Commission européenne, 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,  31.10.2018   
C(2018 ) 7402 final  
  
 
To the notifying party:  
 
Dear Sir or Madam,  
Subject : Case M.9099 - Jin Jiang/Radisson  
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 
(1) On 28 September 2018 , the European Commission received notification of a 
proposed concentration pursuant to Article 4 of the Merger Regulation , by which 
Jin Jiang International Holdings Co., Ltd ("Jin Jiang", China), a State -owned 
company, intends to acquire  within the meaning of Article 3(1)(b) of the Merger 
Regulation sole control of Radisson Holdings, Inc. ( the United Stat es) and 
Radisson Hospitality AB (Sweden) (together "Radisson"), by way of purchase of 
shares (the "Transaction") .3 Jin Jiang  and Radisson  are designated her einafter as the 
"Parties"  or, in particular when assessing the post -Transaction scenario, the 
"merged entity") . 
                                                 
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 introd uced certain changes, such as the 
replacement of  "Community " 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 Offi cial Journal of the European Union No C 359, 5.10.2018, p. 7.   
PUBLIC VERSION  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omitted has been replaced by ranges of figures or a 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 1. THE  PARTIES  
(2) Jin Jiang is a leading Chinese hospitality and travel group that develops and 
manages hotels in China and the rest of the world. Jin  Jiang operates a wide range 
of hotels, under the brands J.Hotel, Jin Jiang, Metropolo, Jin Jiang Inn, the series of 
brands under Groupe du Louvre, the series of brands under Plateno Group and the 
series of brands under Vienna Hotel. Groupe du Louvre consi sts in particular of the 
European brands Royal Tulip, Golden Tulip, Tulip Inn, Campanile, Première 
Classe and Kyriad and a suite of French independent hotels under Hôtels & 
Préférence.4 The Plateno Group has 17 brands, including in particular the 7 Days 
Premium and H12 brands under which four hotels are operated in Austria.5 As at 
the end of 2017, Jin Jiang owns or manages 6 794 hotels with a total of […] rooms 
located in 68 countries around the world, inclu ding […] hotels with a total of […] 
rooms located in 9 countries in Europe.6 
(3) Jin Jiang is a wholly owned subsidiary of the Shanghai State -owned Assets 
Supervision and Administration Commission ("SASAC"), a subsidiary of the 
Shanghai municipal government. As such , Jin Jiang is a Chinese Stat e-owned 
company. Jin Jiang submits that it is the ultimate parent company of the Jin Jiang 
group, and acts independently from all other entities owned by Shanghai SASAC 
and from all other Chinese State -owned enterprises, be they owned by central, 
regional or local authorities.7 
(4) Nevertheless, Jin Jiang's Articles of Association confer on Shanghai SASAC (as 
the 100% shareholder of Jin Jiang) various rights including the right to appoint 
board members and approve significant investment decisions.8 In addition,  the 
Commission has not excluded in prior cases that certain Chinese State -owned 
enterprises lack an independent power of decision and should be considered to 
constitute a single economic unit whose turnover and activities should be 
combined.9  
(5) In any case , for the purpose s of the assessment of the Transaction , the question of 
whether Jin Jiang belongs to the same group as other Chinese State -owned 
enterprises can be left open, as the Transaction would not  raise serious doubts even 
                                                 
4  The independent hotels operated under the Hôtels & Préférence brand are not owned by Jin  Jiang, but 
operate under a distribution alliance via an affiliation model (that is to say no branding, no 
management, just a non -exclusive distribution relationship) (Form CO, footnotes 2, 19 and 40).  
5  As of 30 June 2018, Jin Jiang owns an approximatel y 12.29% shareholding in the issued share capital 
of Accor Hotels. Other shareholders with more than 10% in Accor Hotels include Board members 
founders with 21.64%, QiA with 10.14% and a further 61.14% of shares which are floating. According 
to Jin Jiang, it does not hold a seat on Accor's Board of Directors and does not enjoy any special 
voting rights of any kind that would allow it to influence the strategic decisions of Accor Hotels (Form 
CO, paragraph 99). Therefore, Jin Jiang will not be considered as controlling Accor Hotels for the 
purposes of this Decision.  
6  Form CO , paragraph 137.  
7  Form CO, paragraph 70.  
8  Form CO, paragraph 48.  
9   See for instance  Cases M.7850 – EDF/CGN/NNB Group of companies ; M.7643 – CNRC/Pirelli ; 
M.6113 – DSM/Sinochem/JV ; M.6082 – China National Bluestar/Elkem . 
3 combining the activities of Jin Jiang and of all other Chinese State -owned 
enterprises active in the hotel industry.10   
(6) Radisson, currently controlled by the Chinese conglomerate HNA Group, operates 
a range of hotel brands with a focus on the luxury, upper upscale, upscale and 
upper midscale segments.11 In the EEA, these brands include Radisson Collection, 
Radisson Blu, Radisson, Radisson Red, Park Plaza, Park Inn by Radisson. As at the 
end of 2017, Radisson operates 369 hotels and resorts, […] rooms and has 
operations in 78 countri es.12 As at August 2018, Radisson's activities in the EEA 
included 224 hotels operating under the Radisson brands.13  
2. THE  OPERATION  
(7) On 9 August 2018, a Jin Jiang -led consortium14 and Radisson signed a series of 
agreements comprising three transactions pursuant to which Jin Jiang will acquire 
all the shares in, and therefore sole control over, Radisson . Under the first 
transaction, Jin Jiang will acquire a total of 51.15% of the outstanding shar es and 
votes in Radisson AB. Following the closing of the first transaction, under Swedish 
takeover rules, Jin Jiang will be under an obligation to launch a mandatory public 
tender offer for the remaining outstanding shares in Radisson AB, within four 
week s after the closing of the transaction, unless the ownership in Radisson AB is 
sold down below 30% (which, according to Jin Jiang, will not be the case). Under 
the second transaction, Jin Jiang will acquire up to an additional 18.50% of the 
shares and vote s in Radisson AB from HNA Sweden. Under the third transaction, 
and following the closing of the shares in Radisson AB, Jin Jiang will acquire 
100% of the shares in Radisson Holdings from HNA Hotel HK and HNA 
Sweden.15 
(8) The first, second and third transaction s will occur simultaneously. In addition, the 
closing of the third transaction is conditioned de jure  upon the closing of the first 
                                                 
10  These are in particular: BTG Homeinns Hotels (Group) Co., Jinling Hotels & Resorts Corp., HK CTS 
Hotels Co., Anhui Gujing Hotels Development Co., Huatian Hotel Group Co., Deefly Hotels & Resort 
Group, Yuehai (in ternational) Hotel Group Co., Shenzhen Grand Skylight Hotel Management Co. Of 
these hotel groups, only HK CTS Hotels Co. ("HK CTS") has significant activities in the EEA. In 
2015, HK CTS acquired "Kew Green Hotels", a hotel management company based in the United 
Kingdom. The Kew Green Hotels group provides hotel management services to 55 hotels, all situated 
in the United Kingdom.   
11   Radisson AB operates the bulk of Radisson's European hotel portfolio. Radisson Holdings operates 
Radisson's portfolio in th e Americas and Asia Pacific.  
12  Form CO, paragraph 17.  
13  Form CO, paragraph 144.  
14   The consortium comprises Jin Jiang and SINO -CEE Fund, a private equity investment fund  registered 
in Luxembourg . According to Jin  Jiang, SINO -CEE Fund is only participating in the Transaction as a 
non-controlling minority shareholder of the Jin Jiang acquisition vehicle. It will not enjoy any form of 
right or power that would confer on it joint control under the EU Merger Regulation  (Form CO, 
paragraphs 23 -26). Therefore, SINO -CEE Fund will not be further considered for the purposes of this 
Decision.  
15  Form CO, paragraphs 27 -30 and paragraphs 84 -88. 
4 transaction and the closing or termination of the second transaction.16 Furthermore, 
the three transactions pursue the same e conomic aim, which is to bring about the 
sole control of the Radisson group in the hands of one single entity, Jin Jiang.17 
Therefore, the three transactions are interdependent and constitute a single 
concentration pursuant to paragraph 38 and following of the Commission 
Consolidated Jurisdictional Notice.18  
(9) In light of the above, the operation  pursuant to which Jin Jiang intends to acquire  
sole control over Radisson constitutes a concentration within the meaning of 
Article 3(1)(b) of the Merger Regulation.  
3. UNION  DIMENSION  
(10) The undertakings concerned have a combined aggregate world wide turnover of 
more than EUR 2 500 m illion19 (Jin Jang: 3 416 million; Radisson: EUR 1 257 
million) . In each of three Member States, the combined aggregate turnover of the 
undertaki ngs concerned is more than EUR 100 million (France: […]; Germany: […]; 
United Kingdom: […]). The aggregate turnover of each of the undertakings 
concerned in each of th ose three Member States (France, Germany and United 
Kingdom) exceeds EUR 25 million. Each  of the undertakings concerned has a  
Union -wide turnover in excess of EUR 100 million (Jin Jiang: […]; Radisson: […]), 
but they do not achieve more than two -thirds of their aggregate Union -wide  
turnover within one and the same Member State.  
(11) The Transaction  therefore has a Union  dimension  within the meaning of Article 
1(3) of the Merger Regulation . 
4. MARKET  DEFINITION  
4.1. Introduction  
(12) The Parties are both active in the hotel industry.   
(13) As pointed out by the Commission in Case M.7902 – Marriott 
International/Starwood Hotels & Resorts Worldwide  ("Marriott International "),20 
                                                 
16   The closing of the third transaction is not a condition precedent for either of  the first or the second 
transactions to avoid a situation of legal impossibility in which neither of the first two transactions 
could in fact close.  
17  Form CO, paragraphs 30 -37. 
18  OJ C 95, 16.4.2008, p. 1.  
19   Turnover calculated in accordance with Arti cle 5 of the Merger Regulation and the Commission  
Consolidated Jurisdictional Notice. As indicated above, it is not excluded that Jin Jiang and other 
Chinese State -owned enterprises form part of the same economic unit and that their turnover should 
thus be  combined. Nevertheless, there is no need to conclude on the question of the aggregate turnover 
of these undertakings for the purposes of establishing jurisdiction, since the EU turnover thresholds are 
reached even considering Jin Jiang alone and Radisson.  Furthermore, Radisson does not achieve more 
than two -thirds of its aggregate EU -wide  turnover within one Member State . Therefore, the 
Transaction has in any case an EU dimension.    
20  Case M.7902 – Marriott International/Starwood Hotels & Resorts Worldwi de, paragraph 12.  
5 and as confirmed by the Parties21, hotels may be operated under the following three  
main business models:  (i) under the first model,  hotels  are owned  or leased  and 
managed by the same company under its own name or brand ; (ii) under the second 
model, a company – either a hotel chain or a specialised management company 
("white label management companies") – manages hotels, for a management fee, 
on behalf of their owner ; (iii) under the third model, hotel chains franchise one of 
their brands to hotel owners, who either manage their hotels themselves or use a 
third management company.  
(14) Moreover , the Commission defined in Marriott International  three separate 
markets for: (i) the provision of hotel accommodation services , which is local in 
scope ;22(ii) the provision of hotel management services , which may be EEA - or 
worldwide in scope ;23 and (iii) the provision of hotel franchising services , which 
may be EEA - or worldwid e in scope .24 
(15) Both Parties o perate under the three business models described in the paragraph  
(13) in the EEA and worldwide .25 In the EEA, Jin Jiang predominantly operates via 
Groupe du Louvre  hotels , which are owned or leased, managed or franchised .26 
Radisson has an asset -light strategic goal, whereby it mainly licenses its brands . It 
also manages hotels  and operates a few owned or leased hotel s.27  
(16) Therefore , the Parties' activities overlap in the markets for the provision of : 
a. hotel accommodation services ,  
b. hotel management services, and  
c. hotel franchising services .  
(17) However, neither the market for hotel management services nor the market for 
hotel franchising services is affected at EEA -wide or worldwide levels, even if the 
market shares of other Chinese State -owned hotel managers or franchisors28 are 
included in Jin J iang's market shares . Indeed, according to Jin Jiang's estimates and 
based on the number of hotels rooms classified as "chain management" in the 
                                                 
21  Form CO, paragraphs 138 and 141.  
22  Case M.7902 – Marriott International/Starwood Hotels & Resorts Worldwide , section 4.2.1 , 
paragraphs 17 -75 for the product market definition and section 4.3.1, paragraphs 110 -120 for the 
geographic market definition . 
23  Case M.7902 – Marriott International/Starwood Hotels & Resorts Worldwide , section 4.2.2, 
paragraphs 76 -101 for the product market definition and section 4.3.2, paragraphs 121 -151 for the 
geographic market definition.  
24  Case M.7902 – Marriott International/Starwood Hotels & Resorts Worldwide , section 4.2.3, 
paragraphs 102 -109 for the product market definition and section 4.3.3, paragraphs 152 -180 for the 
geographic market definition.   
25  Form CO, paragraphs 138 and 141.  
26  Form CO, p aragraph 138.  
27  Form CO, paragraphs 141 -145. 
28  BTG Homeinns Hotels (Group) Co., Jinling Hotels & Resorts Corp., HK CTS Hotels Co., Anhui 
Gujing Hotels Development Co., Huatian Hotel Group Co., Deefly Hotels & Resort Group, Yuehai 
(international) Hotel Gr oup Co., Shenzhen Grand Skylight Hotel Management Co.  
6 STR29 database, the Parties' EEA -wide and worldwide combined shares in the  
market for the provision of hotel man agement services would remain below 5%.30 
Similarly, according to Jin Jiang's estimates and based on the number of hotels 
rooms classified as franchised in the STR database, the Parties' EEA -wide and 
worldwide combined shares in the  market for the provision of hotel franchising 
services would remain below 20%.31     
(18) In light of the above , the Commission will not further consider in this Decision the 
definition  of the markets  for the provision of hotel management and franchising 
services , and no c ompetition assessment will be conducted  in this Decision on 
those markets . For the purposes of this Decision, the Commission will only assess 
the effects of the Transaction in the market for the provision for hotel 
accommodation services.  
4.2. Relevant product market  for hotel accommodation services  
(19) In decisions prior to Marrio tt International , the Commission considered a separate 
market for the provision of hotel accommodation services ,32 leaving open whether 
separate markets should be distinguished based on own ership type  (chains vs. 
independent hotels) ,33 comfort/price level  (for instance  star rating) ,34 and the 
provision of services in short stay residences .35 
(20) In Marriott International , the Commission  carried out a  detailed  analysis of 
whether the market for hotel accommodation services should be segmented based 
on: (i) ownership type  (chains vs. independent hotels) ; (ii) comfort/price level  (star 
ratings vs. categories) ; (iii) short stay residences ; and (iv) the provision of specific 
services .36  
                                                 
29  STR Global ("STR") is a leading global provider of hotel market data and benchmarking.  
30  Form CO, Annex 3.1(II), paragraphs  6-8. 
31  Form CO, Annex 3.1(II), paragraphs  9-12. 
32  Cases M. 6738 – Goldma n Sachs/KKR/QMH , paragraph  14; M.6058 – Bank of Scotland/Barclays 
Bank/Kew Green Hotels , paragraph 13; M.1596 – Accor/Blackstone/Colony/Vivendi , paragraph 16; 
M.126 – Accor/Wagons -Lits, point V.  
33  Cases M. 6738 – Goldman Sachs/KKR/QMH , paragraph  14; M.6058 – Bank of Scotland/Barclays 
Bank/Kew Green Hotels , paragraphs 13 and 16; M.126 – Accor/Wagons -Lits, point V., paragraph 21.  
34  Cases M. 6738 – Goldman Sachs/KKR/QMH , paragraph  14; M.6058 – Bank of Scotland/Barclays 
Bank/Kew Green Hotels , paragra phs 13 and 16;  Case M.1596 – Accor/Blackstone/Colony/Vivendi , 
paragraphs 23 -26 and 28.  
35  Case s M.4612 – Accor/Pierre et Vacances/New City JV , paragraph s 15-17; M.3068 – Ascott 
Group/Goldman Sachs/Oriville , paragraphs 13 -17. 
36   Case M.7902 – Marriott Inter national/Starwood Hotels & Resorts Worldwide , paragraphs 21 -75. 
7 4.2.1.  Distincti on by ownership type  
4.2.1.1.  The Commission's pr ecedents  
(21) In its prior decision practice , the Commission considered a segmentation of the 
overall market for hotel accommodation services by ownership type. Specifically, 
the Commission distinguished between three types of hotels: (i) economically and 
legally independent hotels; (i i) voluntary ch ains consisting of groups of 
independent hotels which carry out their marketing, promotion, purchasing etc. 
under one and the same hotel brand; and (iii) integrated chains which operate hotels 
directly through subsidiaries or indirectly by a franchise or m anagement contract.37 
(22) In Marriott International , the Commission concluded that the market for hotel 
accommodation services comprised the services provided by both chain hotels and 
independent hotels.38 
4.2.1.2.  Jin Jiang's view s 
(23) Jin Jiang , first, consider s that independent and chain hotels are entirely 
substitutable,  particularly at a local level. The Parties' hotels competitive sets, that 
is to say  the list of hotels against which Jin Jiang and Radisson benchmark 
themselves and the performance of which the y monitor, consist of both chain and 
independent hotels.39 Second , Jin Jiang argues  that whether a hotel belongs to a 
chain or is independent is not among the main drivers of customers' choice between 
hotels. Third, Jin Jiang  submit s that on-line travel age ncies ("OTAs") are 
increasingly used, enabling customers to compare the  offerings of all chain and 
independent hotels, and their performance through users' reviews. Fourth, Jin Jiang 
maintain s that independent hotels are continuing to improve their offering in the 
area of loyalty program mes and, as a result, any difference which may exist 
between independent and chain hotels in this area is being further eroded. Fifth , 
technological development s continue to enable independent hotels to raise 
awareness of their brands and access to customers on a global basis. Whilst chain 
hotels may potentially have greater brand awareness, customers, including 
corporate customers, purchase hotel accommodation s ervices from both chain and 
independent hotel s.40 
4.2.1.3.  The Commission's assessment   
(24) The results of the market investigation confirmed the Commission 's findings in 
Marriott International . 
(25) First, most of the respondents to the market investigation confirmed  that w hether a 
hotel belongs to a chain or is independent is not among the main drivers of 
customer's choice between hotels.41 In line with the results of the market 
                                                 
37  Cases M.6058 – Bank of Scotland/Barclays Bank/Kew Green Hotels , paragraph 13;  M.1596 – 
Accor/Blackstone/Colony/Vivendi , paragraphs 16 -22. 
38  Case M.7902 – Marriott International/Starwood Hotels & Resorts Worldwide , paragraph 47.  
39  Form CO, Annexes 5.3.2.V(a) and 5.3.2.V(b).  
40  Form CO, paragraphs 152 -163. 
41  Replies to Q1 – Questionnaire to competitors, question 3.  
8 investigation in Marriott International ,42 features such as price, comfort level and 
customers' ra ting are more important for the selection of a hotel in a given location  
than the ownership type .43 
(26) Second, t he majority of the respondents who expressed an opinion confirm ed that 
customers purchase hotel accommodation services from both  chain and 
independe nt hotels.44 They also confirm that, in terms of price, customers consider 
chain and independent hotels as interchangeable.45 Some of the respondents explain 
that the main, or only relevant, difference between chain and independent hotels is 
their offer of loyalty program mes.46  
(27) Third, a ll the respondent s to the market investigation indicated that intermediaries, 
such as travel a gencies, on -line travel agencies and tour operators, have business 
relationships with both chain and independent hotels.47 In this respect, some 
respondents clarif ied that it is in the intermediaries' interest to offer a broad 
portfolio.48 
(28) Finally, according  to the majority of the respondents  having expressed an opinion, 
online travel agents prioritise offerings irrespective of whether the hotels belong to 
chains or are independent.49 
4.2.1.4.  Conclusion  
(29) For the reasons set out in this section, including in light of th e market investigation , 
the Commission concludes that, for the purposes of this Decision,  the market for 
hotel accommodation services should not be segmented on the basis of ownership 
type, but rather comprises the services provided by both chain and indep endent 
hotels.  
4.2.2.  Distinction by comfort/price level   
4.2.2.1.  The Commission's pr ecedents  
(30) In its prior decision practice, the Commission has considered a possible 
segmentation of the market for hotel accommodation services by comfort/price 
level.50 
                                                 
42  Case M.7902 – Marriott International/Starwood Hotels & Resorts Worldwi de, paragraph  29. 
43  Replies to Q1 – Questionnaire to competitors, question 3.  
44  Replies to Q1 – Questionnaire to competitors, question 7.  
45  Replies to Q1 – Questionnaire to competitors, question 6.  
46  Replies to Q1 – Questionnaire to competitors, questi on 6.1.  
47  Replies to Q1 – Questionnaire to competitors, question 8.  
48  Replies to Q1 – Questionnaire to competitors, question 8.1.  
49  Replies to Q1 – Questionnaire to competitors, question 10.  
50  Case M. 7902 – Marriott International/Starwood Hotels & Resorts Worldwide , paragraphs 49 -63; Case 
M. 6738 – Goldman Sachs/KKR/QMH , paragraph  14. 
9 (31) In Marriott International , the Commission left open the question of whether the 
market for hotel accommodation services should be segmented by comfort/price 
level on the basis of hotels' star rating.  It nevertheless considered that the 
distinction by comfort/price lev el on the basis of comfort classes (for instance STR 
classes)51 was not relevant  for the purposes of that decision .52 
4.2.2.2.  Jin Jiang's view s 
(32) Jin Jiang  submit s that any further segmentation of the market for hotel 
accommodation services , based on comfort/price lev el, is not appropriate  for the 
following main reasons . First,  there is no established definition in the hotel industry 
for allocating star ratings to a particular hotel. As a result, i ndividual hotel 
operators often use their own ratings.53 Second,  hotels with adjacent  star rat ings 
(for instance  4-star and 3 -star hotels, 3 -star and 2 -star hotels) exert comp etitive 
pressure on one another .54 Third , with respect  to STR classes, customers are not 
familiar with this classification .55  
4.2.2.3.  The Commission's ass essment  
(33) The majority  of the respondents to the market investigation who expressed an 
opinion confirmed that customers are familiar , or very familiar , with the 
classification of hotels on the basis of star rating.56 Some of the c ompetitors 
nonetheless recognise d that the star rating classification has its limits ; the absence 
of actual standards and the resulting differences among EEA countries  make it 
difficult to rely fully on this classification.57 In any event , as explain ed by some of 
the respondents to the market investigation,  customer rating is grow ing in 
importance and online reputation websites are "becoming ke y" in the selection of 
hotels by customers.58 In conformity with the above, and in particular the 
increasing importance of customer rating, the majority of respondents having  
ranked certain criteria for the choice of hotels in a given location by customers 
considered star rating as not so important.59 
(34) As regards categories  (for instance  STR classes) , the  results of the  market 
investigation supported  the conclusion reached in Marriott International , according 
to which customers are not familiar with this type of classification, which is not 
widely communicated in all distribution channels .60 The majority of the 
                                                 
51  According to STR, there are six classes, namely luxury, upper upscale, upscale, upper midscale, 
midscale, and economy.  
52  Case M.7902 – Marriott International/Starw ood Hotels & Resorts Worldwide , paragraph 63.  
53   Form CO, paragraph 170.  
54  Form CO, paragraph 171.  
55  Form CO, paragraph 172.  
56  Replies to Q1 – Questionnaire to competitors, questions 3.1 and 5.  
57  Replies to Q1 – Questionnaire to competitors, question 5.1. 
58  Replies to Q1 – Questionnaire to competitors, questions 3.1, 5 and 5.1.  
59  Replies to Q1 – Questionnaire to competitors, question 3.  
60  Case M.7902 – Marriott International/Starwood Hotels & Resorts Worldwide , paragraph 62.  
10 respondents to the market invest igation considered  comfort level  (that is to say  
luxury, upper upscale, upscale, upper midscale, midscale and economy)  as either  
important or very important for the choice of a hotel in a given location by final 
customers ,61 for which, subject to the nation al differences referred to in the 
previous paragraph, star  rating should be a proxy.62 However, the high importance 
given to comfort class seems to reflect the importance that customers give to the 
amenities and services offered by hotels and reflected by t he hotel category, rather 
than the general level of awareness  by customers  of the meaning of hotel 
categories. Indeed, some of the respondents explained that comfort levels  are part 
of "industry language" and that  consumers are not familiar  with this specific 
terminology .63 The majority of respondents to the market investigation in fact 
confirmed that customers are not familiar, or not so familiar, with the classification 
of hotels on the basis of comfort level.64  
4.2.2.4.  Conclusion  
(35) In any case , for the purposes of this Decision, the question of  whether the market 
for hotel accommodation services should be segmented on the basis of star rating  
can be left open, as the Transaction would not raise serious doubts as to its 
compatibility with the internal  market under any plausible market definition . 
(36) Furthermore, for the reasons set out in this section, including in light of the market 
investigation , the Commission concludes that, for the purposes of this Decision,  the 
market for hotel accommodation servic es should not be segmented  on the basis of 
categories  (for instance  STR classes) , considering the general lack of awareness by 
customers of this type of classification .  
4.2.3.  Distinction between hotels and s hort stay residences  
4.2.3.1.  The Commission's pr ecedents  
(37) In its prior decision practice , the Commission  assessed whether short stay 
residences are part of a broader hospitality  market , also including hotel 
accommodation services,65 ultimately  leaving the question  open.66 
                                                 
61  Replies to Q1 – Questionnaire to competitors, question 3.  
62  In addition to the national differences in the star rating system, the approach to comfort level (for 
instance STR classification ) deviates from the approach to star rating to the extent that a comfor t level 
is attributed per brand (not per hotel), while star rating is attributed per hotel (not per brand) (see 
replies to Q1 – Questionnaire to competitors, question 5.1).  
63  Replies to Q1 – Questionnaire to competitors, question 3.1.  
64  Replies to Q1 – Questionnaire to competitors, question 4.  
65  Case s M.7902 – Marriott International/Starwood Hotels & Resorts Worldwide , paragraph 65, 67 -68; 
M.4612 – Accor/Pierre et Vacances/New City JV , paragraph s 16-17; M.3068 – Ascott Group/Goldman 
Sachs/Oriville , parag raphs 14 -16. 
66  Case s M.7902 – Marriott International/Starwood Hotels & Resorts Worldwide , paragraph  69; M.4612 
– Accor/Pierre et Vacances/New City JV , paragraph  18; M.3068 – Ascott Group/Goldman 
Sachs/Oriville , paragraph 17.  
11 4.2.3.2.  Jin Jiang's view s 
(38) The Parties submit that serviced apartments do not belong to a separate market as 
they compete with conventional hotels and also with short stay residences, 
including short -term lets. In their view, new entrants, such as Airbnb and FlipKey, 
by allowing the general public to rent out their own houses, represent an increasing 
threat to conventional hotels.67 
4.2.3.3.  The Commission's assessment  
(39) The Parties have marginal serviced apartment offerings, corresponding to short stay 
residences. Jin  Jiang does not offer serviced apartments. Radisson has one 
franchise d hotel  offering serviced apartments, namely, the Radisson Blu Mountain 
Resort & Residences, in Trysil, Norway, with 42 rooms. Radisson also has one 
managed hotel in development, which wi ll offer serviced apartments, namely the 
Radisson Blu Hotel & Residences, in Zakopane, Poland, with 68 rooms.68 
4.2.3.4.  Conclusion  
(40) In any case , for the purpose s of this Decision, the question of  whether short  stay 
residences are part of the same market as hotel acc ommodation services  can be left 
open , as the Transaction would not raise serious doubts as to its compatibility with 
the internal market under any plausible market definition . 
4.2.4.  Distinction between hotel accommodation services and specific services  
4.2.4.1.  The Commission's precedents  
(41) In Marriott International , the Commission concluded that the pro vision of 
additional services, for, for instance,  conferences and events, fitness and spa, food 
& beverage, loyalty programmes etc. by hotel operators is ancillary to h otel 
accommodation services.69 
4.2.4.2.  Jin Jiang's view s 
(42) Jin Jiang submits that specific services offered by the Parties are ancillary to their 
primary offering and are intended to increase the hotels' occupancy rate.70 
4.2.4.3.  The Commission's assessment  
(43) The market invest igation has not produced evidence indicating that the 
Commission should depart from the approach it has recently taken in respect  of the 
ancillary nature of specific services . In particular, respondents have  not submitted 
material comments suggesting that there is any need  to define a separate market  for 
the provision of specific services  for the purpose s of assessing the effects of the 
Transaction  on competition.  
                                                 
67  Form CO, paragraph 182.  
68  Form CO, paragraph 183, footnote 66.  
69  Case M.7902 – Marriott International/Starwood Hotels & Resorts Worldwide , paragraph 72.  
70  Form CO, paragraph 185.  
12 4.2.4.4.  Conclusion  
(44) In light of the above, the Commission concludes that, for the purposes of this 
Decision, the market for hotel accommodation services comprises additional 
services also offered by hotel operators . 
4.2.5.  Conclusion  on the product market definition for hotel accomm odation services  
(45) For the reasons set out in this section, including in light of the market investigation 
and of all the evidence available to it, the Commission concludes that, for the 
purposes of this Decision, the relevant market is the market for the pr ovision of 
hotel accommodation services, whether  provided by chain or independent hotels, 
including the provision of additional services.  
(46) Moreover , for the purposes of this Decision, the Commission considers that it is not 
necessary to conclude on the pote ntial distinctions by star rating and between 
hotels and short stay residences, as the Transaction would not raise serious doubts 
as to its compatibility with the internal market under any plausible market 
definition . 
4.3. Relevant geographic market  for hotel a ccommodation services  
4.3.1.  The Commission's pr ecedents  
(47) In decisions prior to Marriot t International , the Commission left the exact 
geographic scope of the market for hotel accommodation services  open. It ha d 
nonetheless observed that the relevant geographic market present ed both national 
and local characteristics.71 
(48) In Marriott International , the Commission concluded that the geographic market 
for hotel accommodation services appear s to be  local  and that it should not be 
further segmented by city district s.72 It nonetheless left the exact delineation of the 
local market  open , notably the possibility of cities and their respective airport areas 
being  part of the same geographic market.73 
4.3.2.  Jin Jiang's view s 
(49) Jin Jian g submit s that the exact delineation of the  local market for hotel 
accommodation services may be left open as in any case no competition concerns 
would arise from  the Transaction.74 
                                                 
71  Case M.7902 – Marriott International/Starwood Hotels & Resorts Worldwide , paragraph 110.  
72  Case M .7902 – Marriott International/Starwood Hotels & Resorts Worldwide , paragraphs 118 and 
120. 
73  Case M.7902 – Marriott International/Starwood Hotels & Resorts Worldwide , paragraph 119.  
74  Form CO, paragraph 180.  
13 4.3.3.  The Commission's assessment  
(50) The market investigation has not revealed any indication that the 
Commission  should  depart  from  the approach it has  recently taken in respect of the  
local scope of the market for hotel accommodation services. In particular, 
respondents have not submitted material comments suggesting that  there is a need 
to assess the effects on competition on a broader market.  
4.3.4.  Conclusion  on the geographic market definition for hotel accommodation 
services  
(51) For the reasons set out in this section, including in light of the market investigation 
and of all th e evidence available to it, the Commission concludes that, for the 
purposes of this Decision, the geographic market for hotel accommodation services 
is local.  
(52) Moreover , for the purposes of this Decision, the Commission considers that it is not 
necessary to conclude on whether cities and their respective airport areas are part of 
the same geographic markets , as the Transaction would not raise  serious doubts as 
to its compatibility with the internal market under any plausible market definition.  
5. COMPETITIVE  ASSESSMENT  
5.1. Legal framework for the competitive assessment  
(53) Effective competition brings benefits to consumers, such as low prices, high quality 
products, a wide selection of goods and services, and innovation. Through its 
control of mergers, the Commission pr events mergers that would be likely to 
deprive customers of those benefits by significantly increasing the market power of 
firms.75 
(54) Under Article 2(2) and (3) of the Merger Regulation, the Commission must assess 
whether a proposed concentration would signif icantly impede effective competition 
in the internal market or in a substantial part of it, in particular as a result of the 
creation or strengthening of a dominant position . The notion of "significant 
impediment to effective competition" must be interpret ed as extending, beyond the 
concept of dominance, to the anticompetitive effects of a concentration resulting 
from the non -coordinating behaviour of undertakings which do not have a 
dominant position on the market concerned.76 
(55) As regards non -coordinated eff ects, a merger with horizontal effects may 
significantly impede effective competition in a market, even if it does not result in 
the creation or strengthening of a dominant position, by removing important 
competitive constraints and influencing parameters of competition.77 
                                                 
75  Commission Guidelines on the assessment of  horizontal mergers under the Council Regulation on the 
control of concentrations between undertakings (the "Horizontal Merger Guidelines"), OJ C 31, 
5.2.2004, p. 5, paragraph 8.  
76  Recital 25 of the Merger Regulation.  
77  Horizontal Merger Guidelines, para graph 8.  
14 (56) The Horizontal Merger Guidelines list a number of factors which may influence 
whether or not significant non -coordinated effects are likely to result from a 
merger, such as the large market shares of the merging firms, the fact that merging 
firms are close competitors, the limited possibilities for customers to access to the 
services provided by the parties and their competitors and the fact that the merger 
would eliminate an important competitive force.  
(57) It is in the light of the prin ciple set out above that the Commission must analyse 
whether and to what extent the Transaction may raise serious doubts as to its 
compatibility with the internal market.  
5.2. Overview of the reportable markets  
(58) As indicated in section 4.1 above, the Parties' activi ties overlap in the markets for : 
(i) hotel accommodation services ; (ii) hotel management services ; and (iii) hotel 
franchising services in the EEA and worldwide.  
(59) However, as explained in paragraph (17), the Transaction does not give rise to 
affected markets for hotel management or franchising services at EEA -wide or 
worldwide levels . In addition, the majority of respondents to the market 
investigation consider that the Transaction will have no significant overall impact 
on hotel management services or on hotel franchising services in the EEA or 
worldwide.78 In light of the above , the Commission considers that the Transaction 
is unlikely to give rise to any anti -competitive horizontal effects on the EEA or 
worldwide markets for hotel management or franchising services.  
(60) In addition, Jin Jiang provides t our operat ing and travel agency services  in China  
and is thus active in markets that are dow nstream from the market for hotel 
accommodation services .79 However,  the Commission has considered in its prior 
decision practice  that these vertically related markets would generally be national 
or narrower in scope .80 Jin Jiang is thus not active in a product market which is 
upstream or downstream from the hotel accommodation services provided by 
Radisson  within the EEA territory or in a territory wider than the EEA . More 
generally,  neither Jin Jiang nor any other State -owned enterprise s are significantly 
active in a market which is upstream or downstream from the hotel services 
(accommodation, management or franchising) provided by Radisson.81 In light of 
the above,  the Commission considers that  Transaction is unlikely to give rise to an y 
anti-competitive vertical effects.    
                                                 
78  Replies to Q1 – Questionnaire to competitors, questions 14 and 15.  
79  Jin Jiang operates the services "JinJiang Trip", Jin Jiang's own reservation platform, and "JinJiang  
Travel", a travel agency service. Since 2017, these services have allowed Chinese customers to book 
hotels in Europe, although to a marginal extent. In 2017, JinJiang Trip sold a total of […] nights in 
European hotels, with only […] nights sold in Europea n hotels from January to June 2018. Since 2017, 
JinJiang Travel has […] (Form CO, paragraph 45).  
80  For tour operating and travel agency services, see for instance Cases M.8046 – TUI/Transat France , 
paragraphs 65 and 106; M.6704 – REWE Touristik GmbH/ Feri d NASR/EXIM Holding SA, paragraph 
28. For hotel accommodation services, see section XX above.  
81  Form CO, paragraphs 46 and 69 and reply of Jin Jiang to RFI 2 of 17 October 2018.  
15 (61) Therefore, the  assessment of the compatibility of the Transaction with the internal 
market will focus on the non -coordinated horizontal effects in the provision of 
hotel accommodation services , in relation to which  the Transaction gives rise to 
affected markets .  
5.3. Methodology for the estimation of market shares for hotel accommodation 
services  
(62) As indicated in section 4.1 above, the Parties are active on the markets for hotel  
accommodation services in the EEA through owned or leased, managed and 
franchised hotels .  
5.3.1.  Inclusion of managed hotels in the calculation of market shares  
(63) In its prior decision practice, the Commission considered that the provision of hotel 
management services to a hotel owner on a contractual bas is may lead to a situation 
of joint control over the hotel by the hotel owner and the hotel manager .82 In 
particular, in Marriott International , the Commission concluded that hotels 
managed by the parties are most likely jointly controlled by them . Therefor e, the 
Commission included managed hotels in the calculation of the parties' market 
shares.83 
(64) Jin Jiang submits that  each of Jin  Jiang and Radisson have a determining role on 
the operation of their respectively managed hotels and the development and 
implementation of their business.  Therefore, Jin Jiang has included managed hotels 
in the calculation of the Parties' market shares in  the EEA.84 
(65) The Commission notes that, under the standardised management agreements  of 
both Jin Jiang and Radisson,85 the Parties in their function as hotel managers are 
granted a broad authority by the hotel owner to control all major aspects of the 
operati on of the hotel, in particular setting rates, collecting revenues,  preparing 
books and financial reporting,  and performing repairs and maintenance . 
Furthermore, the Parties' management fees consist of a percentage of the hotel's 
gross annual revenues and a  percentage of the hotel's annual operating profit.86 
Therefore, Jin Jiang and Radisson in their function as hotel managers exert 
significant influence over the hotels they manage.  
(66) In light of the above , and in line with the conclusion reached in Marriott 
International , the Commission considers  that the hotels managed by Jin Jiang or 
Radisson are most likely jointly controlled by them. Accordingly , these managed 
hotels should be taken into account for the purposes of identifying the local 
                                                 
82  See for instance Cases M.8718 – Starwood Capital Group/Accor/Sofitel Budap est Chain Bridge Hotel ; 
M.5164 – MSREF/IHG/Crowne Plaza Wiesbaden .  
83  Case M.7902 – Marriott International/Starwood Hotels & Resorts Worldwide , paragraph 192.  
84  Form CO, paragraphs 225 -229. 
85  Jin Jiang indicates that, while each management agreement is negotiated and specific to each hotel, the 
final agreement remains closely aligned with the standard agreement, which may vary and be adjusted 
to a limited extent for brand differences (Form CO, paragraph 225).  
86  Form CO, paragraphs 225 -227 and Annexes 7 .5.1(a), 7.5.1(b), 7.5.2(a) and 7.5.2(b).  
16 markets in the EEA where the Parties' activities overlap and the markets shares of 
these managed hotels should be attributed to the Parties , as this would more 
accurately reflect the Parties' relative market position .87   
5.3.2.  Non-inclusion of franchised hotels in the calculation of market shares  
(67) According to the Commission Consolidated Jurisdictional Notice, "franchising 
agreements as such do not normally confer control over the franchisee's business 
on the franchisor."88 In line with this , the Commission concluded in Marriott 
International  that the parties d id not control their franchised hotels. Therefore, the 
Commission did not include franchised hotels in the calculation of the parties' 
market shares  in that case .89 
(68) Jin Jiang submits that, in contrast to managed hotels, the franc hise agreements do 
not confer upon Jin Jiang or Radisson in their function as hotel franchisors with 
any decision -making authority in relation to the operation of the hotel.90 
(69) The Commission notes that, under the standardised franchis e agreements of both 
Jin Jiang and Radisson,91 the franchisee is responsible for the day -to-day operation 
of the hotel , which includes price setting, budget and business plan, employment 
and staffing issues, maintenance and investment of the hotel . Furthermore, the 
Parties are ty pically remunerated through a franchise application fee, a royalt y fee, 
depending on the hotel's gross sales, and ancillary fees that cover miscellaneous 
expenses, such as the cost of the on -line reservations platform and property sales 
and marketing costs .92 Therefore, hotels franchised by Jin Jiang and Radisson are 
operated independently by their hotel managers and not centrally by the hotel chain 
itself.  
(70) This is confirmed by a majority of respondents to the market investigation , which 
consider ed that fran chised hotels compete with other hotels belonging to the same 
chain within the same location (be they leased or owned, managed or franchised by 
the hotel chain).93 
  
                                                 
87  Considering that the Chinese State -owned company HK CTS manages hotels in the EEA through the 
white -label management company Kew Green Hotels, the Commission consider that hotels managed 
by Kew Green Hotels should be considered as jointly controlled by Jin  Jiang for the purposes of this 
Decision  (see paragraph (5) above).   
88  Commission Consolidated Jurisdictional Notice, p aragraph 19.  
89  Case M.7902 – Marriott Inte rnational/Starwood Hotels & Resorts Worldwide , paragraph 19 9. 
90  Form CO, paragraphs 230 -239. 
91  Jin Jiang indicates that, w hile each franchise agreement is negotiated and specific to each hotel, the 
final agreement remains closely aligned with the standar d agreement (Form CO, paragraph 233).   
92  Form CO, paragraphs 233 -234 and 236 and Annexes 7.5.3(a), 7.5.3( b), 7.5.4(a) and 7.5.4(b) . 
93  Replies to Q1 – Questionnaire to competitors, question  11. For example: "As a franchise you own your 
own P&L and are do ing business in the open market place amongst other hotels including other 
franchised and managed hotels associated with one chain"  (reply to Q1 – Questionnaire to 
competitors, question  11.1).  
17  
(71) In light of the above and taking account of the results of the market investigation 
and of  all the evidence available to it , the Commission considers  that the hotels 
franchised  by Jin Jiang or Radisson are most likely not controlled by them. 
Accordingly, these franchised  hotels should not be taken into account for the 
purposes of identifying th e local markets in the EEA where the Parties' activities 
overlap and the markets shares of these franchised hotels should not be attributed to 
the Parties , as this would not accurately reflect their relative market position .94  
5.3.3.  Calculation of market shares  
(72) Jin Jang  has calculated the Parties' market shares in volume ( room capacity 
expressed in number of rooms) on the basis of data from the STR database, 
supplemented by public record searches using major price comparison websites, 
such as TripAdvisor, Expedia  or Booking.com. Hotels that did not have a star 
rating were excluded from the dataset.95 Furthermore, Jin Jiang has included the 
Parties' pipeline hotels in its estimation of market shares , while excluding, on a 
conservative basis, pipeline projects from  the Parties' competitors.96 
(73) The calculation method adopted by Jin Jiang is in line with the one adopted by 
Marriott in Marriott International . In that decision , the Commission concluded that 
the market data provided by Marriott suffice d for assessing the impact of the 
transaction on the EEA markets for the provision of hotel accommodation 
services.97  
 
                                                 
94  Considering the relationship between Jin Jiang and the hotel s operated under the Hôtels and Préférence 
brand, which simply consists in a non -exclusive distribution relationship (Form CO, footnotes 2, 19 
and 40), the Commission also considers that Jin Jiang does not control the Hôtels and Préférence 
hotels and the l atter's market shares are not attributed to Jin Jiang.   
95  Form CO, footnote 31 . 
96  Form CO, paragraph 981.  
97  Case M.7902 – Marriott International/Starwood Hotels & Resorts Worldwide , paragraphs 200 -203. 
With regard to serviced apartments, Marriott had included Marriott's and Starwood's serviced 
apartments and residential offerings in the parties' market shares for hotel accommodation services, 
while excluding the serviced apartments and residential offerings not operated by the parties from the 
estimation of the market size. In the present case, Jin Jiang does not offer serviced apartments in the 
EEA  and Radisson is only marginally active (through one franchised hotel, the market shar e of which 
is not attributable to Radisson, and through one hotel in development, which is not in an overlap city). 
In this context, Jin Jiang  has provided the two sets of data, including and excluding serviced 
apartments offered by third parties (Form CO,  section 7 is based on the exclusion of serviced 
apartments from the competitor dataset, and Annex 7.1, City Tables Tool , provides market shares 
including and excluding serviced apartments ). 
18 5.4. Affected markets  for hotel accommodation services  
5.4.1.  Introduction on  hotel accommodation services  in the EEA  
(74) As indicated in Marriott International , the hotel s ector  in the EEA  is highly 
fragmented and dynamic.98 Jin Jiang notably indicates that the supply of hotel 
accommodation  services grows by approximately 3% to 5% in the EEA on a yearly 
basis. This dynamism results in approximately 40 000 new hotel rooms avai lable 
every year in the EEA, even excluding the additional capacity and growth of non -
traditional lodging providers such as Airbnb.99  
(75) In a Jin Jiang's internal document, the hospitality market in Europ e is described as 
"relatively fragmental", with the top 5 hospitality market players accounting for less 
than 15% of the market by room number in 2017 (1. Accor: [5-10]%; 2. IHG: [0-5]%; 
3. Marriott: [0-5]%; 4. Best Western: [0-5]%; and 5. Radisson: [0-5]%), and the top 
10 hospitality market players accounting for about 20% (Jin Jiang ranking number 
[…] according to the 2017 room number, with [0-5]%).100 
5.4.2.  Overview of the affected markets  for hotel accommodation services  
(76) Excluding their franchised hotels, the Pa rties' activities on the market for hotel 
accommodation services overlap in 34 cities in the EEA.101 The Parties' combined 
market shares exceed 20% in only four of these cities,  out of which three are only 
affected markets  taking account of distinctions betw een hotels on the basis of their 
star rating.102 The table below provides an overview of the affected markets  (2018 
data) .103 
  
                                                 
98  Case M.7902 – Marriott International/Starwood Hotels & Resorts  Worldwide , paragraphs 204 -205. 
99  Form CO, paragraphs 1024 -1025.  
100  Form CO, Annex 5.4.2 – Project Camry_Business Plan Review, 30 July 2018, slide 28.  
101  Including six cities in the United Kingdom for w hich the overlap only derives from t he hotel 
manageme nt activities of Kew Green Hotels , controlled by another Chinese State -owned company, 
HK CTS Hotels Co . (Form CO, paragraphs 114 -118 and Annex 7.2).  
102  Form CO, paragraph 119 and Annex 7.2.  
103  On a conservative basis, the Parties' market shares are presen ted below on the narrow market for hotel 
accommodation services excluding serviced apartments and short stay residences (only Radisson will 
offer serviced apartments in one non -overlap city).  
19 Table 1 – Affected markets at local level  
  Jin Jiang  Radisson  Combined  
Düsseldorf 
(Germany)104 2 stars  [5-10]% [10-20]% [20-30]% 
1&2 stars  [5-10]% [10-20]% [20-30]% 
Marseille    
(France)105 4 stars  [10-20]% [5-10]% [20-30]% 
4&5 stars  [10-20]% [5-10]% [20-30]%106 
Northampton 
(United Kingdom)107 3 stars  [10-20]% [10-20]% [20-30]% 
Stansted          
(United Kingdom)108 3&4 stars  [10-20]% [20-30]% [30-40]% 
2&3&4 stars  [10-20]% [20-30]% [30-40]% 
3&4&5 stars  [10-20]% [20-30]% [30-40]% 
All stars  [10-20]% [20-30]% [30-40]%109 
Source: Form CO  
5.4.3.  Elements common to the assessment of markets for hotel accommodation services 
in the EEA  
(77) The competitive assessment of the affected markets is carried out at local level in 
section 5.3.4  below. Nonetheless , certain elements which are common to all  
locations are briefly presented below: (i) closeness of competition,110 (ii) consumer 
brand loyalty  and loyalty programmes, and (iii) barriers to entry or expansion.111 
                                                 
104  Market shares on the basis of city -only hotels (excluding th e airport area). The Parties' combined 
market share including airport hotels would be [20-30]%. 
105  Market shares on the basis of city -only hotels (excluding the airport area). The Parties' combined 
market share for 4 -star hotels including airport hotels would be [20-30]%. The market for 4&5 -star 
hotels including airport hotels would not be affected.  
106  Rounding effect.  
107  All hotels in Northampton are considered as city hotels (no airport hotels).  
108  All hotels in Stansted are considered as airport hotels (no city hotels).  
109  Rounding effect.  
110  Horizontal Merger Guidelines, paragraph 28.  
111  Horizontal Merger Guidelines, paragraph 33.  
20 5.4.3.1.  Closeness of competition  
(78) In Marriott International , the Commission assessed the extent to which the parties' 
hotel accommodation services are close substitutes on the basis of (i) their brand 
positioning, and (ii) the geographical proximity of their hotels .112 
(79) Jin Jiang submits that the Parties are not close competitors in the EEA, in view of 
their different brand positioning and minimal geographical overlap .113 
(80) In terms of brand positioning,  both Parties own hotel brands which are present 
across the EEA.114 The majority of respondents to the market investigation 
highlight that, in the EEA, the brand of the hotel is important for the choice of hotel 
in a given location by the final customer.115 
(81) The Jin Jiang brands are predominantly categorised in the EEA in the lower end 
of the market (2 -3 star hotels), while Radisson's brands are predominantly in the 
upper class categories (4 -5 star hotels) .116 In that regard, Jin Jiang's internal document 
drafted in preparation of the Transaction refers to the […] between the Parties.117 
(82) In light of the result of the market investigation and considering the evidence 
available to it, the Commission considers that the Parties' brands in the EEA are not 
particularly close to each other.  
(83) In terms of geographical proximity, the Commission, in its assessment of the 
affected cities (see section 5.3.4  below) will include an assessment of whether the  
Parties' hotels are geographically particularly close to each other or whe ther 
competing hotels could be found at similar or shorter distance . 
5.4.3.2.  Consumer brand loyalty and loyalty programmes  
(84) In Marriott International , the Commission found that brand loyalty of consumers, 
as well as loyalty programmes, d id not play any material rol e in the competitive 
assessment of the transaction in the markets for hotel accommodation services in 
the EEA . 
(85) Jin Jiang submits that the brand and the offering of loyalty programmes are not 
among customers' main selection criteria.118 
(86) The majority of respon dents to t he market investigation confirm ed that loyalty 
programmes, which are indicative of brand loyalty, are not among the strongest 
                                                 
112  Case M.7902 – Marriott International/Starwood Hotels & Resorts Worldwide , paragraph s 210 -224.  
113  Form CO, paragraph 213.  
114  In the EEA, Jin Jiang is mainly present through the Groupe du Louvre brands (Form CO, paragraph  
214).  
115  Replies to Q1 – Questionnaire to competitors, question 3.   
116  See Form CO, paragraphs 215 -219 for the comparison of the marketing of the Parties' hotel brands.  
117  Form CO, Annex 5.4.3 – Project Proposal by Shanghai Investment Consulting Corporation  (SICC), 31 
July 2018, p. 25.  
118  Form CO, paragraphs 153, 160 and 1026.  
21 drivers of consumer decisions in the EEA . In particular, the  importance of loyalty 
programmes for the choice of hotel in  a given location by the final customer is 
ranked lower than , for instance,  price or consumer rating .119 
(87) Two respondents  to the market investigation nevertheless indicated that the new Jin 
Jiang -Radisson entity will benefit from a more popular loyalty progra mme, which 
might contribute to redirecting part of the demand of Chinese travellers to its 
hotels .120 Nevertheless, the Commission notes that Radisson already belonged pre -
Transaction to a Chinese group active in the tourism sector (HNA Group). In 
addition, post-Transaction, Jin Jiang and Radisson combined will continue to face 
strong competition from other hotel chains active globally . As a n example, one of 
the largest hotel companies  indicate s that it offer s attractive loyalty programmes 
and that loyalty programme benefits are similar for all brands and networks.121 
Finally,  the majority of respondents to the market investigation consider that the 
Transaction will have no significant impact on their company.122  
(88) In light of the results of the market investigation and considering the evidence 
available to it, the Commission will not further consider consumer brand loyalty 
and loyalty programmes  in its assessment of the competitive effects of the 
Transaction.  
5.4.3.3.  Barriers to entry or expansion  
(89) In Marriott International , the Commission noted that there is a degree of 
dynamism in the EEA market with hotels changing brands and thus giving 
possibilities to competitors to enter the market .123 
(90) Jin Jiang submits that there are no material legal or regulatory barriers to prevent 
market entry, and no intellectual property rights or other related rights that would 
prevent or make market entry more difficult, and that will remain the case post -
Transaction .124 
(91) The market investigat ion has not revealed any indication that the Transaction 
would have any significant impact on any existing barriers to entry or expansion in 
the hotel accommodation sector . 
(92) In light of the results of the market investigation and considering the evidence 
available to it, the Commission considers that barriers to entry or expansion for the 
provision of hotel accommodation services in the EEA will not be materially 
impacted by the Transaction and do not change the competitive assessments at 
local level for eac h of the affected markets identified in paragraph (76) above . 
                                                 
119  Replies to Q1 – Questionnaire to competitors, question 3.   
120  Replies of two competitors to Q1 – Questionnaire to competitors, question 12.  
121  Replies of a competitor to Q1 – Questionnaire to competitors, question s 1 and 3.1.  
122  Replies to Q1 – Questionnaire to competitors, question 12.  
123  Case M.7902 – Marriott International/Starwood Hotels & Resorts Worldwide , paragraph  237. 
124  Form CO, paragraph 1038.  
22 5.4.4.  Assessment at local level  
5.4.4.1.  Düsseldorf  
The Parties' activities  
(93) There are 12 783 hotel rooms in Düsseldorf (city only), out of which 1 325 are in 
2-star hotels  (there is no 1 -star hotel) . Adding airport hotels, there are 14 251 hotel 
rooms in Düsseldorf, out of which 1 425 are in 2 -star hotels  (there is no 1 -star 
hotel ).125 
(94) In Düsseldorf, Jin Jiang operates  one 2 -star hotel (Premiere Classe Düsseldorf 
City), with 84 rooms, which is located in the city centre . The overlap in the market 
for 2 -star hotels in Düsseldorf only arises if a Radisson pipeline hotel,  Prizeotel 
Düss eldorf City (250 rooms) due to open in 2021  in the city centre , is taken into 
account .126  
The Commission's assessment  
(95) The market s for 2-star and 1&2 -star hotels would be affected with a combined 
market share of the Parties reaching [20-30]% on the narrowest  product market and 
geographic scope . The table below sets out the Parties market shares (2018 data).  
Table 2 – Market shares - Düsseldorf  
  City 
only City and 
airport    City only  City and 
airport  
Jin Jiang  2 stars  [5-10]% [5-10]%  1&2 stars  [5-10]% [5-10]% 
Radisson  2 stars  [10-20]% [10-20]%  1&2 stars  [10-20]% [10-20]% 
Combined  2 stars  [20-30]% [20-
30]%127  1&2 stars  [20-30]% [20-
30]%128 
Source: Form CO, Annex 7.1.  
(96) Therefore, post -Transaction,129 the market share of the merged entity would remain 
moderate, all the more so as, on a conservative basis, Jin Jiang has not included in 
the Parties' market share estimates data for pipeline projects of the Parties' 
competitors.130 
(97) In addition, in Düsseldorf , a number of 2 -star chain hotels compete actively in the 
market, including those operated  by international chain operators such as Accor 
                                                 
125  Form CO, Anne x 7.1.  
126  Form CO, paragraphs 537, 552 and Annex 7.1.  
127  Rounding effect.  
128  Rounding effect.  
129  After the opening of Radisson's 2 -star hotel scheduled in 2021.  
130  Form CO, paragraph 550.  
23 (with Ibis hotels) and B&B Hotels. Moreover, additional competition stems from 
independent 2 -star hotels ( for instance  Hotel Terminus Garni and A &O D üsseldorf 
Hauptbahnhof ).131 
(98) Furthermore, on a geographical level, the Parties' 2 -star hotels w ould not be 
particularly close competitors, since two 2-star Ibis hotels (Ibis Düsseldorf City and 
Ibis Düsseldorf Haup tbahnhof) are not more distant from  the Radisson pipeline 
hotel than the Jin Jiang's hotels.132 
(99) Finally, the majority of respondents to the market investigation having expressed 
an opinion indicated that there will be sufficient competition after the Transaction 
to prevent Jin Jiang and Radisson combined from raising the prices or degrading 
the quality of the hotel accommodation services they provide in Düsseldorf .133 
(100)  Overall, given the Parties' market shares, the presence of significant competitors 
and the fact that n o material concern was expressed during the market 
investigation, the Commission considers that the Transaction is unlikely to lead to 
any significant competition concerns for the market for 2 -star hotel accommodation 
services in Düsseldorf city.  
 
Conclusi on 
(101)  In light of the results of the market investigation and considering all evidence 
available to it, the Commission considers that the Transaction does not raise serious 
doubts as to its compatibility with the internal market with respect  to the market for  
hotel accommodation services in Düsseldorf, under any plausible segmentation.  
5.4.4.2.  Marseille  
The Parties' activities  
(102)  There are 7 704  hotel rooms in Marseille (city only), out of which 2 266  are in 4-
star hotels  and 344 are in 5 -star hotels . Adding airport hote ls, there are 8 002  hotel 
rooms in Marseille , out of which 2 444  are in 4-star hotels  and 344 are in 5 -star 
hotels .134 
(103)  In Marseille , Jin Jiang operates  two 4-star hotel s (Golden Tulip Marseille Euromed  
and Golden Tulip Marseille Villa Massalia ), with  350 rooms together (respectively 
210 and 140 rooms) , which are located in the city centre . Radisson operates  one 4 -
star hotel (Radisson Blu Hotel Marseille Vieux Port), with 1 88 rooms, which is 
located in the city centre .135  
  
                                                 
131  Form CO, paragraph 560 and Annex 7.1.  
132  Form CO, map in paragraph 555.  
133  Replies to Q1 – Questionnaire to competitors, question 13.  
134  Form CO, Annex 7.1.  
135  Form CO, paragraph  389 and Annex 7.1.  
24 The Commission's assessment  
(104)  The markets for 4 -star and 4&5 -star hotels would be affected with a combined 
market share of the Parties reaching [20-30]% on the narrowest product market and 
geographic scope.  The table below sets out the Parties market shares (2018 data).  
Table 3 – Market shares - Marseille  
  City only  City and 
airport    City only  City and 
airport  
Jin Jiang  4 stars  [10-20]% [10-20]%  4&5 stars  [10-20]% [10-20]% 
Radisson  4 stars  [5-10]% [5-10]%  4&5 stars  [5-10]% [5-10]% 
Combined  4 stars  [20-30]% [20-30]%  4&5 stars [20-
30]%136 [10-
20]%137 
Source: Form CO, Annex 7.1.  
(105)  Therefore, post -Transaction, the market share of the merged entity would remain 
below 25%, which, according to the Horizontal Merger Guidelines, is indicative of 
a non -problematic transaction.138  
(106)  In addition, in Marseille, a number of 4 -star chain hotels compete actively in the 
market, including those operated by international chain operators such as Accor 
(with  notably  Novotel and Mercure hotels) , NH Hotel and Best Western . 
Moreover, additional compe tition stems from independent 4 -star hotels ( for 
instance Grand Tonic Hôtel Marseille Vieux Port, La Résidence du Vieux Port) .139  
(107)  Furthermore, on a geographical level, the Parties' 4 -star hotels are not particularly 
close competitors, since a number of 4-star hotels operated notably by Accor and 
NH Hotel are not more distant from  the Radisson hotel than the Jin Jiang's 
hotels.140  
(108)  Finally, the majority of respondents to the market investigation having expressed 
an opinion indicated that there will be suffi cient competition after the Transaction 
to prevent Jin Jiang and Radisson combined from raising the prices or degrading 
the quality of the hotel accommodation services they provide in Marseille.141 
(109)  Overall, given the Parties' market shares, the presence of significant competitors 
and the fact that no material concern was expressed during the market 
investigation, the Commission considers that the Transaction is unlikely to lead to 
                                                 
136  Rounding effect.  
137  Rounding effect.  
138  Horizontal Merger Guidelines, paragraph 18.  
139  Form CO, Annex 7.1.  
140  Form CO , map in paragraph 391. 
141  Replies to Q1 – Questionnaire to competitors, question 13.  
25 any significant com petition concerns for the market for 4 -star hotel accommodation 
services in Marseille city.  
Conclusion  
(110)  In light of the results of the market investigation  and considering all evidence 
available to it, the Commission considers that the Transaction does not raise serious 
doubts as to its compatibility with the internal market with respect to the market for 
hotel accommodation services in Marseille, under any plausible segmentation.  
5.4.4.3.  Northampton  
The Parties' activities  
(111)  There are 2 548 hotel rooms in Northampton , out of which 1 195 are in 3 -star 
hotels.142 
(112)  In Northampton , Radisson  operates  one 3-star hotel ( Park Inn by Radisson 
Northampton ), with 146 rooms . Jin Jiang operates one  3-star hotel under one of its 
brands (Campanile Northampton), with 87 rooms. However, the 3 -star market in 
Northampton is not affected taking account of these two hotels only.143 The 
Transaction gives rise to an affected market in Northampton  only if the activities of 
the 3 -star hotel (Holiday Inn Northampton , 105 rooms) managed by Kew Green 
Hotels, controlled by anot her Chinese State -owned company,  are attributed to Jin 
Jiang .144 
The Commission's assessment  
(113)   The market for 3 -star hotels would be affected with a combined market share of 
the Parties reaching [20-30]%. The table below sets out the  Parties market shares 
(2018 data).  
Table 4 – Market shares - Northampton  
  City 
Jin Jiang  3 stars  [10-20]% 
Radisson  3 stars  [10-20]% 
Combined  3 stars  [20-30]% 
Source: Form CO, Annex 7. 2. 
(114)  Therefore, post -Transaction, the market share of the merged entity would remain 
moderate.  
                                                 
142  Form CO, Annex 7.1.  
143  The Parties' combined market share reaches [10-20]%. 
144  Form CO, paragraphs 961 , 966 and Annex es 7.1 and 7.2 . 
26 (115)  In addition, in Northampton, a number of 3 -star chain hotels compete actively in 
the market, including those operated by international chain operators such as IHG 
(which operates another Holiday Inn than the one managed by Kew  Green Hotels) 
and Premier Inn. Moreover, additional competition stems from independent 3 -star 
hotels ( for instance The Westone Manor Hotel ).145  
(116)  Furthermore, on a geographical level, the Parties' 3 -star hotels would not be 
particularly close competitors, si nce they are not located in the same area ( Park Inn 
by Radisson Northampton  is in the very city centre, Campanile Northampton is in 
the Southern part of the city and Holiday Inn Northampton  is in the Eastern part of 
the city). As an example, another 3 -star Holiday Inn hotel, not managed by Kew 
Green Hotels (Holiday Inn Express Northampton – South), is located in the 
immediate vicinity of Campanile Northampton operated by Jin Jiang .146  
(117)  Finally, the majority of respondents to the market investigation having ex pressed 
an opinion indicated that there will be sufficient competition after the Transaction 
to prevent Jin Jiang and Radisson combined from raising the prices or degrading 
the quality of the hotel accommodation services they provide in Northampton .147 
(118)  Overa ll, given the Parties' market shares, the presence of significant competitors 
and the fact that no material concern was expressed during the market 
investigation, the Commission considers that the Transaction is unlikely to lead to 
any significant competit ion concerns for the market for 3-star hotel accommodation 
services in Northampton . 
Conclusion  
(119)  In light of the results of the market investigation  and considering all evidence 
available to it, the Commission considers that the Transaction does not raise se rious 
doubts as to its compatibility with the internal market with respect to the market for 
hotel accommodation services in Northampton , under any plausible segmentation.  
5.4.4.4.  Stansted  
The Parties' activities  
(120)  There are 2 176 hotel rooms in Stansted, out of which 1 350 are in 3 -star hotels and 
791 are in 4 -star hotels.148 
(121)  In Stansted, Radisson operates one 4 -star hotel ( Radisson Blu Hotel London 
Stansted Airport ), with 494 rooms . The Transaction gives rise to an overlap in 
Stansted and to affected markets only if the activities of the 3 -star hotel ( Holiday 
Inn Express London Stansted Airport , 254 rooms) managed by Kew Green Hotels, 
controlled by another Chinese State -owned company, are attributed to Jin Jiang.149 
                                                 
145  Form CO, paragraph 972 and Annex 7.1.  
146  See map of hotels in Northampton on www.booking.com  
147  Replies to  Q1 – Questionnaire to competitors, question 13.  
148  Form CO, Annexes 7.1 and 7.2 . 
149  Form CO, Annexes 7.1 and 7.2 . 
27 The Commission's assessment  
(122)  The markets for 3& 4-star, 2&3&4 -star, 3&4&5 -star, and all -star hotels would be 
affected with a combined market share of the Parties reaching [30-40]% on the 
narrowest product market (3&4 -star hotels).  The table below sets out the Parties 
market shares (2018 data).  
Table 5 – Market shares - Stansted  
  Airport    Airport  
Jin Jiang  3&4 stars  [10-20]%  2&3&4 stars  [10-20]% 
Radisson  3&4 stars  [20-30]%  2&3&4 stars  [20-30]% 
Combined  3&4 stars  [30-40]%  2&3&4 stars  [30-40]% 
 
 
 
  Airport    Airport  
Jin Jiang  3&4&5 stars  [10-20]%  All stars  [10-20]% 
Radisson  3&4&5 stars  [20-30]%  All stars  [20-30]% 
Combined  3&4&5 stars  [30-40]%  All stars  [30-
40]%150 
Source: Form CO, Annex 7. 2. 
(123)  Therefore, post -Transaction, the market share of the merged entity would remain 
moderate.  
(124)  In addition, in Stansted, a number of 3 -star and 4 -star chain hotels compete actively 
in the market, including those operated by international chain operators such as 
Accor (with a Novotel hotel), Hilton and Premier Inn. Moreover, additional 
competition stems from inde pendent 3 -star and 4 -star hotels ( for instance Desalis 
Hotel London Stansted ).151 
(125)  Moreover, Stansted airport has quick, frequent and multiple transportation links to 
London. Therefore, the Parties' market position considering Stansted does not 
necessarily pr ovide a fair picture of the competition exerted by hotels located in 
cities  connected by public transport to Stansted airport , in particular London.  
(126)  Furthermore, one of the hotels  operated by a third party  chain (Hampton by Hilton 
London Stansted airport)  competes more closely with Jin Jiang's hotel ( Holiday Inn 
Express London Stansted Airport ) than Radisson's hotel ( Radisson Blu Hotel 
London Stansted Airport ), to the extent than both are 3 -star hotels and the 
competing hotel is located closer to Jin Jiang 's hotel than Radisson's hotel.  Besides, 
the distance between Jin Jiang's 3 -star hotel and Radisson's 4 -star hotel is 
                                                 
150  Rounding effect.  
151  Form CO , Annex 7.1.  
28 comparable to the distance between Jin Jiang's 3 -star hotel and a 4 -star hotel 
operated by a chain competitor (Novotel London Stansted Air port).152 
(127)  Finally, the majority of respondents to the market investigation having expressed 
an opinion indicated that there will be sufficient competition after the Transaction 
to prevent Jin  Jiang and Radisson combined from raising the prices or degrading 
the quality of the hotel accommodation services they provide in Stansted.153 
(128)  Overall, given the Parties' market shares, the presence of significant competitors 
and the fact that no material co ncern was expressed during the market 
investigation, the Commission considers that the Transaction is unlikely to lead to 
any significant competition concerns for the market for 3&4 -star hotel 
accommodation services in Stansted.  
Conclusion  
(129)  In light of the results of the market investigation  and considering all evidence 
available to it, the Commission considers that the Transaction does not raise serious 
doubts as to its compatibility with the internal market with respect to the market for 
hotel accommodatio n services in Stansted , under any plausible segmentation.  
6. CONCLUSION  
(130)  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  
 
 
                                                 
152  See map of hotels in the area Stansted airport on www.booking.com  
153  Replies to Q1 – Questionnaire to competitors, question 13.  In particular: "The re is one Radisson Hotel 
in Stansted amongst other chains including Novotel, Hilton, Premier Inn, Holiday Inn plus 
independents – not convinced that the Stansted Airport market can sustain a massive increase in hotel 
supply so new development will need to be very considered"  (reply of a competitor to Q1 – 
Questionnaire to competitors, question 13 .1).