In August 2020, the long-anticipated Antitrust Guidelines for
the Automobile Industry ("the Guidelines") finally lifted
its veil in the book Collection of Antitrust Regulations and
Guidelines 2019 authored by the Anti-Monopoly Bureau of China's
State Administration for Market Regulation ("SAMR"). It
has been four years since its last draft for public comments, and
though its validity is still in question, the Guidelines shows the
attitude of antitrust authorities on automotive issues and sheds
light on antitrust compliance in the automobile industry.
I. The Battle against Automotive Monopoly
The automobile industry is a critical component of economic
growth in China and is heavily regulated. Back in 2005, to regulate
the distribution of automobiles, China applied measures1
to promote the 4S model and required the selling of automobiles to
be conducted solely by authorized dealers in single brand stores
("4S stores") that provided the full service of
