CHINA Trends and Developments Contributed by: Wei Yingling, JunHe LLP
trolled JV in the district to operate a bottled LPG pro - curement, storage and distribution station, allowing the five companies to exit the market. This transac - tion did not meet the turnover threshold, but the par - ties voluntarily submitted a filing to the SAMR. Upon review, the SAMR found that the JV could obtain control over the bottled LPG market in Nanhai district (with a market share of over 60%) and could facilitate co-ordination in the relevant market, potentially lead - ing to price increases. The SAMR’s decision in the Foshan JV case, and the Wuhan Yongtong/Huatai Pharmaceutical case echo the domestic antitrust enforcement priority which is focused on the sectors that affect people’s livelihoods the most (including pharmaceuticals, public utilities, mobile communications, civil-use explosives, and transportation). In the foreseeable future, the liveli - hood sectors will remain the major enforcement focus of China’s regulator, and will be subject to heightened merger review scrutiny. Other Developments in China’s Merger Control Regime Further expansion of the local delegation programme On 1 August 2022, the SAMR launched a pilot pro - gramme, delegating part of its merger review power for short form filings to its provincial branches (“Pro - vincial AMRs”) in Beijing, Shanghai, Guangdong, Chongqing and Shaanxi for three years (ending on 31 July 2025). As disclosed by the SAMR in a press conference dated 15 August 2025, during the three years since the local pilot programme was introduced, Provincial AMRs have completed reviews of a total of 1,162 merger filings, with average acceptance time of 16.9 days and review time of 17.4 days in line with the internal requirement of “20+20”.
Due to such positive results, the SAMR announced on 31 July 2025 the conversion of the pilot programme into a formal delegation, effective from 1 August 2025. Furthermore, on 19 March 2026, the SAMR announced further developments in the programme by delegat - ing certain long form filings to its local arms, as well as expanding the scope of delegation to three more Provincial AMRs in Liaoning, Zhejiang, and Sichuan Provinces. This improved programme will take effect on 1 August 2026. It is expected that after further expansion of the local delegation programme, merger control review in China will be conducted in a more efficient way. Issuance of specifications for notification of concentration of undertakings On 26 September 2025, the SAMR issued the Speci - fications for Notification of Concentration of Under - takings (the “Notification Specifications”) as the first national standard, which consolidates several guid - ance documents into a unified guidebook. The Noti - fication Specifications contain regulations regarding turnover thresholds, applicable filing procedures, information/document requirements in merger filings, and review procedures, etc, providing a clear-cut, one-stop practical guide to merger filing in China. Conclusion China’s merger control regime has continued to evolve over the past years, reflecting the regulator’s dual objectives of safeguarding competition and support - ing broader policy goals. On the one hand, regula - tors are increasingly attentive to high-profile deals in strategic and sensitive sectors. On the other hand, the review for merger filings with no competition con - cern is becoming more streamlined and efficient. For deal parties, particularly those in sensitive sectors, the message is clear: early risk assessment, high-quality document preparation, and proactive engagement with the SAMR remain essential.
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