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ARTICLE · 26 MARCH 2025

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EU Penalizes RPM And Other Vertical Conduct Violations

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The level of fines imposed for infringements relating to vertical and other non-cartel conduct increased ten-fold in 2024, reversing a trend of decline in recent years.

European UnionAntitrust/Competition Law
A&O Shearman
A&O Shearman
Thomas Masterman
Thomas Masterman
Imogen Carr
Imogen Carr
Emily Bourne
Emily Bourne
Joey Chong
Joey Chong
Alexander Westin-Hardy
Alexander Westin-Hardy
Anudeep Bhattacharyya
Anudeep Bhattacharyya
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The level of fines imposed for infringements relating to vertical and other non-cartel conduct increased ten-fold in 2024, reversing a trend of decline in recent years. This rise can be attributed in part to the overall number of decisions recorded in our dataset (101) being the highest in recent years.

The uptick in fines has coincided with authorities taking a less conciliatory approach when penalizing infringements—just 38% of decisions in 2024 involved settlement or other forms of cooperation, down from 61% in 2023 and 42% in 2022.

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Key statistics

The European Commission (EC) recorded its highest level of fines against vertical and other non-cartel conduct in 2024 for over four years, in stark contrast to 2023 where the EC did not record any decisions.The most significant fine, of over EUR330 million, was imposed on Mondelēz International(the producer of Oreo cookies, Cadbury's Dairy Milk, and Toblerone) for hindering the cross-border trade of chocolate,

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