China's Merger Review Guidelines: A Comparative Look Against The EU Framework (Non-Horizontal)

In December 2025, China's State Administration for Market Regulation (SAMR) released the final Guidelines for the Review of Non-Horizontal Concentrations ("SAMR's Non-Horizontal Guidelines"). This follows the issuance of the final Guidelines for the Review of Horizontal Concentrations ("Horizontal Guidelines") published a year earlier, in December 2024. Both sets of guidelines complement other recent reforms to China's merger control regime, including higher filing thresholds and more streamlined procedures.

The implementation of these reforms and the publication of the guidelines underscore SAMR's continued commitment to enhancing transparency in merger reviews and offering clearer guidance to undertakings, legal practitioners, and competition authorities.