gas: Tying and Restrictive Practices a) Period of Violation: From 2014 to May 2018, leveraging its exclusive position in urban gas supply, the company forced property developers to contract pipeline installation with itself and procure materials only from its designated suppliers. It also restricted old neighborhoods from using non-designated brands of pipes and valves.b) Penalty: In May 2024, the Hainan AMR imposed a fine and confiscation totaling RMB 7.1283 million, ordered the termination of exclusive agreements within 60 days, and required the establishment of a third-party assessment system. This was the first abuse of dominance case in public utilities in the Hainan Free Trade Port. 3. Ningbo Senpu Information Technology: Refusal to Deal and Unfair Conditions a) Conduct: Senpu held exclusive agency rights to China’s largest interdealer broker’s real-time bond trading data. It refused without justification to share data with competing information service providers and imposed unreasonably high pricing packages (starting from RMB 700,000/year, far above the industry average of RMB 100,000/year).b) Enforcement Outcome: In August 2024, the Shanghai AMR imposed a fine of RMB 4.5328 million (2% of its 2022 sales) and ordered the company to offer data services on fair, reasonable, and non-discriminatory (FRAND) terms.c) Significance: Recognized as China’s first anti-monopoly case in the financial data sector, this case sets a precedent for antitrust enforcement in data factor markets. III. Merger Control Enforcement In 2024, SAMR received and reviewed 643 merger notifications: 1. 623 were unconditionally approved,2. 1 was conditionally approved (JX Nippon Mining & Metals’ acquisition of Taki Chemical),3. Average case review time was shortened to 24.7 days. Key Developments in Institutional Reform: 1. The new “Notification Threshold Regulation” raised revenue thresholds, reducing the number of filings by 15% year-on-year, thereby directly lowering compliance costs for enterprises;2. The issuance of the “Guidelines for the Review of Horizontal Mergers” and the launch of updated forms for simplified case filings and public notices reduced document sets from 3 to 2 and information items from 44 to 38; 3. A new “1+3+7” integrated system was built, enabling digital interaction across: 1) enterprise filing portal (“1”),2) central SAMR review portal (“3”),3) delegated provincial AMR portals (“7”). Representative Case: Tobishi vs. SAMR – Administrative Litigation on Conditional Merger Approval 1. Background: 1) Parties & Transaction: Simcere Pharmaceutical sought to acquire 100% equity in Beijing Tobishi Pharmaceutical, aiming to consolidate resources for the thrombolytic drug batroxobin injection.2) Timeline: Tobishi submitted a simplified notification on June 29, 2022. On July 20, Simcere submitted supplementary materials; SAMR formally accepted the case on November 23, 2022. 2. Competitive Concerns:Post-merger, the combined market share for batroxobin injections would approach monopoly, and Simcere had tight affiliations with hospitals and distributors, raising concerns of exclusivity, price hikes, and innovation stagnation. 3. SAMR Decision: On September 22, 2023, SAMR issued Decision No. 42 (2023), conditionally approving the transaction. The commitments required:1) Terminating all exclusive agreements involving Tobishi products;2) Divesting an ongoing R&D project to an independent third party (including IP and data);3) Lowering batroxobin ex-factory prices by 15% and maintaining them for at least three years;4) Semi-annual compliance reporting monitored by an independent trustee. 4. Administrative Reconsideration & Litigation: Tobishi challenged the decision as an “excessive intervention in commercial autonomy.” After SAMR reaffirmed its decision in February 2024, Tobishi filed a lawsuit in March 2024 with the Beijing IP Court. 5. Judgment: On December 30, 2024, the court ruled:1) Facts were clearly established,2) Legal application was correct,3) Procedures were lawful. The court dismissed all claims, and Tobishi did not appeal, making the decision legally binding. 6. Key Legal Principles Established: 1) Scope of Justiciable Interest: Only prohibitions or conditional approvals change legal obligations and are thus subject to judicial review; unconditional approvals are not.2) Voluntary Filings Are Fully Reviewable: SAMR retains authority to issue conditional or prohibitive rulings even in voluntary filings.3) Prohibition Is Not Default Remedy: Conditional approvals are preferred when commitments can effectively resolve competition concerns.4) Focus on Structural Effects: The review addresses structural competition harm from the transaction itself, not all market imperfections.5) Three Benchmarks for Commitments: Effectiveness, feasibility, and timeliness are sufficient to validate a commitment plan. 7. Impact and Demonstrative Effect: 1) First Full Judicial Review: This was the first judicial case involving merger review since the 2008 Anti-Monopoly Law came into force, establishing a tripartite remedy path: administrative review → reconsideration → litigation.2) Clarified Key Doctrines: The judgment confirms SAMR’s discretion over voluntary filings and affirms conditional approvals as the primary regulatory solution.3) Enhanced Predictability: Public access to the court ruling offers valuable reference for merger planning, risk evaluation, and commitment design.4) Rule-of-Law Assurance: The case demonstrates transparency, procedural rigor, and legal oversight—enhancing investor confidence in the fairness and predictability of China’s antitrust regime. IV. Enforcement Against Abuse of Administrative Power to Eliminate or Restrict Competition In 2024, 72 cases were filed and 57 cases were concluded, with a focus on exclusive dealing, obstruction of free circulation of goods, and local protectionism (i.e., “local-first” barriers). Key enforcement highlights include: 1. Dismantling Market Barriers 1) Targeted actions addressed exclusionary practices in construction project bidding, government procurement favoring designated brands, and exclusive public utility concessions.2) 23 local red-letter policy documents at the municipal and county levels were corrected under direct supervision. 2. Protecting People’s Livelihood 1) In the healthcare sector, enforcement corrected mandatory procurement of local medical consumables;2) In urban management, it tackled exclusive cooperation agreements for municipal sanitation services.3) Through special supervision, 46 counties and districts publicly amended or repealed improper local rules. 3. Capacity Building 1) For the first time, a systematic training course was conducted to enhance enforcement effectiveness.2) A full-chain coordination mechanism was established: clue identification → task force investigation → direct supervision. Conclusion In 2024, China’s antitrust enforcement, with a greater volume of cases, more refined standards of discretion, and more comprehensive institutional support, has delineated clearer competitive boundaries for market participants: 1) In the people’s livelihood sector, the principle of “regulation for the people” was transformed into tangible price benefits and improved services through typical cases;2) In the factors market, the first data monopoly case marked a critical step toward the rule of law in digital competition;3) At the institutional level, the first direct confrontation between merger review and judicial adjudication provided enterprises with a predictable avenue for rights-based remedies. Looking ahead, by achieving the “three mores” - more mature institutions, more precise enforcement, and more efficient coordination - China’s antitrust enforcement is rapidly shifting from “high-intensity pressure” to “high-quality development”, continuing to safeguard a fair, just, and predictable competitive ecosystem.