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,  23.09.2020  
C(2020 ) 6652 final  
PUBLIC VERSION  
 
To the notifying party  
Subject : Case M. 9560 – Gränges/Impexmetal  
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 19 August 2020 , the European Commission (the ‘Commission’) received 
notification of a concentration pursuant to Article 4 of the Merger Regulation which 
would result  from a proposed transaction by which  Gränges AB (publ) (‘Gränges’ , 
Sweden) intends to  acquire  control within the meaning of Article 3(1)(b)  over the 
whole of Impexmetal S.A. (‘Impexmetal’ or the ‘Target’, Poland), by way of 
purchase of shares (‘the Trans action’) .3 Gränges is referred to hereinafter as the 
‘Notifying Party’ and together with Impexmetal as ‘the Parties’.  The undertaking that 
would result from the Transaction is referred to as 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 introduced 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 Official Journal of the European Union No C 286, 31.8.2020 , p. 2. 
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information omitted has been replaced by 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) Gränges  manufactures and supplies aluminium flat rolled products (‘FRPs’) for 
customers in the automotive industry, the heating, ventilation and air conditioning 
(‘HVAC’) industry and niche sectors such as transformers and food packaging.  
(3) Impexmetal  manufactures  and supplies aluminium FRPs for the automotive industry, 
closure manufacturers, and companies within electronics.  
(4) Impexmetal is active in aluminium FRPs operations through its division Aluminium 
Konin . Apart from aluminium, the Target is active within cop per, brass, lead and 
zinc. However, a disposal of these other activities will take place prior to the closing 
of the Transaction  so that only the Aluminium Konin business will remain in the 
Target when the transaction is closed.  
2. THE CONCENTRATION  
(5) Pursuant to a share purchase agreement dated 27 November 2019, Gränges will 
acquire sole control over Impexmetal (only containing the Aluminium Konin 
business) by purchasing all the shares in the Target.  
(6) It follows that the Transaction would result in a concentrat ion within the meaning of 
Article 3(1)(b) of the Merger Regulation . 
3. UNION  DIMENSION  
(7) The Transaction does not have an Union dimension within the meaning of Article 1 
of the Merger Regulation because the combined aggregate worldwide turnover of 
Gränges and I mpexmetal is not more than EUR 2 500 million.  
(8) However, on 13 December 2019 , Gränges submitted a request for a referral to the 
Commission pursuant to Article 4(5) of the Merger Regulation ( the ‘Form RS’). The 
request fulfilled  the two conditions set out in  Article 4(5) of the Merger Regulation 
in that (i) it referred to  a concentration within the meaning of Article 3 of the Merger 
Regulation that (ii) it had to be notified in at least three Member States.  In addition, 
the Transaction fulfil led a number of f urther criteria set out in the Commission’s 
Notice on Case Referral.4 In this regard, since the case extended over territories 
reaching beyond national boundaries , the markets involved were larger than national , 
the case required investigative efforts in several countries as well as appropriate 
enforcement powers, the Commission concluded it was in the best position  to review 
the Transaction.  
(9) The Form RS was transmitted to all EU Member States and none of them expressed 
their disagreement to the referral. The Transaction is therefore deemed to have a 
Union dimension.  
                                                 
4  Commission Notice on Case Referral in respect of concentrations (‘ Commission’s Notice on Case 
Referral ’), OJ C 56, 05.03.200 5, p. 2 -23. 
 
3 4. INTRODUCTION TO ALUMI NIUM FLAT -ROLLED PRODUCTS  
(10) The Transaction brings together  Gränges ’ and  Impexmetal ’s manufacture and supply 
of aluminium FRPs . For the purpose of the merger control assessm ent of the 
Transaction, this section introduces the Commission’s understanding of the basic 
characteristics of aluminium FRPs.  
4.1. Different types of aluminium FRPs – Automotive HEX materials  
(11) Aluminium FRPs are a group of semi -finished flat aluminium produ cts that are 
produced in hot and cold rolling mills. FRPs are produced from aluminium sheet 
ingots, sometimes referred to as rolling ingots or slabs, which are either produced 
from primary aluminium or from scrap (secondary aluminium).5 Cold rolling mills 
are used where flat products need to be rolled thinner.6  
(12) Aluminium FRPs comprise over 15 categories of products, some of which 
correspond to a specific end application, whereas some others are multi -purpose 
products. In general, rolling mills may be confi gured in such a way as to produce 
various types of FRPs depending on the final application (the so -called ‘product 
mix’).7 
(13) CRU,8 a provider of analysis, prices and consulting in the mining and metals market , 
has divided Aluminium FRPs into the various segm ents shown in Figure 1 below.  
Figure 1. Segments within aluminium FRPs   
 
Source: Notifying Party’s Response to Pre -Notification RFI 4, question  2 
                                                 
5  Commission decision of  29 September  2003, ALCAN/PECHINEY (II) (M.3225), paragraph 54.  
6  See Form CO, paragraph 164 and minutes of a call with a competitor of 20 March 2020, paragraph 11.  
7  The categories of FRPs that mills can produce incl ude common material alloy (1xxx, 3xxx, 5xxx), paint 
stock & sheet, foil stock and foil, beverage can body stock, beverage can end stock, food can stock, bright 
sheet, brazing sheet, plate and shate, lithographic sheet, fin stock, other thin gauge (3xxx and  5xxx), 
automotive sheet and heat treat. See Commission decision of  29 September  2003, ALCAN/PECHINEY 
(II) (M.3225), paragraph 55.  
8  For more information on CRU, see https://www.crugroup.com/ . 

 
4 (14) Standard aluminium FRPs (‘Standard FRPs’) are a category within aluminium FRPs . 
This category,  as will be discussed in the product market definition in Section 5 
below , consists of all FRPs that do not constitute distinct product markets within the 
field of aluminium FRPs.9  
(15) Aluminium FRPs for automotive heat exchangers (‘Automotive HEX’)  are a 
category within aluminium  FRPs . This category is marked in orange in Figure 1 
above. Automotive HEX materials can be divided into three categories which vary in 
shape and thickness : material for plates, tubes and fins.10 These categories are 
comprised within two segments: brazing sheet and finstock:  
(16) Brazing sheet segment: is comprised of material for plates and tubes.  
 Material for p lates: Usually has a thickness of more than 0.4mm.  Material for 
plates serves for producing p lates.  Plates consist of a core alloy clad with braze 
clad on one or two sides. The rolled product is stamped or shaped by the 
customer, depending on the application. Plates are used in many kind of HEX 
applications, either for coolant plates or manifolds.11  
 Material for t ubes:  Usually has  a thickness of between 0.2 mm to 0.4 mm . 
Material for tubes serves for producing tubes. Tubes can be used for both 
welded and folded tube designs.12 
(17) Finstock: is comprised of material for fins (both clad and unclad, as wil l be 
explained in paragraph (19) below).  
 Material for f ins: Usually has  a thickness of less than 0.2 mm . Material for fins 
serves for producing fins.  Fins are used for applications such as radiators, 
heaters, charge air coolers and evaporators. For heat exchangers, the fins’ 
function is to improve cooling performance. They also create structural 
integrity and work as a sacrificial part to prevent corro sion of the aluminium 
tubes (by directing the corrosion away from the tube material and absorbing 
the corrosion).13 
(18) Automotive HEX materials for fins can be either clad or unclad. Clad products 
consist of a core alloy with clad layers on one or two sides. C ladding consists of 
scalping a slab to remove an oxide layer, pre -heating and hot rolling into a long plate 
which is cut into smaller plates. These plates are then put on top and bottom of 
another so -called core slab to form a package of different alloys.14 
                                                 
9  Commission decision of  29 September  2003, ALCAN/PECHINEY (II) (M.3225), paragraph 61.  
10  See Form CO, paragraph 38.  
11  See Form CO, paragraphs 108 and 267.  
12 See Form CO, paragraphs 108 and 267. Please note that, while tubes can be clad or unclad, unclad tubes 
are ma de by a process of extrusion and are not FRPs. The Commission has previously considered that 
FRPs and extrusions belong to two different product markets (see Commission decision of 
2 October  2007, RIO TINTO/ALCAN (M.4827), paragraph 33). Therefore, for the  purposes of this 
Decision, if not explained otherwise the Commission refers to clad tubes when mentioning tubes.  
13  See Form CO, paragraphs 108, 267 and 285.  
14  See Form CO, paragraph 161 and m inutes of a call with a competitor of 20 March 2020, paragraph  4. 
 
5 (19) Both unclad and clad fins have the same function in HEX, i.e. to improve cooling 
performance.15 Unclad fins are made of a single layer of alloy. Clad fins are made of 
clad material similar to brazing sheet, consisting of multiple layers.16 Clad fins are 
predominantly used in an application called a condenser, a part of the air -
conditioning loop in a vehicle which makes it possible to cool the cabin. The 
condenser typically has two different designs. One design uses clad fins and unclad 
tubes and the other de sign uses unclad fins and clad tubes.17 However, other designs 
could be possible, for example, water -cooled  condensers. This concept would be a 
stack disc cooler where the refrigerant is cooled by means of a coolant. In the 
condenser, the refrigerant in the  tubes is cooled with air from the outside by the 
airstream.18 
4.2. The production process of standard aluminium FRPs and Automotive HEX 
materials  
(20) The Automotive HEX materials are delivered to the producers of automotive heat 
exchangers in the form of aluminium coil, aluminium plates and aluminium strips. 
Those customers then use the Automotive HEX materials to create the HEX 
components (plates, tubes and fins) and assemble them into an Automotive HEX. 
Customers need to go  through a process of validation in terms  of properties 
(strength, corrosion, formability, etc.) for the materials or the suppliers they are 
going to use (they can validate more than one supplier if needed) . Customers then 
provide the Automotive HEX to car manufacturers  (the ‘OEMs’) .19  
(21) There are two basic processes for producing Standard  FRPs: direct -chill casting and 
continuous casting. Direct chill casting can be used to produce all Standard FRPs. 
Some categories of aluminium  FRPs can also be produced using continuous casting: 
unclad fins, build ing sheet, foil stock and other 3x thin gauge.20 The production 
process analysed in paragraphs (22) and ff. is that of the direct -chill casting, as it 
covers all Standard FRPs and it is the process used by the Parties to the Transaction.  
(22) Aluminium FRPs are produced using similar machinery, and involve several 
common steps, although depending on the product, certain adjustments (primarily 
and the finishing stage) ar e required to produce different aluminium FRPs.21  
(23) The production process is as follows:22 
(a) Slabs: An aluminium ingot with the correct alloy chemistry is direct -chill 
cast. This is the first stage in making all FRPs.   
(b) Cladding (only for clad products): Consis ts of scalping a slab to remove an 
oxide layer, pre -heating and hot rolling into a long plate which is cut into 
smaller plates. These plates are then put on top and bottom of another 
                                                 
15  See Form CO, paragraph 285.  
16  Annex 6.1 to the Form CO, Section 2.1.  
17  See Form CO, paragraph 286.  
18  See two responses to the request for information sent to car manufacturers, question 1(e) received on 
2 and 3 September 2020.  
19  See Form CO, paragraphs 109, 156 and 379.  
20  Annex 6.1 to the Form CO, footnote 7.  
21  See Form CO, paragraph 160.  
22  See Form CO, paragraph 161.  
 
6 so-called slab, to form a package of different alloys. As cladding only a pplies 
to clad products, unclad products do not have this stage.  
(c) Pre-heating, hot rolling, cold rolling and annealing: these stages apply to all 
products. However, even though the cold rolling machines  can in principle be 
universal  for production of Standa rd FRPs and Automotive HEX materials, 
there are differences in the need of cold rolling capacity, due to differences in 
final product thickness. The thinnest product group within Automotive HEX 
materials, material for fins, requires most cold rolling capac ity, while 
material for plates as the thickest product group requires the least amount of 
cold rolling capacity.23  
(d) In practice, suppliers often use a heavy gauge machine for the initial cold 
rolling followed by a lighter gauge machine to roll thinner mater ial. Mills can 
be segmented into ‘breakdown mills’ for heavy gauge (0.5 -5mm) and mills 
for intermediate/light gauge (0.03 -0.05-1mm). Some companies have 
universal mills, which can cover a wide gauge range, but these are not as 
productive as mills specially  designed for light gauges. Therefore, most 
suppliers have a set -up of at least two mills (breakdown mill and finishing 
mill) or three or more mills (breakdown mill, intermediate mill, finishing 
mill) to cover the gauge range from plate over tube to fin.  
(e) Finishing: Applies to all products. However, finishing (and hence finishing 
machines) is different depending on the product. For example, Automotive 
HEX materials for plates and tubes undergo an initial finishing stage called 
tension levelling, which is not  applied to material for fins. Material for plates 
is slit using a heavy gauge slitting machine, and tubes, clad fins and unclad 
fins are slit using a light gauge slitting machine. Other aluminium  FRPs can 
be finished using tension levelling and either a s litting or a cut -to-length 
machine.   
(24) Therefore, while the machinery for some of the production steps is similar, there are 
certain differences in the capacity and machinery required by product, most notably 
in the cold rolling mills (to achieve a certain p roduct thinness) and in the finishing 
lines.  
4.3. Automotive HEX materials c ustomers ’ purchase process  
(25) Customers source Automotive HEX materials through tenders. These follow a 
typical B2B organisational buying process, where customers define their raw 
material  specifications, and conduct  a standard search to identify suppliers that offer 
what they are looking for. The Automotive HEX materials customer s then request  
the identified suppliers to quote for the specified materials, review  the proposals and 
make a ch oice.24  
                                                 
23  See Form CO, paragraph 164.  
24  See Form CO, paragraph 37 0. 
 
7 (26) The selection process involves a review of the proposals (quotations) submitted, 
including price as well as consideration of the supplier’s quality performance, 
delivery performance, R&D capabilities, previous experiences etc.25  
(27) The customers then short -list a number of suppliers, who are invited to meet with 
them to discuss the proposal and address any questions, concerns or gaps. At this 
stage, the customer may attempt to negotiate final, advantageous terms with each of 
the short -listed vendors. B ilateral negotiations are typically used for supplier 
selection.26 
(28) After negotiations, the customer and the supplier agree on a supply agreement that 
lists technical specifications for the different materials, price, volumes, 
logistic/freight conditions, etc. The agreement may involve several product 
specifications and may be multi -year.27 Typically, agreements are concluded for 2 to 
5 years and the contract time is independent from the product category (i.e. material 
for plates, tubes and fins) .28  
(29) Customers  consider  multi -sourc ing useful29 but the decision depends mostly on 
whether there is enough budget, the volume of the project, and whether the 
manufacturing plant can handle two suppliers for the same application. Customers 
consider multi -sourcing good, to avoid supply disruptions: ‘Mult isourcing is 
required in order to avoid any supply source risk and to safeguard the supply 
chain .’30, but as one customer stated: ‘On individual project (HEX product for a car 
model) level with an OEM mostly just one supplier is validated. On category basis  
(for example tube or fin), several suppliers are qualified. Validation cost to achieve 
dual sourcing on project level is generally very high. Therefore, risk management 
must at least be done on category level to be able to offer emergency solution to 
OEMs  in case of supply issues ’.31  
4.4. Automotive HEX materials’ validation process  
(30) Both Automotive HEX materials’ customers (tier suppliers) and end -customers 
(e.g. OEMs ) need to validate the materials .32 This validation is done according to the 
requirements of the  OEM.33 
(31) Customers need to validate the material before purchasing it for the first time.34 This 
is called the material validation process. During this process, the customer is testing 
for inter alia  strength, corrosion and formability, after they have formed/brazed the 
heat exchanger together.35 Therefore, every time the Automotive HEX materials 
customers need a new product, suppliers need to produce new material (alloy, gauge, 
width, temper) to fulfi l the customers’ requirements on strength, corrosion, 
                                                 
25  See Form CO, paragraph 370.  
26  See Form CO, paragraph 370.  
27  See Form CO, paragraph 370.  
28  Questionnaire to customers, question D.C.7.  
29 Questionnaire to customers, question D.C.2.1.  
30  Questionnaire to customers, question D.C.2.1.  
31  Questionnaire to customers, question D.C.2.1.  
32  Questionnaire to customers, q uestion D.C.1.1.  
33  Questionnaire to customers, question D.C.1.1.  
34  There is no need to validate the machinery.  
35  See Form CO, paragraph 374.  
 
8 formability or similar requirements.36 If suppliers change materials without 
informing the customers, they may be reported. As a customer submitted: ‘ Suppliers 
shall be reported if they change like the 4 Ms (Material/Machine/Men/Method) ’.37  
(32) Further, if changes occur in suppliers’ production lines (new machinery or changed 
process) then they need to apply for a change request for a renewed material 
validation at the customer and show that the new material i s the same as the old 
material in terms of properties (strength, corrosion, formability, etc.).38  
(33) The supplier’s material also has to be proposed to the OEM and accepted by it. This 
includes technical presentations, product testing and validation.39 In addi tion, IATF 
16949 certification is mandatory for suppliers to the automotive industry.40 
(34) Validation times vary per product  and end -customer . Duration and qualification 
requirements are specific to each OEM.41 The process can take up to two years.42For 
example,  a competitor points at the following steps and duration: ‘ Typical steps: 
1) Lab testing at HEX manufacturer of materi al properties (9 -12 months); 
2) Material validation at HEX manufacturer of material used on specific customer 
application. In some cases a lso partially done by end -customer (car manufacturer) 
12-15 months); 3) Process validation at HEX manufacturer plant (3 -6 months).’43 
(35) As one customer stated: ‘As a first step the supplier must be certified for the needs of 
automotive quality requirements (I ATF and audit specific customer requirements). 
Once the supplier is certified, a process for validation of supplier process and 
product (material) is performed. Once supplier validations are completed and 
declared as conform, Tier 1 will validate the mater ial on the heat exchanger by 
performing a design and product validation, based on a testing plan discussed and 
agreed with the OEM. Tests results will be then presented to the OEM, which will as 
well perform tests on its side (including sometime vehicle te sts). This long and heavy 
process, including administrative tasks and lead times  for production, usually takes 
more than two years ’.44  
5. PRODUCT MARKET DEFINI TION  
(36) The Parties activities overlap45 in the production of aluminium FRPs , including 
Standard FRPs and all segments of Automotive HEX. In the EEA, both Parties 
                                                 
36  See Form CO, paragraph 375.  
37  Questionnaire to customers, question D.C.1.1.  
38  See Form CO, paragraph 376.  
39  Questionnaire to customers, question D.C.1.1.  
40  Questionnaire to competitors, question D.C.1.1.  
41  Questionnaire to competitors, question D.C.1.1.  
42  Questionnaire to customers, question D.C.1.1., questionnaire to competitors, question D.C.1.1.  
43  Questionnaire to competito rs, question D.C.1.1.  
44  Questionnaire to customers, question D.C.1.1.  
45  The Parties also have a small overlap in the supply of rolled aluminium products to the HVAC/ R HEX 
sector (‘HVAC/ R HEX FRPs’), also a part of the larger S tandard FRP segment, in the EEA. This industry 
includes systems for heating, ventilation and air -conditioning in private homes, and in commercial and 
industrial buildings. The Parties argue that HVAC/R HEX FRPs is not a separate market from the wider 
Stand ard FRPs. However, under any plausible market definition, including HEVAC/R HEX FRPs as a 
separate market, the Parties’ combined market share would be [0-5]% in the EEA and [10 -20]% on a 
 
 
9 produce, sell and deliver both Standard FRPs and Automotive HEX material s for 
plates, tubes and fins with different gauges, widths, tempers  and alloys.46 Therefore, 
the Transaction gives  rise to h orizontal overlaps with respect to the manufacture and 
supply of Standard  FRPs and of Automotive HEX  materials .  
5.1. The Commission’s precedents  
(37) In previous decisions, the Commission segmented aluminium FRPs into several 
separate product markets, one of them b eing Standard FRPs .47 The Commission 
considered that there exists a distinct market for Standard FRPs consisting of all 
FRPs that do not constitute distinct product markets within the field of FRPs . The 
market for Standard FRPs would  include standard sheet,  plates, foil stock, etc.  for 
which , there exists a certain degree of supply side substitutability . The market 
investigations in these previous cases indicated that aluminium producers were able 
to produce the full range of Standard FRPs, switching production between the 
different types within a short period of time and without incurring significant 
additional costs .48 
(38) In one case, the Commission contemplated the possibility of considering brazing 
sheet (i.e. sheet for tubes and plates) for the use in  heat exchangers as a separate 
product market.49 However, the product market definition was left open.  
5.2. The Notifying Party’s view  
(39) The Notifying Party submits that  the relevant product market in this case is the 
supply of Standard FRPs. The Notifying Party c onsider s that Standard FRPs belong 
to the same product market as  aluminium FRPs for Automotive HEX material s. The 
Notifying Party considers the supply of Standard FRPs as the relevant product 
market for the following reasons :50 
(a) There is a large overlap betw een the production stages required not only  for 
aluminium FRPs for Automotive HEX but for aluminium FRPs more 
generally . Therefore, Gränges argues that it is possible for suppliers to flex 
between the production of aluminium FRPs for Automotive HEX. Moreov er, 
as the main suppliers of aluminium FRPs for Automotive HEX  already 
produce plates, tubes and either clad or unclad fins, they are able to flex 
production volumes between various types of Automotive HEX that they 
produce without incurring in material in vestment costs.   
                                                                                                                                                      
global market with predominant significance in North America. Therefo re, HVAC/R HEX FRPs does not 
constitute an affected market and will not be analysed further.  
46  Form CO, paragraphs 10 and 11.  
47  According to the Commission’s precedents FRPs have thus been segmented into the following seven 
distinct product markets: (i) beverage can bodies; (ii) beverage can ends; (iii) food can bodies; 
(iv) lithographic sheet; (v) aluminium foil, which in turn may be divided into container foil, converter foil, 
household foil and industrial foil; (vi) automotive sheet; and (vii) Standard  FRPs. ( M.4605  - Hindalco / 
Novelis, paragraph 13 ). 
48  Commission decision of  29 September  2003, ALCAN/PECHINEY (II) (M.3225), paragraph 61; 
Commission decision of  4 March 2002,  Norsk Hydro /VAW (M.2702), paragraph 11.  
49  Commission decision of 26 June 200 1, ELKEM/SAPA (M.2404), paragraph 19.  
50  Form CO, paragraph 21, and Annex 6.1 to the Form CO.  
 
10 (b) The machinery used for Automotive HEX FRPs and other Standard FRPs is 
similar . Costs and time for installation of machinery are limited (no barriers 
to entry) , it would take probably less than 6 months to move into an adjacent 
segment (e.g . from clad tube to clad fin) ;51  
(c) There is significant spare capacity, which facilitates supply -side expansion. 
Subsequently, the Notifying Party argues that suppliers are able to expand 
production to produce another material type in the short term by utili sing the 
existing equipment ;52 
(d) A 5-10% price rise for Automotive HEX could induce volumes to be 
switched from other Standard FRPs to Automotive HEX FRP production . As 
supply -side substitution is likely to be profitable, separate markets for 
Automotive HEX should not be defined.  
(e) For the narrower segments of material for clad fins and unclad fins, t he 
Notifying Party argues that there is  also demand -side substitutability for these 
types of products . With the introduction of more corrosion resistant tube 
stock , more condenser designs are using external unclad fins. Therefore, 
Gränges believes that if the price of clad fins increased, customers that have a 
secondary condenser design that uses unclad fins could switch to unclad 
fins.53 
5.3. The Commission’s assessment  
(40) A wide majority of customers and competitors who expressed an opinion in the 
market investigation on this point submitted that  they cannot use Standard FRPs 
instead of aluminium FRPs for Automotive H EX for the same applications neither 
overall or in terms of price, use/end applications, product characteristics and 
efficiency.54 As one customer stated : ‘Automotive heat exchangers products are not 
generic flat rolled aluminium alloys but customized per application, tailor made in 
chemical composition, mechanic al properties, dimensional tolerances .’55; and a 
competitor mentioned : ‘Aluminium FRPs for Automotive HEX are in general 
completely different products than Standard FRPs. For example, Standard products 
are for building applications, Foilstock or General Eng ineering, while Automotive 
HEX products are made for heat exchanger for passenger cars or trucks. A big part 
of this products is clad, which means the products have a core alloy and on top a 
clad layer which allows the customer to braze material together i n order to produce 
a heat exchanger. The Standards FRPs do not have alloy combinations in one 
product ”.56 
(41) All customers and a  large majority of competitors who expressed an opinion in the 
market investigation on this point consider that Automotive HEX mater ial for  
(i) plates (with a thickness of >0.4 mm), (ii) tubes (with a thickness between 0.2 mm 
                                                 
51  Annex 6.1, paragraph 3.1.1.  
52  Form CO, paragraph 103.  
53  See Form CO, paragraph 287.  
54  Questionnaire to customers, questions B.1 and B.1.1; questionnaire to competitors, questions B.1 
and B.1.1.  
55  Questionnaire to customers, question B.1.1.  
56  Questionnaire to competitors, question B.1.1.  
 
11 and 0.4 mm) and  (iii) fins (with a thickness of <0.2 mm) belong to separate product 
markets due to limited substitutability for customers in terms of, e.g., product 
characteristics, applications and prices .57 Also a large majority of customers and 
competitors consider clad fins are not interchangeable with unclad fins due to limited 
substitutability for customers in terms of, e.g., product characteristics, appl ications 
and prices .58 In this respect,  a customer stated : ‘Clad fin materials are developed 
and/or selected for specific functionality and/or technical requirement. Thus, clad 
and unclad fin materials are not substitutable each other by its technical natur e.’59 
The m ajority of competitors considered that t he supply side substitutability between 
different types of Automotive HEX is limited .60 
(42) Based on the market investigation and in view of the information available to it  in 
paragraphs (11) to (41), the Commission considers, f or the purposes of this Decision , 
that Standard FRPs and a luminium FRPs for Automotive HEX  both constitute 
distinct relevant product markets. The question whether the market for aluminium 
FRPs for Automotive HEX could be further segmented into Automotive HEX 
material for plates; Automotive HEX material for tubes; Automotive HEX material 
for overall fins; Automotive HEX material for clad fins and Automotive HEX 
material for unclad fins  can be left open  as the Transaction does not give rise to 
serious doubts as to its compatibility with the intern al market or the functioning of 
the EEA Agreement under any of these plausible product market definitions.  
6.  GEOGRAPHIC MARKET DEF INITION  
6.1. The Commission’s precedents  
(43) The Commission previously  considered that  the geographic market of Standard 
aluminium FRPs is at least EEA -wide and possibly, for certain categories, even  
wider  in scope.61  
(44) The Commission has not specifically analysed the supply of Automotive HEX 
materials (i.e. materials for plates, tubes and fins) in its previous decisions in the 
aluminium sec tor. 
6.2. The Notifying Party’s view  
(45) The Notifying Party agrees with the Commission’s precedents, and considers the 
relevant geographic market to be at least EEA -wide.  
6.3. The Commission’s assessment  
(46) The market investigation in the present case support s the view  that the relevant 
geographic market for the production and supply of  Standard FRPs and  Automotive 
HEX materials  is EEA -wide.   
                                                 
57  Questionnaire to customers, question B.4; questionnaire to competitors, question B.2.  
58  Questionnaire to customers, qu estion B.5; questionnaire to competitors, question B.3.  
59  Questionnaire to customers, question B.5.1.  
60  Questionnaire to competitors, question B.7.1.  
61  Commission decision of  8 May 2007, HINDALCO / NOVELIS (M.4605), paragraph 13; Commission 
decision of  29 September  2003, ALCAN/PECHINEY (II) (M.3225), paragraphs 66 -67. 
 
12 (47) In particular, during the Commission’s market investigation, all of the  competitors 
and customers  who expressed an opinion  stated that the supply and demand of 
Standard FRPs are  at least  EEA -wide .62 A competitor stated that ‘[s] everal risk 
factors discourages customers to buy globally ’.63 Another competitor stated that: 
‘[the Company] does not consider to be directly competing with Asian producers as 
the latter’s materials are not exactly the same quality .’64 
(48) Market participants expressed similar views with regard to Automotive HEX 
materials . Irrespective of whether they are defined as a separate relevant product 
market, from a g eographic perspective appear to follow largely similar competitive 
dynamics as other types of Standard FRPs. Most competitors and customers also 
stated that  the prices of Automotive HEX materials  are similar throughout the entire 
EEA.65 The majority of cust omers consider that suppliers provide Automotive HEX 
materials at EEA level.66 The majority of competitors and customers consider that 
the above does not differ for the different types of  Automotive HEX materials 
(i.e. materials for tubes, fins overall , clad fins and unclad fins).67 
(49) In addition to the foregoing, respondents to the market investigation considered 
duties as an important constraint.68 Imports of Automotive HEX materials from a 
third country into the EEA are subject to an import duty of 7.5%. Further, and on top 
of these 7.5% duties, the Commission opened an antidumping investigation on China 
imports ( AD668 ) on 14 August 2020.69 As a customer explained: ‘ In case additional 
duties are applied, supply from outside the EEA cannot be as competitive compared 
to supply within the EEA. ’70 This may constitute an additional constraint for 
customers to source from outside the EEA.  
(50) Moreover, transportation costs also impacts imports and exports of Automotive HEX 
materials. The majority of customers consider  that, due to transport cost, Automotive 
HEX materials can only be sold within the same region (e.g. the EEA) where they 
are manufactured.71 A competitor pointed out that: ‘ transport cost can have a 
sizeable impact in the aluminium FRP price when overseas s hipments are 
involved ’.72 The majority of competitors and customers consider that the above does 
not differ for the different types of Automotive HEX materials (i.e. materials for 
tubes,  fins overall , clad fins and unclad fins).73 
6.4. Conclusion on the geographi c market definition  
(51) For the purposes of this decision and in light of the results of the market 
investigation and of all information available to it, the Commission considers that 
the geographic market for Standard FRPs and Automotive HEX materials  is 
                                                 
62  Questionnaire to customers, question C.1; questionnaire to competitors, question C.1.  
63  Questionnaire to competitors, question C.2.1.  
64  Minutes of a call with a competitor  of 12 March 2020 , paragraph 16.  
65  Questionnaire to customers, question C.2; questionnaire to competitors, question C.2.  
66  Questionnaire to customers; question C.2  
67  Questionnaire to customers, question C.2.2; questonnaire to competitors, question C.2.2.  
68  Questionnaire to customers, question C.3.1, questionnaire to competitors, question C.3.1.  
69  See https://trade.ec.europa.eu/tdi/case details.cfm?id=2475 .  
70  Questionnaire to customers, question C.3.1.  
71  Questionnaire to customers, question C.3.  
72  Questionnaire to competitors, question C.3.1.  
73  Questionnaire to customers, question C.3.2; questionnaire to competitors, question C.3.2.  
 
13 EEA -wide in scope . The production and supply of the different Automotive HEX 
materials (i.e. materials for tubes, fins overall , clad fins and unclad fins), if treated as 
separate relevant product markets, would also be EEA -wide in scope.  
7. COMPETITIVE ASSESSMEN T  
7.1. Legal framework  
(52) Under Article 2(2) and (3) of the Merger Regulation, the Commission must assess 
whether a proposed concentration would significantly impede effective competition 
in the internal market or in a substantial part of it, in particular through  the creation 
or strengthening of a dominant position. In this respect, a merger can entail 
horizontal and/or non -horizontal effects.  
(53) Horizontal effects are those deriving from a concentration where the undertakings 
concerned are actual or potential compet itors of each other in one or more of the 
relevant markets concerned. The Commission appraises horizontal effects in 
accordance with the Horizontal Merger Guidelines.74 
(54) According to paragraph 26 of the Horizontal Merger Guidelines, a non -exhaustive 
list of relevant factors need to be assessed  in order to draw a conclusion whether 
significant non -coordinated effects are likely to result from a merger.  
(55) Accordingly, Section 7.4 assess es market shares, closeness of competition between 
the Parties, important dynamics of the markets where the Parties’ activities overlap, 
the alternatives to  the Parties and barriers to entry  and competitors’ behavior in case 
of price increases . Based on all these factors considered together, conclusions on 
horizontal non -coordinated effects are drawn in at the end of Section 7.4. 
7.2. Introduction and m arket structure  
(56) The Automotive HEX materials market, as Table 1 below shows, is small compared 
to the Standard FRPs market, estimated at around [10-20]% of the volume sales of 
Standard FRPs.  Within  the Automotive HEX segment  material , plates  
represent  [20-30]%, tubes represent [30-40]%, overall fins represent [30-40]% 
(unclad fins represent ing [30-40]% and clad fins represent ing [0-5]%). 
Table 1. Estimated market sizes of various potential segments of Standard FRPs  
EEA Markets 2018 (mt):  
Standard  FRPs:  2 346 410  
Auto HEX FRPs:  [280 000 -310 000]  
Plates:  [70 000 -90 000]  
Tubes:  [100 000 -120 000]  
Fins:  [90 000 -110 000]  
Unclad fins:  [80 000 -100 000]  
Clad fins:  [10 000 -20 000]  
Source: Form CO, paragraph 289  
                                                 
74  Guidelines on the assessment of horizo ntal mergers under the Council Regulation on the control of 
concentrations between undertakings (‘Horizontal Merger Guidelines’), OJ C 31, 05.02.2014.  
 
14 (57) Automotive HEX materials  are used in all types of vehicles, from light to heavy 
duty, as well as hybrid and Electric Vehicles (‘EV’). A higher share of hybrid 
vehicles, EVs and vehicles with different types of advanced features, affects the 
demand of Automotive HEX materials.  
(58) Gränges supplies aluminium FRPs, primarily for use  in HEX applications. Gränges 
has one production site in the EEA, in Finspång, Sweden , which supplies the 
Automotive and HVAC/R industries.  
(59) Impexmetal operates one production facility in Konin, Poland, with an  annual 
production capacity of 100,000 mt. Impexmetal has [Impexmetal’s strategic decision 
relating to possible expansion of capacity/offering ].75  
(60) In the EEA , for Automotive HEX materials  and Automotive HEX materials  
subcategories the Notifying Party identifies at least four large suppliers , namely 
Aleris, Hydro, Constellium, and AMAG and several other smaller ones: Arconic, 
Elval, Alinvest, Alcha, Novelis, Huafon, and Wuxi Yinbang.76 The market 
investigation revealed the following c ompanies that registered sales of Automotive 
HEX in the EEA for the last 4 years: AMAG, Constellium, Elval, Eurofoil, Norsk 
Hydro , ALRO, Hulamin, Huafon, Novelis and Assan .77 
(61) Customers of Automotive HEX are large Tier 1 -suppliers to OEMs like [the Parties’ 
customers 1, 2 and 3 ]. They  represent ed [60-70]% of Gränges’ sales of Automotive 
HEX in the EEA in 2018 . Impexmetal  has in total [number of customers ] automotive 
HEX materials  customers in EEA. In addition, the Parties’ customers multisource .78 
(62) For Automotive HEX materials  and subcategories, besides the market shares used to 
assess market power, the overall production and spare capacity is also a good 
parameter to assess the competitive strength of a supplier. A suppliers’ capacity to 
increase pr oduction depends on the part of the equipment that is usually the 
bottleneck in the process, and this is usually the finishing equipment  (i.e. capacity 
for slitters, tension levelling etc.) .79 The CRU report focuses on rolling capacity 
since this is t he capital-intensive part of the business , hence the capacity presented  in 
Table 2 below is related to the rolling capacity of the factories . 
                                                 
75  Form CO, paragraphs 136 and 137.  
76  Form CO, paragraph 258.  
77  Questionnaire to competitors, question  D.D.8.  
78  Form CO, paragraph 266.  
79  Form CO, paragraphs 329 -331. 


 
17 HEX materials for tube s, overall fins (including clad and unclad), clad fins and 
unclad fins.  
(66) In this regard, the Notifying Party claims that: (i) the Parties are not close 
competitors; (ii) there will remain a sufficient number of competitors post -
Transaction; (iii) suppliers  of Standard FRPs can switch their current product mix in 
order to increase (or start) supplying Automotive HEX materials, especially if prices 
increase; (iv) capacity constraints in Automotive HEX materials are unlikely to be a 
problem; (v) customers of A utomotive HEX materials are large sophisticated 
companies with plenty of countervailing buyer power, and they usually multi -source.  
(67) On closeness of competition , the Notifying Party submits that Gränges and 
Impexmetal’s businesses are complementary,84 and th at they are in  any case not 
close competitors.   
(68) The Notifying Party considers that there are two different types of suppliers of 
Automotive HEX materials as regards product quality and whether products are 
standardised or commoditised: high -end and low -end suppliers.85  
(69) Gränges regards itself as a high -end supplier, and considers Impexmetal to be a low -
end supplier. In Gränges’ opinion, it has more advanced capabilities and technical 
competence in process and R&D, as well as higher quality or more advanced 
products than those of low -end suppliers. The Notifying Party considers that other 
high-end suppliers include Aleris, Constellium, Hydro, AMAG and Elval.86 Gränges 
believes that customers might regard the Target to be focusing on the commodity 
market.87 Other  low-end suppliers produce more standardised products, such as 
Eurofoil, Alro, Assan, Alcomet, Hulamin, Arconic, and Alcha.88 This is also true for 
the different Automotive HEX materials, and particularly for materials for tubes .89 
(70) The Notifying Party submit s that its high - versus low - end suppliers argument is 
further supported by [price structure of the Parties ] between the Parties and by 
analysing the products in Gränges portfolio that Impexmetal cannot produce.90 For 
example, Gränges supplies multiclad materials while Impexmetal does not 
[Impexmetal’s strategic decision relating to possible expansion of capacity/offering ]. 
Gränges also submits that it is focused on being a flexible supplier that allows 
smaller ord er sizes to the customer, [price structure of Gränges ] (smaller order sizes 
mean more setup time in the machinery).91  
                                                 
84 According to the Notifying Party, around [70-80]% of Impexmetal’s business consist of other aluminium 
FRPs th an Automotive HEX FRPs. The reverse happens with Gränges, where in the EEA, about 
[90-100]% of its sales of Standard FRPs consist of Automotive HEX FRPs. See Form CO, paragraph 28.  
85  See Form CO, paragraphs 39 2, 394 and 395. 
86  See Form CO, paragraphs 12 , 34, 392, 394.  
87  See Form CO, paragraphs 12, 34, 39 4, 395. 
88  See Form CO, paragraph 41.  
89  See Form CO, paragraphs 276 and 277.  
90  See Form CO, paragraph s 34, 395. 
91  See Form CO, paragraph 395. 
 
18 (71) The pricing comparison of the Parties’ average prices for Automotive HEX materials 
is sho wn below:  
Figure 2. Part ies' average conversion prices for Automotive HEX materials  
[…] 
Source: Form CO, table 37 (paragraph 395)  
(72) On the sufficient number of remaining competitors in the market , the Notifying 
Party submits that, post -Transaction, it will be possible for customers  to switch 
volumes of products to other suppliers.92  
(73) The Notifying Party submits that it possible to switch su pplier, despite the validation 
costs in  case a customer needs to validate new Automotive HEX materials. The 
Notifying Party considers these costs as insignificant compared to the potential 
savings that could occur.93 
(74) Gränges argues that multi -sourcing is very common, and therefore customers would 
not need to go through additional validation processes to switch volumes quickly.94 
Gränges considers that  due to multi -sourcing, customers could easily switch 
suppliers in case of a price increase.95 According to Gränges, Automotive HEX 
materials customer [the Parties’ customer 1 ] multi -sources standardised tubes from 
eight suppliers, and fins from seven suppl iers. [the Parties’ customer 2] multi -
sources tubes and fins from six suppliers (each product).96 
(75) The Notifying Party argues that the difficulty for customers of switching supplier  is 
further decreased for commoditised  products (such as unclad fins) as these are 
standardised (i.e. the same material can be used for multiple applications so there 
would be no need to pass a validation process).97  
(76) On the suppliers’ ability to flex (and/or increase) production in case of a price 
increase,  the Notifying Party submits that supply -side substitution is timely and 
inexpensive within Automotive HEX materials.98 The Notifying Party submits that 
post-Transaction, several powerful actual and potential competitors would still be 
able to discipline the Parties by starting  or expanding their production of Automotive 
HEX materials.99 Further, the Notifying Party submits that a 5 -10% price rise in any 
Automotive HEX material would likely cause rapid switching and expansion.100 
(77) Gränges argues that competitors active in other segm ents than Automotive HEX 
materials have the possibility to switch capacity in or out of Automotive HEX 
materials.101 The Notifying Party submits that most of the main Automotive HEX 
materials suppliers already produce material for plates, tubes and either cl ad or 
                                                 
92  See Form CO, paragraphs 36 and 377.  
93  See Form CO, par agraph 363.  
94  See Form CO, paragra ph 377.  
95  See Form CO, paragraph 386.  
96  See Form CO, paragraphs 27 8 and 283.  
97  See Form CO, paragraph 378.  
98  See Annex 6 .1 to the Form CO, Section 3.1.2.  
99  See Form CO, paragraph 216.  
100  See Annex 6.1 to the Form CO,  Section 3.1.3.  
101  See Form C O, paragraph 248, and Annex 6.1 to t he Form CO.  
 
19 unclad fins, and they would be able to flex production volumes between the 
Automotive HEX materials that they produce without incurring material investment 
costs.102 Gränges considers that, for suppliers already acquainted with clad products, 
and with the equipment in place, it would take less than six months to move into an 
adjacent segment (e.g. from clad tubes to clad fin).103  
(78) Further, the Notifying Party submits that the production process for Automotive 
HEX materials  (i.e., materials for plates, tub es and fins) use similar or identical 
equipment, and even if a supplier needs to invest in additional machinery, this 
machinery is low cost and can be set up quickly.104 The table below shows the 
machinery requirements to switch capacity between Automotive H EX materials:  
Table 4. Machinery requirements to switch capacity between Automotive HEX 
materials  
 
Source: Annex 6.1 to the Form CO, table 5  
(79) The Notifying Party notes that this table assumes that direct chill technology is used. 
Suppliers of unclad fins using continuous casting would not be able to switch 
production to direct -chill products without significant investment.105  
(80) With regards to the cost and time to install machinery required to switch capacity 
from one Automotive HEX m aterial to another, the Notifying Party estimates the 
following:  
                                                 
102  See Annex 6.1 to the Form CO, Section 3.1.1.  
103  See Annex 6.1 to the Form CO, Section 3.1.1.  
104  See Annex 6.1 to the Form CO, Section 3.1.2.  
105  See Annex 6.1 to the Form CO, Se ction 3.1.2.  

 
20 Table 5. Cost and time to install machinery required to switch capacity  
Machinery  Cost (EUR million)  Time to install  Annual capacity  
Cladding  [...]  12 months  50 kt  
Tension levelling  [...] 8-12 mon ths  20-50 kt  
Slitting – light gauge  [...] 8-12 months  5-30 kt  
Slitting – heavy gauge  [...]  8-12 months  5-30 kt  
Source: Annex 6.1 to the Form CO, table 6  
(81) Therefore, Gränges argues that the costs and time required to install machinery to be 
able to switch capacity from one Automotive HEX material to another is not 
significant . 
(82) Moreover, the Notifying Party believes that there are credible import threats comi ng 
from Chinese suppliers .106 According to Gränges, Chinese suppliers have access to 
cheaper metal as well as gover nment subsidies .107  
(83) With regard to material for clad fins, the Notifying Party argues that fewer number 
of clad fin suppliers is likely due to l ow demand and low volumes of product sold 
and not to barriers to entry.108 Gränges considers that suppliers of unclad fins need 
little time and capital to start producing clad fins (although suppliers would have to 
use the direct chill technology).109 Further,  suppliers who already produce clad 
material (e.g. tubes) can start producing clad fins without installing any additional 
machinery, as tubes use the same cladding and light gauge slitting machines as clad 
fins.110 Moreover, Gränges considered that even in t he case that investments in a clad 
fin were needed, it would only take a year to build with some minor investment (of 
around EUR [information on the Parties’ costs relating to manufacture ]).111 Gränges 
believes higher clad fin prices would induce more suppli ers to produce clad fins.112 
(84) On the lack of capacity constraints,  Gränges argues that this would contribute to 
competitors increasing (or starting) their supply of Automotive HEX materials. 
Gränges estimates that capacity utilisation in 2019 was likely to be  around 
80-90%.113 Gränges expects capacity to increase substantially in the coming years 
because of three main reasons:114  
 First, the US -China trade war has freed Chinese capacity to supply European 
customers.  
                                                 
106 See Form CO, paragraph 262.  
107  See Form CO, paragraph 262.  
108 See Form CO, paragraph 300.  
109  See Form CO, paragraphs 300 and 301.  
110  See Form CO, paragraph 300.  
111  See Form CO, paragraph 301.  
112  See Form CO, paragraph 300.  
113  See Form CO, paragraph 265.  
114  See Form CO, paragraph s 216 and 265.  
 
21  Second, a weak automobile sector has reduced or ders, and led to idle 
European capacity.  
 Third, Gränges estimates that between 2018 -2023 Europe will add 
403 000mt of capacity of aluminium FRPs which includes planned 
expansions in the near future by Elval, Assan, AMAG, Alcomet and Alro.115 
The Notifying P arty argues that, in principle, it is possible to use the capacity 
for all different segments of aluminium FRPs to produce Standard FRPs, so it 
estimated these capacity increases on the basis of capacity for all aluminium 
FRP segments.116 
(85) On the countervaili ng buyer power , the Notifying Party argues that customers are 
sophisticated and consolidated (with only a few large customers making up for a 
large part of suppliers’ sales of Automotive HEX materials) have global contracts 
and strong financial resources, and therefore have a strong countervailing buyer 
power.117 Therefore, Gränges submits that significant losses of sales and market 
shares would occur if customers were to switch volumes away from the Parties, 
which makes suppliers of Automotive HEX materials more dependent on the 
customers than the other way round.118 
7.4. The Commission’s assessment   
7.4.1.  Automotive HEX materials overall  – horizontal non -coordinated effects  
(86) In this Section, the Commission will assess the effects of the Transaction in an 
overall plausible market for Automotive HEX materials. The assessment for the 
alternative plausible markets for individual products (i.e. Automotive HEX materials 
for tubes, f ins overall, clad fins and unclad fins) will be addressed in 
Section  7.4.2 7.4.2 . 
(87) The Transaction is not likely to raise serious doubts in relation to the EEA -wide 
market for the supply of Automotive HEX materials overall for the reasons set out 
below . 
(88) If an overall market for all Automotive HEX materials  were  defined, the 
Transaction would give rise to an affected market. T he market investigation has 
pointed at certain barriers to entry for example, the cost, time and approval needed 
for validation of additional materials/suppliers and the current imports that may be 
affected by further duties imposed to them.119 
                                                 
115  See Form CO, paragraph 265.  
116  See Form CO, paragraph 244.  
117  See Form CO, paragraphs 38 2, 384 and 385. 
118  See Form CO, paragraph 3 85. 
119 Questionnaire to customers, questions C.3.1 and D.C.2.1; ques tionnaire to competitors, question E.2.1.  

 
23 quality, high assortment range, HEX -specific R&D capability) whereas Impexmetal 
is perceived as being able to supply less complex p roducts than Gränges.126  
(93) Third , competitors have idle capacity for Automotive HEX materials, as shown in 
Table 2, and as confirmed in the market investigation. Therefore, several competitors 
could increase production of Automotive HEX materials in reaction to an increase in 
demand in the EEA.127 Further, the majority of competitors consider that neither 
casting, nor hot rolling, cold rolling, cladding, cleaving  or packing would act as 
barriers or bottlenecks in case of an increase of production on Automotive HEX 
materials.128 
(94) Fourth , several (actual and potential) suppliers would remain in the market. The data 
provided by the Notifying Party and the results of the mar ket investigation indicate 
that the competitive landscape in the market for Automotive HEX materials is 
characterised by a number of strong global players, which are active across the EEA. 
The merged entity will continue to face strong competitive pressure  from strong 
players such as Aleris ( [10-20]%), Constellium ( [10-20]%), Hydro ( [10-20]%) and 
other smaller players as well as imports from South Africa and China . A competitor 
explained that ‘ there are many suppliers active in the EEA ’.129 
(95) Lastly, competitor s are likely to increase their supply should prices increase. The 
market investigation results have shown that the majority of competitors  who 
expressed an opinion on this point  would increase production of Automotive HEX 
materials overall in the event of a 5-10% price increase.130 
(96) Based the considerations in paragraphs (88) to (95) above and in light of the results 
of the market investigation and of all evidence available to  it, the Commission 
concludes that the Transaction does not give rise to serious doubts as to its 
compatibility with the internal market or the functioning of the EEA Agreement with 
respect the overall market for  Automotive HEX in the EEA.   
7.4.2.  Plausible marke ts of Automotive HEX materials for tubes, fins overall, clad fins and 
unclad fins  
(97) In this Section, the Commission will assess the effects of the Transaction in the 
plausible narrower markets for each individual product  within aluminium FRPs for 
Automotive HEX, where there is an affected market : Automotive HEX materials for 
tubes, Automotive HEX materials for fins overall, Automotive HEX materials for 
clad fins, and Automotive HEX materials for unclad fins.  
7.4.2.1.  Plausible narrower market of Automotive HEX materi als for tubes  – horizontal 
non-coordinated effects  
(98) The Transaction is not likely to raise serious doubts in relation to the EEA -wide 
market for the supply of Automotive HEX materials for tubes for the following 
reasons . 
                                                 
126  Questionnaire to customers, questions D.C.6, and  D.C.6.1 ; questionnaire to competitors, questions D.C.3 
and D.C.3.1.  
127 Questionnaire to competitors, question D.D.7.  
128 Questionnaire to competitors, question D.D.9.  
129  Minutes of a call with a competitor of 20 March 2020, paragraph 20.  
130  Questionnaire to competitors, question D.D.2.  


 
26 (107)  However, on balance, the Commission finds the transaction not likely to raise 
serious doubts in relation to the EEA -wide market for the supply of all Automotive 
HEX fin materials because of the following reasons . 
(108)  First, based on the Parties’ estimates in Section 7.2 above, the combined share of the 
Parties in all Automotive HEX materials for fins in 201 8 would be limited to 
[20-30]% in the EEA . The Automotive HEX materials for fins market is likely not to 
increase in the following years since  a large majority of customers that responded in 
the market investigation stated135 that they do not intend to or ar e unsure as whether 
they will  increase their demand for overall fins for the next 3 years.  
(109)  Second, several (actual and potential) suppliers would remain in the market. The 
data provided by the Notifying Party and the results of the market investigation 
indicate that the competitive landscape in the market for Automotive HEX materials 
for fins overall  is characterised by a number of strong global players, which are 
active across the EEA. The merged entity will continue to face strong competitive 
pressure fro m strong players such as as Alinvest ( [10-20]%), Hydro ( [5-10]%), 
Eurofoil ( [5-10]%), Arconic ( [5-10]%), Aleris ( [5-10]%), Elval ( [0-5]%) as well as 
imports from Turkey, South Africa and China.  
(110)  Third, Gränges  and Impexmetal are not close competitors in all Automotive HEX fin 
materials  as Gränges  is specialised in more high -end quality products than 
Impexmetal.136  
(111)  Forth, even though competitors there are barriers to entry the Automotive HEX fin 
materials market in terms of investment in production machinery, know -how and the 
validation process with customers, the  majority of competitors answered they would 
increase the production of material for fins in the event of a price increase of 
5-10%137 and, as Table 2 above shows it , they would have spare capacity they can 
use in case of necessity.  
(112)  Based on  the considerations in paragraphs (107)  to (111)  and in light  of the results of 
the market investigation and of  all evidence available to it,  the Commission 
concludes that the Transaction does not give rise to serious doubts as to its 
compatibility with the internal market or the functioning of the EEA Agreement with 
respect to  the market for all Automotive HEX fins  in the EEA.   
(A) Plausible market of Automotive HEX materials for clad fins   
(113)  The Transaction is not likely to raise serious doubts in relation to the EEA -wide 
market for the supply of Automotive HEX materials for clad fins for the reasons set 
out below . 
(114)  If one single market for  Auto motive HEX clad  fin materials  were  defined, then the 
Transaction would give rise to an affected market. The market investigation has 
pointed at certain barriers to entry such as, for example, the cost, time and approval 
needed for validation of additional materials/suppliers and the current imports may 
                                                 
135  Questionnaire to customers, question D.D.5.  
136  Questionnaire to customers, question D.A.2.  
137  Questionnaire to competitors, question D.D.2.  

 
28 requirements for clad finstock in […] Europe are quite low (less than 3% of our 
FRP usage), s o very few  new RFQ have been sent in the last year ’.143 
(119)  Second,  several (actual and potential) suppliers would remain in the market. The 
merged entity will continue to face strong competitive pressure from strong players 
such as Hydro and Elval ( [10-20]%), a s well as imports from South Africa and 
China.  There would still remain enough competitive pressure on the market as one 
competitor stated: ‘ Suppliers that focus on thinner products like clad fin, unclad fin, 
and clad tube to some extent have a relatively small market volume to compete for. 
These products are niche products in the FRP industry, and normally suppliers 
combine this business with other foil type of products to be able to reach positive 
contribution. There are still enough suppliers to generate  low market prices for 
these niche products, and even if the clad fin product is higher priced due to fewer 
supply alternatives, the total market volume is low .’144 
(120)  Third, as Table 2 above  shows , there is spare capacity that could  be used to increase 
clad fins ’ production . Despite the barriers to entry in the Automotive HEX material 
for clad fins market in terms of investment in production machinery, know -how and 
the valida tion process with customers, there are interested competitors that would 
increase the production of material for clad fins in the  event of a price increase 
of 5-10%.145 
(121)  Fourth , customers would still have enough ability to switch to other suppliers as the 
results of the market investigation indicate:  most customers see Alcha and Huafon as 
potential alternatives for their demand, but a large minority of customers also 
consider Arconic, Assan and Hydro.146 Yinbang  and Elval were also pointed out as 
possible suppli ers.147 Even the Notifying Party argues that it lost sales to [Gränges’ 
volume loss to a competitor in 2013 -2014 and 2019 ].148 
(122)  Fifth , Gränges and Impexmetal are not close competitors in the market for 
Automotive HEX materials for clad fins as the Parties’ products are substantially 
differentiated. Gränges supplies the more advanced multi -clad products  than 
Impexmetal , such as [an example of Gränges’ multiclad clad fin products and the 
volume sold thereof ], which represents […] of Gränges’ sales within clad fins.149 
(123)  Lastly , even though the customers perceive the clad fins market to be less 
competitive compared to other Automotive HEX categories, the majority of 
customers consider150 that clad fin prices did not evolve differently from th e prices 
of the other aluminium FRPs for Automotive HEX in the past 3 years.  
(124)  Based on  the considerations in paragraphs (116)  to (123)  and in light of the results of 
the market investigation and of all evidence available to it, the Commission 
concludes that the Transaction does not give rise to serious doubts as to its 
                                                 
143  Questionnaire to customers, question D.D.4.2.  
144  Questionnaire to competitors, question E.3.2 . 
145  Questionnaire to competitors, question D.D.2.  
146  Questionnaire to customers, question D.D.4.  
147  Questionnaire to customers, question D.D.4.1.  
148  Form CO, paragraph 293.  
149  Form CO, paragraph 295.  
150  Questionnaire to customers, question D.E.3.  

 
30 investigation stated151 that they do not intend to or are unsure as to whether they will  
increase their demand for unclad fins in the next 3 years.  
(129)  Second, several (actual and potential) suppliers would remain in the market. The 
data provided by the Notifying Party and the results of the market investigation 
indicate that the competitive landscape in the market for Automotive HEX materials 
for unclad fins is characterised by a number of strong global players, which are 
active across the EEA. The merged entity will continue to face strong competitive 
pressure from strong players such as Alinvest ( [10-20]%), Eurofoil ( [5-10]%), 
Hydro  ([5-10]%), Arconic ( [5-10]%) amongst others and as well as imports from 
Turkey, South Africa and China. The results of the market investigation revealed 
that there are suppliers that most customers would consider as potential alternatives 
for their demand :152 Alcha, Alinvest, E urofoil and also153 Elval, Huafon, Yinbang  
and Alu-Slim/Grupporeco . 
(130)  Further, and as shown in  Table 2 above, there are no capacity constraints, and spare 
capacity can be mo bilised where needed. So, despite the smaller share of supply of 
some of the competitors mentioned above, these have spare capacity and some of 
them plan to further increase capacity in the near future, or are undergoing current 
plans for capacity increase s, for example Elval, AMAG, Alro and Alcomet.154 
(131)  Third, unclad fins are standardised products, which makes it easier to switch 
suppliers. Further, the market investigation results have shown that for unclad fins 
the barriers to entry are low. A competitor me ntioned that the ‘ barriers to entry are 
low provided the rolling infrastructure (gauge capability at cold mill) is in place ’155 
and a customer stated: ‘ Unclad fins for HEX are more and more produced via the 
Continuous Casting Process with subsequent cold rol ling to final thickness. This 
process is very price competitive and produces fin materials with good forming 
behaviour and superior corrosion properties .’156 
(132)  Fourth, Gränges  and Impexmetal are not close competitors in Automotive HEX 
materials for unclad fins as Gränges  is specialised in more high end quality products 
than Impexmetal.157  
(133)  Fifth, the majority of competitors answered that they would increase the production 
of material for unclad fins in the event of a price increase of 5 -10%158 and, as Table 
2 above shows , they would have spare capacity they can use in case of necessity.  
(134)  Based on  the considerations in paragraphs (128)  to (133)  and in light of the results of 
the market investigation and all evidence available to it, the Commission concludes 
that the Transaction does not give rise to serious doubts as to its compatibi lity with 
the internal market or the functioning of the EEA Agreement with respect to  the 
market for Automotive HEX for unclad fins  in the EEA.  
                                                 
151  Questionnaire to customers, question D.D.5.  
152  Questionnaire to customers, question D.D.3.  
153  Questionnaire to customers, question D.D.3.1.  
154  Questionnaire to competitors, question D.D.7 and minutes of a call  with a competitor of 12 March 2020, 
paragraph 19, Form CO, table 20.  
155  Questionnaire to competitors, question D.D.5.  
156  Questionnaire to customers, question B.5.1  
157  Questionnaire to customers, question D.A.2.  
158  Questionnaire to competitors, question D. D.2. 
 
31 7.4.3.  Final conclusion of the competitive assessment  
(135)  Based on  the considerations included in paragraphs (87) to (134)  above and in light 
of the results of the market investigation and of all evidence available to it, the 
Commission considers that the Transaction will not give rise to serious doubts as to 
its compatibility with the internal market or the functioning of the EEA Agreement 
with respect to  horizontal  non-coordinated effects under any plausible market 
definition.  
8. CONCLUSION  
(136)  For the above reasons, the European Commission has decided not to oppose th e 
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  
Executive Vice-President