Commission européenn e, DG COMP MERGER REGISTRY, 1049 Bruxelles, BELGIQUE  
Europese Commissie, DG COMP MERGER REGISTRY, 1049 Brussel,   BELGIË  
 
Tel: +32 229 -91111. Fax: +32 229 -64301. E -mail: COMP -MERGER -REGISTRY@ec.europa.eu .  EUROPEAN COMMISSION  
 
 
 
 
 
Brussels, 13.5.2019  
C(2019 ) 3722 final  
PUBLIC VERSION  
 
To the notifying party  
Subject : Case M.9293 – ICONEX/HANSOL DENMARK/R+S GROUP  
Commission decision pursuant to Article 6(1)(b) of Council Regulation 
No 139/20041 and Article 57 of the Agreement on the European Economic 
Area2 
Dear Sir or Madam,  
(1) On 1 April 2019 , the European Commission received notification of a proposed 
concentration pursuant to Article 4 of the Merger Regulation by which Iconex LLC 
(“Iconex” , of the United States of America ) acquire s within the meaning of Article 
3(1)(b) of the Merger Regulation sole control of the whole of Hansol Denmark 
ApS and all subsidiar ies, including  Schades A/S (“Hansol Denmark ”, of Denmark)  
and R+S Group Gmb H (“R+S Group”, of Germany) , by way of purchase of shares  
(the “Transaction”).3 Iconex is designated hereinafter as the “Notifying Party”.  
Hansol Denmark  and R+S Group  are referred to together as the “Target 
Companies ”. Iconex, Hansol Denmark and R+S Group  are collectively referred to 
as the “Parties ”. 
                                                 
1  OJ L 24, 29.1.2004, p. 1 (the 'Merger Regulation '). With effect from 1 December 2009,  the Treaty on the 
Functioning of the European Union ( 'TFEU ') has introduced certain changes, such as the replacement of  
'Commu nity' by 'Union ' and 'common market ' by 'internal market '. The terminology of the TFEU will be 
used throughout this decision.  
2  OJ L 1, 3.1.1994, p. 3 (the 'EEA Agreement').  
3  Publication in the Official Journal of the European Union No C 132 , 9.4.2019 , p. 46.  
In the published version of this decision, 
some information has been omitted 
pursuant to Article 17(2) of Council 
Regulation (EC) No 139/2004 
concerning non -disclosure of business 
secrets and other  confidential 
information. The omissions are shown 
thus […] . Where possible the 
information omitted has been replaced by 
ranges of figures or a general description.  
2 (2) This concentration was referred to the Commission by Germany on 7 February 
2019  pursuant to Article 22(3)  of the Merger Regulation (the “Referral Request” ). 
The Referral Request was subsequently joined by France. The Commission 
accepted the referral by decision of 15 March 2019.  
(3) The UK  had initially also joined the Referral Request bu t eventually withdrew it s 
request  on 13 March 2019.  The Competition and Markets Authority (the “CMA”) 
has jurisdiction over the UK part of the Transaction.  
1. THE PARTIES  & THE OPERATION  
(4) Iconex  produces and sells lightweight thermal paper (“LWTP”) for printer 
consumables, labels and receipts. It offers products such as paper receipts and 
thermal printing paper receipts, supply ch ain management labels, shelf marking 
labels, combined receipt and adhesive labels, thermal labels and variable pre -
printed barcodes . It serves retail and wholesale trade, manufacturing, and 
transportation markets, banks and credit unions and eating and dri nking places. 
Iconex is ultimately majority owned by Atlas Holdings LLC, an industrial holding 
company whose portfolio includes manufacturers and wholesalers active in the 
packaging, pulp, paper and logistics sector.  
(5) Hansol  Denmark  converts and sells LWTP for various end -products including 
receipt paper rolls for cash registers and self -adhesive labels, for customers in  
office stationary, distributors in food and non -food retail, and logistics.  
(6) The R+S Group  is a subsidiar y of the Hansol Group and  is also active in  
converting and selling LWTP  for receipt and ticket applications, as well as self -
adhesive labels.  
(7) Pursuant  to a share purchase agreement of 5 November 2018, Iconex will acquire 
the total share capital of the Target Companies, which will therefore be solely 
controlled by Iconex post -Transaction . The Operation therefore constitutes a 
concentration pursuant to Article 3(1)(b) of the Merger Regulation . 
2. EU DIMENSION  
(8) The Transaction does not meet the thresholds set out in t he Merger Regulation and 
therefore it does not have an EU dimension. However, the Commission has 
jurisdiction over it following the decision of 15 March 2019 accepting the Referral 
Request . 
3. MARKET DEFINITION  
 Converted rolls vs converted labels  3.1
(9) The Parties produce and sell converted rolls  and converted labels . 
(10) Converted rolls are LWTP rolls which have bee n “converted” (slit) from LWTP 
jumbo r olls. Converted labels are LWTP self -adhesive label rolls which have also 
been “converted” (slit) from LWTP  jumbo roll s. 
3 (11) The Parties buy large LWTP jumbo rolls from suppliers, cut them into smaller rolls 
and sell those rolls to resellers and end -users, a process known as “converting”. 
Sometimes, prior to cutting the LWTP jumbo rolls, converters print the customer’s 
logo o r other requested information onto the rolls.4 
(12) Converted rolls are used in point of sale (“POS”) devices (including credit card 
machines) and automated teller machines (“ATMs”) (and in the case of the Target 
Companies, certain kinds of tickets).  
(13) Converted labels are used in the transportation of goods for bar codes and 
addresses. Converted labels have an adhesive that is either applied by a third party 
prior to the converter purchasing the raw material or is applied by the converter in -
house.  
(14) The Commission  has not previously considered a market for the supply of 
converted rolls and converted labels.  
3.1.1.  The Notifying Party’s views  
(15) The Notifying Party submits that  converted rolls and converted labels constitute 
different product markets since although the production process  is the same  for 
both products , the machines used are different . 
3.1.2.  The Commission’s assessment  
(16) The market investigation carried out by the Commission indicated that the vast 
majority of customers do not use converted rolls and converted la bels 
interchangeably and confirmed that there is no supply -side substitutability between 
the two products.5 Customers explained that converted labels and converted rolls 
are used for different purposes and in different printers and they are different types  
of products. For example, converted rolls are used for printing the receipt for the 
customer at the cash desk whereas converted labels contain the necessary 
information for the product to which they are attached.  
(17) In view of the above, the Commission consi ders that for the purpose  of this case 
the market for production and supply of converted labels is separate from the 
market for production and supply of converted rolls.  
(18) Given  the small combined market share of the Parties  (significantly below 5% at 
the EE A level and below 20% at the level of any Member State ), the Commission 
considers that the Transaction does not give rise to serious  doubts as to its 
compatibility with the internal market in relation to the market for  the supply of 
converted labels.  There fore, the market for the supply of converted labels will not 
be further discussed in this decision.  
                                                 
4  The most common thermal paper that is used to produce converted rolls has a thermal coating on only one 
side of the paper (1ST thermal paper). As the paper passes through the printer, it is thermally printed with 
receipt information on the side t hat is thermally coated. Two -sided (2ST) thermal paper is the one that is 
coated on both sides.  
5  Replies to Question 6 of the Questionnaire Q2 to Customers and Questions 6 -7 of the Questionnaire Q1 to 
Competitors.  
4  Product market  definition  3.2
3.2.1 The Notifying Party’s views  
(19) The Notifying Party submits that  converted rolls have two main variables, namely 
paper thickness/weight  and d imensions (width and length) . Converted rolls are 
supplied to specific customer requirements depending on the exact specifications of 
the printers for which the converted rolls are being supplied.   
(20) The Notifying Party submits that  from a customer point of view , converted rolls  
could be divided into three primary categories  based on their end -use application, 
because different applications require different roll sizes : 
(a) POS rolls are used to provide retail paper receipts at the points of  sale in 
retail s tores  (e.g., supermarkets) . POS rolls are 80mm in width and the paper 
receipts that are printed tend to be longer than th e other categories  of 
converted rolls ;  
(b) Credit card rolls , which are narrower than POS rolls , are typically 57mm in 
width  and shorter , since they are used inside smalle r handheld credit card 
machines ;  
(c) ATM Rolls are typically also 80mm in width, though this can vary depending 
on the size of the printers that are installed in different ATM machines – this 
varies by bank and by country. In general, however, ATM rolls range from 
60mm and 110mm in width, and are usually longer rolls.  
(21) Nevertheless, t he Notifying Party submits that the relevant product market 
comprises all types of converted rolls and no segmentation is appro priate , because 
the machines used to convert the LWTP jumbo rolls into converted rolls can be 
(and are) used to produce products of all dimensions and weights . Thus, all 
suppliers should generally be able to produce all converted roll sizes and do so by 
configuring their machinery appropriately . The Notifying Party also submits that 
no segmentation should be made between 1ST and 2ST  converted rolls  since the 
same machinery is used to produce both types of converted rolls. Therefore, 
according to the Notifyi ng Party, there is a very high level of supply -side 
substitutability in the production and supply of converted rolls.  
3.2.2 The Commission’s  assessment   
(22) The market investigation carried out by the Commission confirms  that the demand -
side substitutability is limi ted as customers require different specifications 
depending on the end -application , and that machine s used by a customer cannot 
process different types of converted rolls due to size requirements .6 
(23) However , as regards supply -side substitutability, the market investigation confirms 
that all suppliers of converted rolls can and do produce all types of converted rolls 
upon request of their customers , including POS rolls, credit card rolls and ATM 
rolls on the one hand and 1ST and 2ST converted rolls on  the other hand .7 
                                                 
6  Replies to Questions 11 and 11.1 of the Questionnaire Q2 to Customers.  
7  Replies to Question 10 of the Questionnaire Q2 to Customers.  
5 (24) In particular, all the competitors that replied  in the Commission’s market 
investigation  indicated that it is technically possible to switch, using the same 
production line, between various types of converted rolls .8 Indeed, c onverters do  
not specialize in the production of certain sizes or weights of converted rolls , and 
the machines used to convert LWTP jumbo rolls can be (and are) used to produce 
products of all dimensions and weights. I t is a matter of adjusting the settings on a 
machi ne to slit, for example, 80mm rolls in place of 57mm rolls. Similarly, the 
different weights of paper used for different applications are all handled by the 
same machines. Moreover, the vast majority of respondents indicated that it is 
economically possibl e to do so.9 Most  competitors that replied in the Commission’s 
market investigation estimated the time needed for switching between various 
types of converted rolls  to be from 30 minutes to a few hours. In particular, a 
respondent to the market investigati on noted that switching between different 
products occurs several times a day and does not entail  high costs.10  
(25) In view of the above , the Commission considers that for the purpose of this case , 
there is an overall market for the production and supply of converted rolls, which 
should not be further segmented according to different types of converted rolls.  
 Geographic market definition  3.3
3.3.1 The Notifying Party’s views  
(26) The Notifying Party submits that the relevant geographic market with regard to the 
markets for the production and supply of converted rolls is at least EEA -wide  for 
the following reasons .  
(27) First, suppliers ship across the whole of Europe to meet customer demand. It is 
unnecessary to have a plant in the customer’s country in order to win business in 
that customer’s country. It is also unnecessary to have a significant sales or support 
presence in the country concerned. The Notifying Party submits that it  supplies 
customers in around 20 coun tries from its plants in France and the UK, while the 
Target Companies supply to customers in over 40 countries from their production 
facilities in Denmark, Germany and the UK.  
(28) Second, the Notifying Party submits that  transport costs are a small percentage  of 
the overall cost and the incremental cost of shipping across longer distances is 
small and in no way prohibitive.  
(29) Third, the Notifying Party submits that  customers can, and do, switch their orders 
to companies located elsewhere in the EEA in the short term and at a negligible 
cost. 
(30) Fourth, converters also supply the EEA market from outside the EEA, including 
from China.  
                                                 
8  Replies to Question 11 of the Questionnaire Q1 to Competitors.  
9  Replies to Question 12 of the Questionnaire Q1 to Competitors.  
10  Reply to Question 12.4  of the Questionnaire Q1 to Competitors.  
6 3.3.2 The Commission’s assessment  
(31) Based on the results of the market investigation , the geographic scope of the 
market for the supply of converted rolls  is at least  national and in fact likely 
broader  than national ( possibly with the exception of the UK) , but most probably  
not encompassing  the entirety  of the EEA.  
(32) The market investigation revealed that half of the customers that replied so urce 
converted rolls at national level. The rest of the customers  source either at EEA 
level or globally.11  
(33) Among the competitors that replied, 25% supply converted rolls only nationally. 
The rest of the competitors  indicated that they supply converted rol ls further away 
(most of them at EEA level and even globally).12 
(34) As regards the possibility of sourcing from outside the EEA, a vast majority of the 
competitors that replied indicated that there are imports of converted rolls into the 
EEA from outside the E EA (mostly from Turkey, China and South Korea)13.  
(35) Some customers indicated that there has been “ an increase in offers and supplies 
from Asia & Turkey ” and that imports represented approximately 10% of the total 
supply for converted rolls in the EEA.14 
(36) As regards transport costs, half of the competitors that replied indicated that those 
represent up to 5% of the total value of converted rolls, while the other half 
indicated that they represent between 5 and 10% of the total value  of converted 
rolls.15 A small majority of customers  that replied  indicated that the distance 
between a supplier’s production plant for converted rolls and their own location is 
not important. The rest of the customers  pointed at the importance of distance for 
transportation costs.16 
(37) The market investigation revealed that the majority of customers choose their 
supplier for converted rolls primarily based on the price. The other important 
criteria for customers are quality and delivery time.17 Nearly all customers  that 
source converted  rolls in various countries indicated that prices do not differ more 
than 5% depending on the country.18 
(38) The market investigation showed that the competitive landscape in the UK appears 
to be different from  Continental Europe , mainly because transport  costs  are higher  
and there are risks  associated to the exchange rate , as a result of which  UK 
customers tend to prefer  UK suppliers .19  
                                                 
11  Replies to Question 16 of the Questionnaire Q2 to Customers.  
12  Replies to Question 18 of the Questionnaire Q1 to Competitors.  
13  Replies to Question 23 of the Questionnaire Q1 to Competitors.  
14  Replies to Quest ions 22 and 22.1 of the Questionnaire Q2 to Customers.  
15  Replies to Question 19 of the Questionnaire Q1 to Competitors.  
16  Replies to Questions 18 and 18.1 of the Questionnaire Q2 to Customers.  
17  Replies to Question 21 and 21.1 of the Questionnaire Q2 to  Customers.  
18  Replies to Question 20 of the Questionnaire Q2 to Customers.  
19  Replies to Questions 22 and 22.1 of the Questionnaire Q1 to Competitors.  
7 (39) Indeed, while , most customers elsewhere in the EEA did not report any national 
preference , a majority of UK customers that replied indicated a clear preference for 
UK-based suppliers because transports costs are higher and delivery time  is longer 
when sourcing  from  outside the UK .20  
(40) The results from the market investigation are inconclusive as regards  the exact  
scope of the geographic market. In view of the above, and for the present case, it 
can be concluded  that the geographic market for converted rolls is at least  national 
and possibly wider  in scope  as the ease to trade cross -border at least in Continental 
Europe, the insignificant price differences across countries,  and the ability for 
customers to source from abroad and even from outside the EEA  point to  a market  
wider than national  (possibly with the exception of the UK) . However, s ince a 
significant number  of suppliers are not active at EEA level, and  certain customers 
do not source at EEA level, the geographic scope of the market is probably  
narrower than EEA -wide.21  
(41) In any event, the Commission considers that the exact delineation of the relevant 
market i n this case may be left open , as the Transaction does not raise serious 
doubts as to its compatibility with the internal market at any geographic  level . For 
the purpose of this decision, the competitive assessment will be conducted at the 
narrowest level, the national level, as well as at the EEA level.  
4. COMPETITIVE ASSESSMEN T 
(42) The Transaction leads to a horizontally affected market  in the supply of converted 
rolls at the EEA level, and in France and in Germany  if the relevant geographical 
market would be defined as  national .22  
(43) There are no vertical links arising from the Transaction.23  
4.1 The Notifying Party’s views  
(44) The Notifying Party submits that the Transaction would not give rise to any 
competition concerns for the following reasons.  
(45) First, the Parties’ market shares are moderate and the market for the supply of 
converted rolls is highly competitive with a number of  large competitors , such as 
the German  company Veit, the Spanish companies Fesa and IS Botella, the Italian 
company Rotoli ficio Bergamasco as well as the Polish supplier Omeko.  In 
addition, there are larger suppliers in neighbouring countries, such as  Umur in 
Turkey, which could increase imports into the EEA.  
                                                 
20  Replies to Questions 16.1, 16.3 and 18.1 of the Questionnaire Q2 to Customers.  
21  Replies to Question  29 of the Questionnaire Q2 to Customers.  
22  For completeness, the Transaction does not result in any other affected markets at national level, apart 
from within the UK, which will be assessed by the CMA (see also paragraph (3)) and will not be 
discussed in this decision.  
23  At present , the Target Companies are ultimately owned by Hansol Paper Co. Ltd, which produces LWTP 
jumbo rolls, used as an input for the producti on of conve rted rolls and converted labels. However, Iconex 
will not acquire these production activities.  Therefore, not only the Transaction will not lead to vertical 
links, but it will also break such links.  
8 (46) These  competitors compete for orders throughout  the EEA . In additi on to larger 
competitors , there are also many competitors that compete on a more regional basis 
and together exert a competitive restraint throughout the EEA to win both small 
and large contracts. A number of smaller suppliers supply large customers and it  is 
not rare that smaller suppliers win business for large customers away from larger 
suppliers.24 
(47) The Notifying Party also submits that converted rolls are a commodity product, and 
since all competitors use the same input with little transformation applied, all 
converted roll suppliers can easily meet any customer specifications.  
(48) The Notifying Party further submits that there is significant spare capacity in the 
converting business in Europe, and competitors could increase production and 
supply of co nverted rolls easily.   
(49) In addition, barriers to entry and expansion in the market for the supply of 
converted rolls are very low. This is because machinery capital costs are modest 
and highly skilled workforce is not required to operate slitting . In addit ion, t here 
are no legal or regulatory barriers to entry . 
4.2 The Commission’s assessment  
Low product differentiation  
(50) The results of the market investigation confirm that c onverted rolls  are a 
commodity product , and that there is no discernible difference in th e quality of 
paper which forms the input . The vast majority of the customers that replied to the 
market investigation indicated that the most important criterion to select a supplier 
of converted rolls is price .25 As explained in paragraphs (23) - (25), all competitors 
use the same input and therefore any standards specified by customers in contrac ts 
can be easily met by all suppliers.  
(51) This was supported by the market investigation. The majority of customers that 
replied mentioned a number of converted rolls suppliers and did not see the Parties 
as the closest competitors.26 
Spare c apacity  
(52) All the co mpetitors that repli ed to the market investigation indicat ed that they have 
spare capacity and could easily add new working shifts.27 The majority of 
competitors even confirmed  that they would be able to increase capacity under 
their current shift pattern ( i.e., without adding new shifts).28 
  
                                                 
24  Form CO, paragraph  177. 
25  Replies to Ques tion 36 of the Questionnaire Q 2 to Customers.  
26  Replies to Question 25  of the Questionnaire Q2 to Customers.  
27  Replies to Question 37 of the Questionnaire Q1 to Competitors.  
28  E-mails of competitors  of 12 April 2019, 17 April 2019, 18 April 201 9, 24 April 2019, 25 April 2019 and 
26 April 2019 .  
9 Barriers to entry  
(53) The market investigation revealed that barriers to entry are low. The machinery 
necessary to produce converted rolls can cost as little as approximately EUR 50 
000 – 60 000.29 Moreover, t he presence of a number of small suppliers in this 
market reflects that barriers to entry are not high.  
Sourcing  by customers  
(54) The market investigation showed that customers generally multisource.30 Although 
large customers tend to source from large supplier s as they benefit from economies 
of scale , some large customers source from smaller suppliers . In particular, some 
international customers indicated that they could easily source from smaller 
suppliers and even that they do not differentiate between large and small suppliers.  
31  
Purchase of jumbo rolls 
(55) During the market investigation some competitors raised concerns as to the 
potential increase of bargaining power of the combined entity in its purchases of 
jumbo rolls. However, the Commission considers that  these concerns are not 
substantiated.  
(56) First, unlike the Parties, Hansol Paper Co. Ltd ., (the “ Seller ”) is active in the 
production and supply of jumbo rolls. As such, pre -merger there is a vertical link 
between the Seller and the Target Companies. The Transaction will break this 
vertical link and there fore, in principle,  there will be more competition in the 
purchasing of jumbo rolls. 
(57) Second, the Parties ’ purchases of jumbo rolls only account for [0-5]% of the total 
supply of jumbo rolls worldwide . It is therefore not likely that the Transaction will 
give rise to competition concerns  regarding the purchasing of jumbo rolls. 
4.2.1 Horizontal overlap in converted  rolls at EEA -level  
(58) On an overall market for converted rolls - encompassing all types of converted rolls 
- the Notifying Party estimates  that the Parties’ combined market share at  EEA 
level  is [20-30]% (Iconex: [0-5]%, Target Companies: [10-20]%). The Notifying 
Party estimates  that Veit has a market share of [10-20]% at the EEA level, and that 
a long tail of smaller converted roll suppliers accounts for the rest of the market .  
(59) In the course of the market investigation some documents pointed to a combined 
market share of the Parties [significantly higher] . However, the Commission 
contacted various market participants and trade bodies to gather additional data on 
sales figures and the size of the market . The results of the market investigation are 
more  consistent with the estimates of the market size and market shares provided 
by the Notifying Party . Therefore, the Parties’ combined position at EEA level , as 
well as  the increment resulting from the Transaction , are modest.  
                                                 
29  Replies to Question 41 of the Questionnaire Q1 to Competitors.  
30  Replies to Question 30 of the Questionnaire Q2 to Customers.  
31  Replies to Question 35 of the Questionnaire Q2 to Customers.  
10 (60) The market investigation revealed that there is low product differentiation  in 
respect of converted rolls, there is spare capacity in the industry, barriers to entry 
are low, and customers generally multisource (see paragraphs (50) - (54)).    
(61) In view of the above, the Commission considers that the Transaction does not give 
rise to serious  doubts as to its compatibility with the internal market  and the EEA 
agreement  in relation to the market for the  supply of converted rolls at the EEA 
level.  
4.2.2 Horizontal overlap in converted rolls in France  
(62) In France, the Notifying Party estimates  that the Parties’ combined mar ket share is 
[30-40]% (Iconex: [10-20]%, Target Companies [10-20]%). The Notifying Party 
further  estimates that in France Rolfax and FranceRol have a market share of [5-
10]% each, followed by Veit with a market share of [5-10]%, and by other smaller 
competitors.   
(63) Moreover, the market investigation suggested that imports and exports play an 
important  role in this market. Market participants confirmed that suppliers based in 
Germany, Italy, Spain, Poland and Turkey  (among other c ountries) supply 
converted rolls to French customers.32 In particular, […] converted rolls sold by the 
Target Companies to French customers (amounting to [10-20]% of the French 
market  in terms of sales ) are produced outside France .  
(64) The market investigation also revealed that customers generally multisource. 
Moreover, all suppliers of converted rolls, regardless of their size, compete for 
orders from all types of customers . 
(65) In addition, as ex plained in paragraphs (50) – (53), there is low product 
differentiation  in respect of converted rolls , there is spare capacity in the industry , 
and barriers to entry are low . 
(66) In view of the above, the Commission considers that the Transaction does not give 
rise to serious  doubts as to its compatibility with the internal market  and the EEA 
agreement  in relation to the market for the  supply of converted rolls in France.  
4.2.3 Horizontal overlap in converted rolls in Germany  
(67) In Germany , the Notifying Party estimates  that the Parties’ combined market share 
is [20-30]% (Iconex: [0-5]%; Target Companies: [20-30]%). The Notifying Party 
submits  that in Germany  Veit has a market share of [30-40]%, followed by 
Schneider and Blumberg with a market share of [5-10]% each , and other smaller 
competitors . 
(68) In the course of the market investigation, a large customer complained  that post-
transaction  there  would be only two suppliers of converted rolls able to meet its 
demand as smaller supplie rs would not be an option  because  they would be  unable 
to meet their whole demand  and are more expensive . However, the majority of 
                                                 
32  E-mails of co mpetitors  of 25 April 2019 .  
11 German customers that replied to the market investigation indicated that they will 
have sufficient alternatives in terms of suppliers post -transaction .33 
(69) Furthermore , most of the  large customers  that replied  indicated that they could 
source at EEA level and even from outside the EEA , and such imports  already 
occur , mainly from Turkey.34 
(70) Moreover , as explained in paragraphs (50) – (54), there is low product 
differentiation  in respect of converted rolls , there is spare capacity in the industry , 
many customers multisource and barriers to entry are low .  
(71) In addition , Iconex presence  in Germany is very limited, accounting for [0-5]% of 
the market for converted rolls in Germany.  
(72) In view of the above, the Com mission considers that the Transaction does not give 
rise to serious  doubts as to its compatibility with the internal market  and the EEA 
agreement  in relation to the market for the  supply of converted rolls in Germany.  
4.2.4 Conclusion  
(73) In view of the above, regardless of whether the geographical market is national, 
EEA -wide or in between, the Commission considers that the Transaction does not 
give rise to serious doubts as to its compatibility with the internal market in relation 
to the market for the  supply of converted rolls.  
5. CONCLUSION  
(74) For the above reasons, the European Commission has decided not to oppose the 
notified operation and to declare it compatible with the internal  market and with the 
EEA Agreement. This decision is adopted in application of Article 6(1)(b) of the 
Merger Regulation and Article 57 of the EEA Agreement . 
For the Commission  
 
 
(Signed)  
Margrethe VESTAGER  
Member of the Commission  
                                                 
33  Replies to Question 3 2 of the Questionnaire Q2 to Customers.  
34  Replies to Question 3 6 of the Questionnaire Q2 to Customers.