向欧盟委员会提交的关于合并监管的意见（英）

COMMENTS OF ITIF to the European CommissionBrussels, Belgium In the Matter of:) Sept 3, 2025 REVIEW MERGER GUIDELINES Fields marked with * are mandatory. Introduction I. Introduction 1.1 Background and aim of the questionnaire In line with the objectives of the EU Treaties, EU competition rules aim to enable a dynamic and well-functioning internal market, by making sure all businesses are able to compete effectively, and to prevent Article 2 of the EU Merger Regulation requires the Commission to assess whether a merger would“significantly impede effective competition, in particular as a result of the creation or strengthening of a Mergers can involve companies that are actual or potential competitors on the same market (“horizontalmergers”) or companies that are active on different levels of the supply chain (e.g. one supplies the other with Like all competition tools, EU merger control needs to remain fit for purpose, as market realities changearound it. The objective of merger control, in accordance with the EU Merger Regulation, remains valid and under the Merger Regulation has equally evolved, to capture those new realities and protect competition withinthem. In all these years, there has also been relevant case law of the Court of Justice, which has informed the In light of these factors, which apply equally to both the Horizontal and Non-Horizontal Merger Guidelines, theCommission is proposing to revise both sets of guidelines in a holistic exercise. The goal is to ensure theGuidelines are up-to-date in order to allow the Commission to continue to protect competition under the We welcome your input on how the Commission should assess mergers within the framework of the EU This questionnaire aims at collecting facts, views and evidence from the public and other stakeholders that willhelp the Commission determine how to adequately update its Guidelines. It represents one of the methods of The Commission will summarise the results of this consultation in a report, which will be published on the Nothing in this questionnaire should be interpreted as stating an official position of the European Commission. 1.2 Submission of your contribution Please reply to this public consultation by responding to the questionnaire online. You may include documents You are not obliged to complete the questionnaire all at once; you have the option of saving your responses asa "draft" and finalising them later. To do this you should click on "Save as Draft" and save the new link that you If you have any questions, you can contact us via the following functional mailbox:.COMP MG REVIEWIn case of technical problems, please contact the Commission's CENTRAL HELPDESK. 1.3 Duration of the consultation The consultation on this questionnaire will be open for 16 weeks. About you Language of my contribution* BulgarianCroatianCzechDanishDutchEnglish First name Surname Email (this won't be published) kiss.lilla.nora@outlook.com Country of origin Please add your country of origin, or that of your organisation. This list does not represent the official position of the European institutions with regard to the legal status or policy of I am giving my contribution as* Academic/research institutionBusiness associationCompany/business If you are giving your contribution for the company / organisation for which you work,or on behalf of a client, please specify the main function / activity of the company /* Text of 1 to 600 characters will be accepted The Information Technology and Innovation Foundation (“ITIF”) is an independent, non-profit and non-partisanthink tank. ITIF’s mission is to formulate, evaluate, and promote policy solutions that accelerate innovation andboost productivity to spur growth. ITIF strives to provide policymakers around the world with high-quality If you are giving your contribution for the company / organisation for which you work,or on behalf of a client, please indicate in which sector it is active (multiple options* between 1 and 16 choicesMULTIPLE OPTIONS POSSIBLE Agriculture / agri-foodAutomotive Please specify Competition / Antitrust Please specify Please mark the countries where your main business is based. Other If other, please specify Organisation name 255 character(s) maximum Information Technology and Innovation Foundation Organisation size Micro (1 to 9 employees)Small (10 to 49 employees)Medium (50 to 249 employees)Large (250 or more) Transparency register number Check if your organisation is on the transparency register. It's a voluntary database for organisations seeking to 923915716105-08 Has your company/business been the addressee of a Commission decision underArticle 6 or Article 8 of Council Regulation (EC) No 139/2004, or has it been another between 1 and 7 choices No Yes, Article 6.1.(a) decisionYes, Article 6.1(b) decision (simplified procedure)Yes, Article 6.1(b) decision (normal procedure)Yes, Article 6.1(b) in conjunction with Arti