French Competition Enforcement in the New EU Paradigm

Like in the United States, competition enforcement in Europe is in flux. The European Commission has appointed new leadership (Teresa Ribera) and set new policy directives.  While one could not be blamed for focusing all attention on Brussels and Washington, DC, the Member States’ national competition authorities continue to play major roles in enforcing the law and in setting policy. 

Among those key authorities is France’s Autorité de la concurrence (French Competition Authority or FCA), led by President Benoît Cœuré. In recent statements and interviews, Cœuré has signaled his alignment with the goals of DG Comp and the Draghi Report. For example, he endorsed leveraging an “economic progress” provision in French merger law to make way for European “champions.” 

Last year, the FCA unconditionally cleared 97 percent of the transactions it reviewed (98.5 percent in 2023), raising concerns of needless administrative burden.  The French National Assembly is considering a bill that would increase the default merger review thresholds by tens of millions of Euros, reducing the number of transactions the FCA reviews each year.  

Recent decisions on the mergers front include unconditional clearances of the following transactions:

• LDC Group/Pierre Martinet Group: The FCA unconditionally cleared Lambert Dodard Chancereul (LDC) Group’s acquisition of Pierre Martinet in April 2025 after a one-month investigation. LDC Group is a major player in the poultry sector of the French agrifood industry. Pierre Martinet Group specializes in the manufacture and marketing of fresh delicatessen salads and other delicatessen products. According to an LDC press release, the transaction “enables LDC to be present in 70% of the product families in supermarket and hypermarket convenience food departments” in France. The FCA analyzed horizontal overlaps, vertical effects, and potential bundling/conglomerate concerns but ultimately ruled out any risk of harm to competition.
• IPSOS/XPage Group: The FCA unconditionally cleared IPSOS’s acquisition of XPage Group in June 2025 after a one-month investigation. IPSOS specializes in polls, surveys, and market research. XPage Group is the parent company of the BVA group, which is also active in the market research sector. The FCA’s investigation focused on customized market research services that both firms offered and found that, “[w]hatever market definition used, the combined market share of the parties... is below 25%, a threshold below which the markets concerned are presumed not to be affected.” In a press release IPSOS celebrated the approval and said it would allow IPSOS to strengthen its European presence and compete globally. 
• Les Crudettes/Bonduelle Group: The FCA unconditionally cleared Les Crudettes’s acquisition of Bonduelle Frais France. Les Crudettes and Bonduelle Frais France were “two large, well-known” French operators active in the processing and packaging of ready-to-use salad leaves for supermarkets and the food service industry. The FCA examined both upstream effects on the salad leaf market and downstream effects on supermarkets and found that low barriers to entry and other European competitors ruled out any risk of harm to competition.

Despite these clearances, the FCA is hardly retreating from merger enforcement:

• The FCA began a public consultation on how best to challenge below-threshold transactions that still threaten competition, like “killer” pharmaceutical or technology acquisitions that have recently concerned DG Comp. In this regard, Cœuré lamented the loss of the Article 22 referral mechanism after the European Court of Justice’s (ECJ’s) Illumina/Grail ruling and has expressed support for French national call-in powers like those the Italian Competition Authority used to refer Nvidia’s acquisition of Run:ai to the EC late last year.  (Although that acquisition was eventually cleared, Nvidia has brought a case against the EC that will decide on the propriety of EC referrals based on national call-in powers.)
• Cœuré expressed his ambition for increased collaboration between international competition authorities, including with the U.S. enforcers at DOJ and the FTC.  Indeed, it seems possible that there is even closer alignment between the FCA and the Trump Administration than there had been between the FCA and the Biden Administration, with a focus on coordination and an openness to remedies.
• Following recent criticism of the Digital Markets Act by Chairman Ferguson of the Federal Trade Commission, Cœuré reaffirmed his support for Act.  While the Digital Markets Act is enforced at the EC level, the FCA has several ongoing probes into U.S. technology companies and recently fined Apple €150 million for abusing its dominant position in mobile app advertising.
• Last month, the FCA issued its first standalone decision targeting no-poach agreements, levying €29.5 million in fines on four companies in the engineering, technology consulting, and IT services sectors. The infringing parties were also ordered to publish a summary of the FCA’s decision—including on LinkedIn—underlining the reputational and legal risks associated with no-poach agreements.

We look forward to monitoring competition law developments in France and across the European Union as we work with our clients in the U.S. and abroad.