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Practices

Scrutiny of joint venture interests in merger control analyses

22 January 2007

On 19th July 2006 the merger between Aggregate Industries and Foster Yeoman was notified to the European Commission. Both parties are based in the UK and active in the supply of aggregates in the South West of England, asphalt in the South West and South East of England and the supply of road surfacing services in Great Britain.

The OFT requested that the Commission refer to it the UK aspect of the merger under Article 9 of the European Community Merger Regulation. The Commission cleared the merger as regards those markets beyond the UK and agreed to the OFT’s request to refer to it the UK aspect of the merger.

The OFT’s concern centred on the parties’ supply of asphalt in the South West and South East of England. In light of the perishability of the product, the OFT divided these regions according to the distance which could confidently be covered in a two hour drive from a plant. Its main concerns were:

  • the risk of coordination between the two remaining major players in a 20 mile radius in Hertford:  Aggregate Industries and Lafarge. In particular, the merger would result in a structural link between Aggregate Industries and Lafarge, the two main players in Hertford which together account for a 90% market share. Prior to the merger, in addition to owning three plants, Lafarge, held a one third stake in capacity allocation at a plant in Hertford. The other two thirds share in this plant was owned by Foster Yeoman and Tarmac (Tarmac being the only other competitor in this area). As a result of the merger between Aggregate Industries and Foster Yeoman, Aggregate Industries would replace Foster Yeoman in the joint venture for this plant. This would therefore create a structural link between the two main competitors in the Hertford area: Aggregate Industries and Lafarge. The OFT was concerned that this link could materially increase the risk of coordination between Aggregate Industries and Lafarge on pricing, output or investment; and
  • the high combined market share of the merging parties in a 20 mile radius in Crawley and a 30 mile radius in Theale (70 – 80% and 40 – 50% respectively), the merging parties being close competitors and the lack of other plants in these areas. 

The OFT announced on 3 January 2007 that it has accepted undertakings from Aggregate Industries to carry out divestments which  resolve the OFT’s concerns listed above. Such acceptance means that the transaction will not be referred to the Competition Commission for a detailed (and lengthy) investigation.

How this could be relevant to you?

If your company is involved in a merger you must be aware that, beyond the scrutiny of the activities of the companies which fall within your company’s group, the OFT will also scrutinise any joint venture interests which your company may have. Whilst such interests may seem a step removed from the activities of a company’s core group, they are of no less interest to the OFT.

The above case also highlights how a small geographic region can constitute a market for competition law purposes. In this case, the issue which was determinative of the geographic market of the supply of asphalt was its perishability (hence the market was a distance which can confidently be covered within a two hour drive from a plant).

For further information, please contact Charles Whiddington.