China’s SAMR Releases Merger Control Review Data for the First Half of 2026
Published 19 July 2026
Yu Du
On 16 July 2026, China’s State Administration for Market Regulation (SAMR) released data on its merger control review activities during the first half of 2026. SAMR concluded its review of 298 concentrations of undertakings during the period. Of these, 283 transactions were cleared unconditionally, 12 notifications were withdrawn by the notifying parties after formal acceptance, two transactions were approved subject to restrictive conditions, and one transaction was prohibited.
The data indicate that investment activity was particularly strong in manufacturing, electricity, heat, gas and water production and supply, transportation, financial services and real estate.
Review Outcomes and Case Types
Of the 283 transactions cleared unconditionally, 257 were reviewed under the simplified procedure, representing approximately 90.8% of all unconditional clearances.
SAMR completed the review of 251 cases during the preliminary review period—that is, within 30 days after formal acceptance—without initiating a further review. These cases represented approximately 88.7% of all unconditional clearances. A further 32 cases were cleared during the further review period.
The figures indicate that the simplified procedure and clearance during the preliminary review period continued to account for the substantial majority of unconditional merger approvals.
Transaction Values
The aggregate transaction value of the concentrations cleared unconditionally exceeded RMB 2.23 trillion.
Among these transactions:
35 had a transaction value of RMB 10 billion or more, representing approximately 12.4%; 83 had a transaction value between RMB 1 billion and RMB 10 billion, representing approximately 29.3%; and 74 had a transaction value between RMB 100 million and RMB 1 billion, representing approximately 26.1%.
Domestic and Cross-Border Transactions
Transactions between domestic enterprises accounted for the largest proportion of unconditional clearances. Specifically:
158 transactions were between domestic enterprises, representing approximately 55.8%; 89 transactions were between overseas enterprises, representing approximately 31.4%; and 36 transactions involved both domestic and overseas enterprises, representing approximately 12.7%.
The parties participating in the reviewed transactions came from approximately 30 countries and regions. Overseas enterprises involved in the concentrations were principally from Japan, the United States, Singapore, the United Kingdom, South Korea and France.
Within China, Beijing, Shanghai, Guangdong, Zhejiang and Shandong were the five leading provincial-level jurisdictions by number of participating enterprises.
Participation by Different Types of Enterprise
The reviewed transactions involved enterprises under a range of ownership structures. A total of 143 concentrations involved state-owned enterprises, representing approximately 50.5% of unconditional clearances. A further 102 involved privately owned enterprises, representing approximately 36.0%, while 117 involved foreign-invested enterprises, representing approximately 41.3%.
Industry Distribution
Manufacturing was the most active sector, accounting for 105 concentrations, or approximately 37.1% of unconditional clearances.
Other sectors with comparatively high levels of transaction activity included:
electricity, heat, gas and water production and supply: 32 transactions; transportation: 25 transactions; financial services: 22 transactions; real estate: 21 transactions; and wholesale and retail: 17 transactions.
Within manufacturing, the chemical raw materials and chemical products sector and the automobile manufacturing sector each accounted for 17 transactions. Each represented approximately 16.2% of manufacturing transactions.
Other active manufacturing segments included electrical machinery and equipment, rubber and plastic products, computers, communications and other electronic equipment, petroleum, coal and other fuel processing, and general-purpose equipment manufacturing.
Transaction Structures and Competitive Relationships
Horizontal concentrations involving competitors accounted for 182 transactions, representing approximately 64.3% of unconditional clearances. Vertical concentrations involving enterprises at different levels of the supply chain accounted for 120 transactions, or approximately 42.4%, while conglomerate concentrations accounted for 69 transactions, or approximately 24.4%.
In terms of transaction structure:
156 concentrations were implemented through acquisitions of equity interests, representing approximately 55.1%; 122 involved the establishment of joint ventures, representing approximately 43.1%; and seven involved mergers or acquisitions of assets.
The categories relating to competitive relationships may overlap, as a single transaction may have horizontal, vertical and conglomerate dimensions.
Comment
The statistics confirm that most notified transactions continue to obtain unconditional clearance, with the simplified procedure and preliminary review period providing a relatively efficient route for transactions that do not raise material competition concerns. Nevertheless, the withdrawal of 12 notifications, together with two conditional approvals and one prohibition, demonstrates that substantive merger control risk remains significant in transactions involving concentrated markets, close competitors, important supply relationships or strategically sensitive sectors.
Parties contemplating transactions with a China nexus should assess filing obligations and potential competition concerns at an early stage. Particular attention should be paid to market definition, market shares, horizontal and vertical overlaps, access to key inputs and customers, and the consistency of China filing strategies with merger control submissions in other jurisdictions. Transaction documents and timetables should also provide sufficient flexibility for information requests, an extended review, potential remedies or, in higher-risk cases, the possibility that clearance may not be obtained.
The data indicate that investment activity was particularly strong in manufacturing, electricity, heat, gas and water production and supply, transportation, financial services and real estate.
Review Outcomes and Case Types
Of the 283 transactions cleared unconditionally, 257 were reviewed under the simplified procedure, representing approximately 90.8% of all unconditional clearances.
SAMR completed the review of 251 cases during the preliminary review period—that is, within 30 days after formal acceptance—without initiating a further review. These cases represented approximately 88.7% of all unconditional clearances. A further 32 cases were cleared during the further review period.
The figures indicate that the simplified procedure and clearance during the preliminary review period continued to account for the substantial majority of unconditional merger approvals.
Transaction Values
The aggregate transaction value of the concentrations cleared unconditionally exceeded RMB 2.23 trillion.
Among these transactions:
35 had a transaction value of RMB 10 billion or more, representing approximately 12.4%; 83 had a transaction value between RMB 1 billion and RMB 10 billion, representing approximately 29.3%; and 74 had a transaction value between RMB 100 million and RMB 1 billion, representing approximately 26.1%.
Domestic and Cross-Border Transactions
Transactions between domestic enterprises accounted for the largest proportion of unconditional clearances. Specifically:
158 transactions were between domestic enterprises, representing approximately 55.8%; 89 transactions were between overseas enterprises, representing approximately 31.4%; and 36 transactions involved both domestic and overseas enterprises, representing approximately 12.7%.
The parties participating in the reviewed transactions came from approximately 30 countries and regions. Overseas enterprises involved in the concentrations were principally from Japan, the United States, Singapore, the United Kingdom, South Korea and France.
Within China, Beijing, Shanghai, Guangdong, Zhejiang and Shandong were the five leading provincial-level jurisdictions by number of participating enterprises.
Participation by Different Types of Enterprise
The reviewed transactions involved enterprises under a range of ownership structures. A total of 143 concentrations involved state-owned enterprises, representing approximately 50.5% of unconditional clearances. A further 102 involved privately owned enterprises, representing approximately 36.0%, while 117 involved foreign-invested enterprises, representing approximately 41.3%.
Industry Distribution
Manufacturing was the most active sector, accounting for 105 concentrations, or approximately 37.1% of unconditional clearances.
Other sectors with comparatively high levels of transaction activity included:
electricity, heat, gas and water production and supply: 32 transactions; transportation: 25 transactions; financial services: 22 transactions; real estate: 21 transactions; and wholesale and retail: 17 transactions.
Within manufacturing, the chemical raw materials and chemical products sector and the automobile manufacturing sector each accounted for 17 transactions. Each represented approximately 16.2% of manufacturing transactions.
Other active manufacturing segments included electrical machinery and equipment, rubber and plastic products, computers, communications and other electronic equipment, petroleum, coal and other fuel processing, and general-purpose equipment manufacturing.
Transaction Structures and Competitive Relationships
Horizontal concentrations involving competitors accounted for 182 transactions, representing approximately 64.3% of unconditional clearances. Vertical concentrations involving enterprises at different levels of the supply chain accounted for 120 transactions, or approximately 42.4%, while conglomerate concentrations accounted for 69 transactions, or approximately 24.4%.
In terms of transaction structure:
156 concentrations were implemented through acquisitions of equity interests, representing approximately 55.1%; 122 involved the establishment of joint ventures, representing approximately 43.1%; and seven involved mergers or acquisitions of assets.
The categories relating to competitive relationships may overlap, as a single transaction may have horizontal, vertical and conglomerate dimensions.
Comment
The statistics confirm that most notified transactions continue to obtain unconditional clearance, with the simplified procedure and preliminary review period providing a relatively efficient route for transactions that do not raise material competition concerns. Nevertheless, the withdrawal of 12 notifications, together with two conditional approvals and one prohibition, demonstrates that substantive merger control risk remains significant in transactions involving concentrated markets, close competitors, important supply relationships or strategically sensitive sectors.
Parties contemplating transactions with a China nexus should assess filing obligations and potential competition concerns at an early stage. Particular attention should be paid to market definition, market shares, horizontal and vertical overlaps, access to key inputs and customers, and the consistency of China filing strategies with merger control submissions in other jurisdictions. Transaction documents and timetables should also provide sufficient flexibility for information requests, an extended review, potential remedies or, in higher-risk cases, the possibility that clearance may not be obtained.