GREECE Trends and Developments Contributed by: Victoria Mertikopoulou, Ifigeneia Argyri and Maria Paziotopoulou, Kyriakides Georgopoulos Law Firm
Sector inquiries In 2024, the HCC continued the use of sector inquiries as a means of soft enforcement in order to investigate competition conditions in various markets. The aim of these sector inquiries was to detect potential distortions and submit pro - posals to promote competition in these markets. i) Sector inquiry into bank deposits Following HCC Decision 838/2023 pertaining to a horizontal collusion in the banking sector, the HCC launched a sector inquiry into bank depos - its in July 2024. Its aim is to identify market con - ditions prevailing in the sector that may lead to collusion, harming consumer welfare, and also consider its structure and the low interest rates offered by the Greek banks (compared to the Eurozone average). The inquiry is expected to analyse the competi - tive environment, investigate factors contribut - ing to low depositor mobility to alternative pro - viders, and assess the reasons why banks are not offering higher interest rates for deposits. The key objectives include, inter alia, determin - ing the effectiveness of competition between banks, proposing effective competition poli - cies or regulatory measures, and supporting the economic restructuring, innovation, and digi - tal transformation of the sector. Currently, the interim conclusions that will be reached by the HCC ‒ after considering comments on the ques - tionnaires sent to the respective undertakings in November 2024 ‒ are anticipated. ii) Sector inquiry into waste management and recycling ‒ interim report published In the context of broader sustainability consid - erations facing the Greek economy, the HCC launched a sector inquiry into the waste man -
agement and recycling sectors in 2021, consid - ering their economic importance and contribu - tion to sustainable development objectives. In July 2024, the HCC published its interim report, aiming to identify potential competition issues in the industry and focusing (inter alia) on bar - riers to entry, bargaining power, structural links between players, regulatory framework, market practices, and whether the market structure contributes to the possibility of developing co- ordinated or non-coordinated effects. The report highlights several entry barriers, including a costly and time-consuming licensing process and an unclear legislative framework. Moreover, it indicates that market concentration varies, with some streams dominated by a single Alternative Management System (AMS), which may engage in anti-competitive practices such as refusing to co-operate or imposing exclusive obligations. Finally, the bureaucratic and costly operating framework hinders healthy competition, as insuf - ficient supervision allows non-compliant provid - ers to gain unfair advantages. Following the pub - lication of the interim report, the HCC initiated a public consultation in September 2024, inviting stakeholders to share views and comments to be addressed in the final report. Market mapping studies The HCC has conducted market mapping stud - ies to proactively analyse the competitive con - ditions in key sectors for Greek consumers to inform the exercise of its powers. In view of concerns regarding inflation and price hikes in respect of basic consumer goods, and against the backdrop of legislative measures controlling businesses’ profit margins on consumer goods necessary for consumers’ subsistence and hygiene to prevent unfair profiteering (Article
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