Customer savings generated by the Commission’s antitrust and merger enforcement : a 10-year perspective.
Date: 2022-10-21
Institutions: Directorate-General for Competition
Subjects: EU competition policy, anti-trust legislation, merger control, savings

Issue 1 | October 2022  

ISBN 978-92-76-58443-8, ISSN: 2315-3113 

Competition  policy brief 

Customer savings generated by 
the Commission’s antitrust and 
merger enforcement:  a 10-year 
perspective 

Thomas  DEISENHOFER,  Adriaan  DIERX,  Fabienne  ILZKOVITZ, 
Alexis STEVENSON and Vincent VEROUDEN 

Introduction 

The  European  Commission’s  antitrust  and  merger  enforcement 
aims to protect effective competition on the market with a view 
to ensure lower prices, improved quality and more innovation for 
the benefit of customers1 and the EU economy as a whole.  

Part  of  the  above  benefits  of  competition  enforcement,  namely 
those resulting from the direct price effects for customers of the 
Commission’s  interventions  in  the  markets  concerned  (‘direct 
customer  savings’)  can  be  relatively  easily  estimated  using  a 
methodology suggested by the  OECD 2, case specific information 
from  past  interventions  as  well  as  simplifying  assumptions 
derived from the economic literature.  

Starting in 2012, DG Competition has calculated and reported3 on 
an  annual  basis  the  direct  customers  savings  generated  by  its 
cartel and merger enforcement. 

The  present  policy  brief  presents  and  discusses  new  and 
improved estimates of the direct customer savings generated by 
the  Commission’s  competition  enforcement  over  a  full  ten-year 
period 2012-2021. For the first time the estimates also include a 
full ten-year dataset on the direct customer savings generated by 

1   Final  consumers,  but  also  customers  of  intermediate  goods  and 

services. 

2   OECD  (2014),  Guide  for  helping  competition  authorities  assess  the 

expected impact of their activities, 
https://www.oecd.org/daf/competition/Guide-competition-impact-
assessmentEN.pdf3   See,  for  instance,  Annual  Activity  Report  2021, 
Directorate-General 
Competition, 
https://ec.europa.eu/info/publications/annual-activity-report-2021-
competition_en  

for 

3  See, for instance, Annual Activity Report 2021, Directorate-General for 
https://ec.europa.eu/info/publications/annual-activity-

Competition, 
report-2021-competition_en  

The content of this article does not necessarily reflect the 
official position of the European Commission. Responsibility 
for the information and views expressed lies entirely with 
the authors. 

by 

non-cartel 
antitrust 
interventions.  The  policy 
brief further discusses (1) 
issues 
methodological 
the 
encountered 
(2) 
Commission, 
the 
comparisons  with 
savings
customer
by 
reported 
other 
jurisdictions 
(3)  macro-
modelling  efforts  based 
on  the  customer  savings 
calculations  and  (4)  how 
to  further  develop  the 
current work on customer 
savings.  

Concept, basic 
method and 
assumptions 

the 

direct 
Estimating 
customers 
savings 
generated  by  competition 
enforcement 
actions 
consists  essentially  in  a 
‘bottom-up’  summing-up 
estimated 
of 
benefits 
customer
all 
generated 
competition 
individual 
enforcement 
actions 
(‘interventions’)  during  a 
given period of time.  

the 

by 

In a nutshell 

It is possible to use a relatively 
simple  methodology  relying  on 
previous  work  from  the  OECD 
to estimate the direct customer 
savings  generated  by 
the 
Commission’s  antitrust  and 
merger enforcement.  

For  the  ten-year  period  from 
2012  to  2021,  the  estimated 
total  direct  customer  savings 
from  all  antitrust  and  merger 
interventions  by  the  European 
Commission were in a range of 
EUR 120 to 21O billion, or EUR 
12  -  21  billion  per  year.  While 
these  ranges  of  estimates  are 
relatively  wide,  they  provide  a 
good 
idea  of  the  order  of 
magnitude  of  the  likely  direct 
the 
savings  generated  by 
Commission’s 
enforcement 
work. 

for 

Impressive  as  these  numbers 
may  be,  they  only  reflect  the 
“tip of the iceberg” in terms of 
positive  effects  of  competition 
society. 
enforcement 
Indeed,
competition 
enforcement  also  generates  (i) 
indirect  deterrence  effects  and 
(ii) positive non-price effects on
innovation, 
and 
productivity  which  are  likely  to 
be significantly larger, but also 
more difficult to calculate. 

quality, 

Direct  customer  savings 
from  a  given  intervention 
the  product  of 
equal 
estimates of (1) the price 
increase  avoided  as  a 
result of the intervention, (2) the size of the affected market(s) or 
turnover, and (3) the expected duration of the price effect.  

KD-AK-22-001-EN-N, doi 10.2763/80601 
©European Union, 2022  
Reproduction is authorised provided the source is 
acknowledged. More publications on: 
https://ec.europa.eu/competition-policy/publications_en and 
http://bookshop.europa.eu 

Customer savings from the Commission’s competition enforcement | Competition Policy Brief No 1/2022) 

Annual  customer  savings  are  the  sum  of  the  direct  customer 
savings  associated  with  all  competition  policy  interventions  in  a 
given year.  

Information  on  the  three  components  of  the  customer  savings 
are based on case-specific information to the extent possible and 
on Commission assumptions (see Table 1 below) inspired by the 
economic literature and the OECD.4 

Table 1: Assumptions used to calculate the customer savings 
 from cartel, merger and antitrust interventions5 

Merger 
cases 

Cartel cases 

Avoided price 
increase 

3-5% 

10-15% 

Annual 
turnover of 
all firms in 
the affected 
market(s) 

Annual 
turnover of the 
companies 
under 
investigation in 
the affected 
market(s) 

Affected 
turnover 

Expected 
duration of the 
price effect 

Antitrust 
cases 
5-10%, unless 
case-specific 
information is 
available  
Annual turnover 
of the 
companies 
under 
investigation in 
the affected 
market(s) 

2/3/5 years 

1/3/6 years 

1/3/6 years 

competition policy to the general public and internal and external 
stakeholders such as the European Parliament. 

Main findings 

Over  the  past  ten  years  (2012-2021),  the  average  number  of 
Commission  interventions7 per  year  was  around  30  and  was 
relatively stable with a majority of merger interventions (65% of 
the  total  number  of  interventions),  followed  by  interventions  in 
the area of non-cartel antitrust (19 %; composed of interventions 
against  restrictive  agreements  and  concerted  practices  under 
Article 101 = 11% and interventions against abuses of dominant 
positions under Article 102 = 8%) and cartel decisions (16%). 

Number of interventions 
(2012 - 2021)

40
30
20
10
0

The  main  limitations  of  this  type  of  calculations  are  that  they 
underestimate the benefits of EU competition policy interventions 
as  they  do  not  report  their  deterrent  effects  and  their  positive 
non-price  effects  such  as  those  on  innovation,  productivity  and 
product quality. 

The  main  strengths  of  calculating  customer  savings  in  this  way 
are that (1) the calculation method is simple and the underlying 
assumptions  are  conservative,  (2)  the  calculations  can  be 
performed at relatively low cost of resources and retroactively to 
create  longer  time  series,  (3)  due  to  the  law  of  large  numbers, 
aggregate  figures  provide  relatively  robust  ranges  of  outcomes 
and therefore a good idea of the order of magnitude of the true 
savings6,  (4)  such  calculations  can  help  to  control  and,  where 
appropriate,  optimise  priority  setting  for  enforcement,  (5)  such 
calculations help to quantify and report on the likely benefits of 

4  Cf. OECD (2014, quoted above) and A. Dierx and F. Ilzkovitz (2020), Ex-
Post  Economic  Evaluation  of  Competition  Policy:  the  EU  Experience 
(Kluwer)), Ch. 11. Please note that contrary to the OECD 2014 guidance 
paper  we  consider  ranges  for  the  expected  price  effects  of  the 
competition  policy  interventions  to  reflect  the  ranges  of  such  effects 
reported  in  the  economic  literature  and  the  existing  uncertainty  over 
the  average  magnitude  of  such  effects.  Moreover,  for  mergers  and 
cartels we use a higher upper bound of the range than the OECD single 
figure recommendation and for antitrust we use a lower bound of the 
range.  
5  Idem.   
6   Figures for individual cases are by the nature of the process less robust 

and therefore not reported in this policy brief. 

Merger

Cartel

Antitrust

For  the  ten-year  period  under  consideration,  the  estimated  total 
customer savings from all competition policy interventions by the 
European  Commission  were  in  a  range  of  EUR  120  to  21O 
billion  depending  on  lower  or  upper  bound  assumptions  made 
for  the  price  effects  of  the  different  interventions.  The  average 
annual direct customers savings were thus in a range of EUR 12 
to  21  billion.  Total  direct  customer  savings  over  the  ten-year 
period  from  non-cartel  antitrust,  cartels  and  mergers  ranged 
respectively from EUR 17- 26, 33-61 and 74-123 billion.  

Table 2: Customer savings in billion EUR by year and instrument 

Year 

2012 
2013 
2014 

Merger  

Cartel  

Antitrust  

5.5 – 9.1 
0.4 – 0.6 
2.1 – 3.6 

1.4 – 2.0 
0.6 – 0.9 
1.7 – 2.6 

0.1 – 0.2 
4.3 – 6.6 
2.4 – 7.7 

Total 
customer 
savings 
7.0 – 11.3 
5.3 – 8.1 
6.2 – 13.9 

7   The sample of decisions (‘interventions’) used for the customer savings 
calculations  consists  of  decisions  concerning  anticompetitive  mergers, 
cartels  and  non-cartel  antitrust  conduct  and  agreements.  Merger 
interventions  include  phase  II  prohibitions,  phase  II  clearances  subject 
to  remedies,  phase  II  abandonments  and  phase  I  clearances  with 
remedies.  Cartel  interventions  consist  of  prohibition  decisions  under 
Article  7  of  Reg.  1/2003.  Antitrust  interventions  include  prohibition 
decisions under Article 7 and   commitment decisions under Article 9 of 
Reg. 1/2003, as well as ‘informal interventions’ (see details below). 

2 

 
 
 
  
 
 
 
 
 
Customer savings from the Commission’s competition enforcement | Competition Policy Brief No 1/2022) 

2015 
2016 
2017 
2018 
2019 
2020 
2021 
Total 
Average per 
case 

1.7 – 2.9 
18.3 – 30.4 
2.4 – 4.1 
15.0 – 25.0 
5.7 – 9.4 
13.8 – 23.0 
9.2 – 15.3 
74 – 123 

1.0 – 1.5 
6.7 – 10.0 
1.4 – 2.1 
1.3 – 1.9 
1.5 – 2.3 
0.2 – 0.3 
1.3 – 1.9 
17 – 26 

1.6 – 3.3 
1.4 – 2.9 
7.8 – 14.3 
7.4 – 14.9 
6.4 – 7.7 
1.6 – 3.3 
0.2– 0.3 
33– 61 

4.3 – 7.7 
26.4 – 43.3 
11.6 – 20.5 
23.7 – 41.8 
13.6 – 19.4 
15.6 – 26.6 
10.7 – 17.5 
124 – 210 

0.4 - 0.6 

0.3 – 0.5 

0.6 – 1.0 

The  annual  direct  customer  savings  varied  considerably  from 
year to year. They were particularly high in 2016 and 2018, with 
average annual amounts of over EUR 30 billion. In 2016, this was 
due  to  several  important  merger  interventions  and  cartel 
prohibitions.  In  2018  this  was  due  to  merger  and  non-cartel 
antitrust interventions (specifically Art. 102).  

Customer savings (2012-2021) in bn EUR

40
35
30
25
20
15
10
5
0

Antitrust interventions in focus  

retroactively 

This  year,  for  the  first  time,  the  Commission  has  also 
savings 
calculated 
generated by non-cartel antitrust interventions. Due to 
the diversity of antitrust enforcement the exercise was 
more  challenging  than  calculating  direct  customer 
savings for cartel and merger interventions. 

customer 

the 

Over the period 2012-2021, the European Commission 
took  52  decisions  aimed  at  stopping  anticompetitive 
In 
behaviour  under  Articles  101  and  102  TFEU. 
addition,  there  were  several  ‘informal  interventions’, 
i.e.  Commission  decisions  to  close  a  case  after  the 
Commission’s  investigation  led  to  the  termination 
and/or remediation of the conduct of concern.  

Number of antitrust interventions

10
8
6
4
2
0

Merger

Cartel

Antitrust

Art 101 Prohibition

Art 102 Prohibition

Art 101 Commitment

Art 102 Commitment

Informal interventions

On  average,  annual  aggregate  customer  savings  from  merger 
interventions  are  larger  (EUR  7  -  12  billion  per  annum  over  the 
period  considered,  with  wide  variation  from  year  to  year)  than 
those  from  antitrust  interventions  (EUR  3-6  billion  per  annum) 
and  cartel  prohibitions  (EUR  2  -  2.5  billion  per  annum).  This 
difference  in  large  part  reflects  differences  in  the  number  of 
interventions  made  over  the  2012-2021  period,  which  varies 
from 49 for cartels, 59 for antitrust and 197 for mergers. 

By  contrast  the  customer  savings  associated  with  an  “average” 
individual  antitrust  intervention  (EUR  0.6-1)  lie  above  those 
recorded for an average cartel prohibition (EUR 0.3-0.5 billion) or 
merger intervention (EUR 0.4-0.6 billion). 

When  comparing  customer  savings  generated  by  interventions 
based  on  different  enforcement  instruments  it  is  important  to 
bear  in  mind  that  for  mergers  it  is  assumed  -  in  line  with  the 
OECD  methodology  –  that  the  intervention  affects  the  prices  of 
all firms in the affected market, while for cartels and antitrust it 

customer 

The 
interventions were largest in 2017 and 2018. 

savings  generated  by  antitrust 

12

10

8

6

4

2

0

3 

Art 101 Prohibition
Art 101 Commitment
Informal interventions

Art 102 Prohibition
Art 102 Commitment

 
 
 
 
  
 
 
  
 
 
Customer savings from the Commission’s competition enforcement | Competition Policy Brief No 1/2022) 

Over the full ten-year period large shares of the total 
customer  savings  were  generated  in  the  Agriculture 
and  Energy  sectors  which  are  particularly  important 
Information  and 
followed  by 
consumers, 
for 
Communication (I&C). 

Share in Total Customer Savings by 
sector (2012-2021)

30%
25%
20%
15%
10%
5%
0%

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is  assumed  that  the  interventions  affect  only  the  prices  of  the 
firms under investigation8. 

The  figure  below illustrates  the distribution  of  customer  savings 
by  sector  and  competition  policy  instrument.  It  shows  that  the 
customer savings from antitrust interventions (other than cartels) 
are  present  over  a  wide  range  of  different  sectors,  with 
particularly  large  savings  in  the  agricultural  and  utility  sectors. 
Customer  savings 
interventions  are  more 
concentrated  in  the  manufacturing  and  I&C  (information  and 
communication)  sectors,  while  the  customer  savings  from  cartel 
prohibitions are largely concentrated in the manufacturing sector. 
About  46%  of  total  customer  savings  are  realised  in  the 
manufacturing sector. 

from  merger 

8 Cf. Table 1.  

4 

Customer savings by sector and instrument 
(2012-2021, total, bn EUR)

80

70

60

50

40

30

20

10

0

Mergers

Cartels

Antitrust

Methodological 
Commission 

issues  encountered  by 

the 

As set out above the basic calculation method is inspired by the 
OECD  guidance  from  2014  and  is  relatively  simple:  customer 
savings from a given intervention equal the product of estimate 
of  (1)  the  price  increase  avoided,  (2)  the  size  of  the  affected 
market(s) or turnovers and (3) the expected duration of the price 
effect  in  the  absence  of  an  intervention  by  the  competition 
authority. 

During the Commission’s recent efforts to calculate, for the first 
time,  customer  savings  generated  by  non-cartel  antitrust 
interventions and to review the customer savings calculations for 
a  full  ten  period  also  for  the  two  other  instruments,  the 
Commission has encountered four complex methodological issues 
which  have,  to  date,  not  been  (fully)  addressed  by  OECD 
guidance.  

First of all, it became apparent that the calculation of customer 
savings  from  antitrust  interventions  (excluding  cartels)  is 
more  challenging  because  non-cartel  antitrust  cases  are 
significantly more diverse in nature than mergers or cartel cases. 
This diversity in turn makes the use of standardised assumptions 
on  the  avoided  price  increase  and  the  expected  duration  of  the 
price  effect  more  difficult.  To  address  this  challenge,  the 
responsible  antitrust  case  teams  have  been  approached  with  a 
questionnaire  with  the  aim  of  collecting  case  specific  data.  The 
responses to the questionnaire suggest that antitrust cases more 
frequently  seek  to  protect  innovation  competition  than,  for 
example,  merger  cases.  The  effects  of  these  interventions  on 
innovation  cannot  be  measured,  however,  via  direct  customer 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Customer savings from the Commission’s competition enforcement | Competition Policy Brief No 1/2022) 

savings calculations. In that sense, the estimates obtained in this 
area of enforcement can be deemed especially conservative.  

Secondly, the issue arose whether or not to retroactively change 
the customer savings calculations decisions for past years when 
intervention  decisions 
those 
calculations are later annulled by the General Court.   

included 

initially 

in 

In  line  with  the  guidance  of  the  OECD,  customer  savings 
calculations  should  be  done  on  a  yearly  basis  and  cover  all 
decisions taken during each year. In line with the same guidance 
DG  Competition  includes  all  interventions  in  its  calculations 
including  those  that  are  appealed  or  might  potentially  be 
appealed  in  the  future,  because  the  fate  of  those  actual  or 
potential  appeals  cannot  be  predicted  with  any  certainty.9 The 
OECD  guidance  does  however  not  contain  express  indications 
what  to  do  with  customer  savings  calculations  for  past  years 
when  a  few  years  later  a  decision  initially  included  in  the 
customer savings calculations is annulled by the General Court.  

On the one hand, it could be argued that the Commission should 
in  such  a  scenario  retroactively  correct  customer  savings 
calculations for the past year in question, because otherwise the 
numbers for this past year contain interventions which have been 
found to be illegal by the General Court.  

On  the  other,  it  must  be  borne  in  mind  that,  first,  decisions 
initially  annulled  by  the  General  Court  may  be  confirmed  on 
appeal  and/or  readopted  by  the  Commission  which  raises  the 
follow-on  question  whether  decisions  retroactively  removed 
might later have to be retroactively added again. 

Secondly,  customer  savings  calculations  report  -  as  explained  in 
the  OECD  guidance  –  the  expected  customer  savings  at  the 
moment  when  the  savings  are  calculated,  as  opposed  to  the 
actual  effects,  which  can  only  be  assessed  on  the  basis  of  a 
proper ex-post evaluation.   

Thirdly,  these  calculations  should  be  simple,  concise  and 
transparent, there should be consistency over time and no double 
counting. If the customer savings figures for past years had to be 
changed  repeatedly  depending  on  the  outcome  of  later  court 
proceedings and possible re-adoptions of decisions, the customer 
savings  calculations  for  past  years  would  become  unstable.  
Moreover,  the  numbers  for  the  most  recent  years  (which  by 
definition do not yet reflect annulments) could not any longer be 
compared  in  a  meaningful  way  with  numbers  for  those  past 
years which retroactively take into account annulments.    

In the light of these difficulties and in line with the objectives of 
the  customer  savings  calculations  to  keep  them  simple  and 

9  According to the OECD guidance, decisions which are appealed can be 
included directly in the year in which they have been taken or only once 
they  have  become  final.  Each  agency  should  decide  the  approach  it 
prefers, but ensure that the approach is consistent over time and does 
not lead to any double counting of benefits. 

5 

concise,  the  Commission  decided  not  to  retroactively  change 
calculations  for  past  years  following  annulments.    On  the  other 
hand,  in  order  to  exclude  double  counting  and  in  order  to 
maintain  consistency  over  time,  re-adoption  decisions  are 
excluded from the calculations. 

A  third  methodological  issue  was  to  what  extent  the  customer 
savings  calculations  for  antitrust  should  take  into  account 
‘informal  interventions’  of  the  Commission,  i.e.  Commission 
decisions to close a case after the Commission’s investigation led 
to  the  termination  of  the  behaviour  of  concern  and/or  the 
implementation of satisfactory remedies. 

As can be seen from the graphs above, the Commission decided 
to include those informal interventions in its calculations because 
(1) depending on the case, for a competition authority, it can be 
an adequate use of its limited investigative resources to close an 
investigation  without  a  formal  decision,  if  the  firms  under 
investigation  abandon  and/or  remedy  the  investigated  conduct; 
and  (2)  from  an  economic  point  of  view  such 
informal 
interventions  generate  the  same  customer  savings  as  formal 
interventions.  In  order  to  make  sure  the  Commission  does  not 
claim  credit  for  changes  of  business  conduct  which  were  not 
triggered  by  its  investigation,  an  informal  intervention  is  only 
included  in  the  customer  savings  calculations  in  those  cases  in 
which  the  Commission  communicated  officially  (e.g.  in  a  press 
release  or  an  official  report)  about  its  intervention  and  the 
effects on the investigated conduct.  

A  fourth  methodological  issue  which  so  far  had  also  not  been 
addressed  by  OECD  guidance  was  whether  interventions  in 
cartels  and  non-cartel  antitrust  cases  tackling  infringements 
terminated before the Commission’s investigation started 
can generate direct customers savings.  

Here, one can think for example of cartel cases where a leniency 
applicant informed the Commission of the illegal activities of the 
cartel,  the  Commission  started  an  investigation,  while  the  cartel 
stopped its activities before that date. 

It  could  be  argued  that  in  those  cases  the  Commission’s 
investigation did not cause any positive effects for customers, as 
the infringement stopped before the official investigation started. 
On  the  other  hand,  at  least  in  some  of  those  cases  the 
termination  of  the  infringement  was  possibly  caused  by  fear  of 
an  impending  investigative  action  by  the  Commission,  for 
example  because  the  parties  to  a  cartel  feared  that  one  of  the 
members  might  apply  for  leniency.  In  those  cases,  the  cartel’s 
ending  can  be  seen  as  directly  linked  to  (and  the  logical 
consequence of) an imminent Commission investigation.  

In order to keep the customer calculation exercise simple, and by 
way  of  compromise,  DG  Competition  decided  to  take  past 
infringements  into  account  in  both  cartels  and  antitrust,  if  the 
infringement  was  terminated  less  than  three  years  before  the 
Commission registered the case and otherwise not to take those 
cases into account.  

 
 
 
Customer savings from the Commission’s competition enforcement | Competition Policy Brief No 1/2022) 

Comparison  with  other  jurisdictions  outside  the 
EU 

An  increasing  number  of  competition  authorities  is  conducting 
customer  savings  calculations  along  the  lines  suggested  by  the 
OECD. Table 3 below presents data on the total customer savings 
in billion euro from the Commission and three non-EU authorities, 
namely  the  US  Department  of  Justice  and  Federal  Trade 
Commission, and the Japan Fair Trade Commission. 

2016 

2017 

2018 

2019 

2020 

Annual average 

Annual average 
adjusted by EU 
GDP 

34.9 

16.1 

32.8 

16.5 

21.1 

17.0 

17.0 

5.4 

4.7 

4.0 

7.9 

3.1 

5.0 

3.9 

7.7 

2.2 

0.6 

4.3 

3.0 

2.4 

7.0 

the 

figures 

reflecting  different 

Such a cross-jurisdictional comparison has to be made with great 
caution  and  is  subject  to  important  caveats  given  that  it  entails 
the  comparison  of 
reporting 
methodologies,  different  competition  enforcement  systems  and 
different  economies.  First,  not  all  authorities  report  customer 
savings generated by all three enforcement instruments and the 
methodologies  may  differ.  Second, 
role  of  private 
enforcement is particularly strong in the US and more prominent 
than  in  most  other  jurisdictions.  Likewise,  the  customer  savings 
generated by the administrative enforcement by the EU National 
Competition  Authorities  (NCAs)  or  for  that  matter  by  US  State 
authorities, are not taken into account, even if there are customer 
benefits  associated  with  such  interventions  as well.  Third,  it  has 
to be kept in mind that higher direct customer savings (reflecting 
intense  enforcement  activity)  do  not  necessarily  imply  a  more 
effective  competition  enforcement  overall  as  a  very  efficient 
authority 
from  past 
interventions)  may  be  able  to  more  effectively  deter  anti-
competitive  behaviour  with  fewer  interventions.  Finally,  the 
authorities 
in  question  are  responsible  for  enforcing  the 
competition  rules  in  economies  of  different  sizes.  To  overcome 
the  latter  problem,  the  last  line  of  the  table  below  reports 
average  annual  customer  savings  figures  adjusted  to  take  into 
account the differences in size of the economies considered: the 
figures  are  expressed  ‘as  if’  the  economy  in  the  different 
countries were of the same size as the EU economy in terms of 
GDP.  

(building  on  a  strong 

reputation 

Bearing  these  limitations  and  caveats  in  mind,  the  below  table 
suggests  that  the  overall  direct  customer  savings  generated  by 
the  enforcement  actions  of  the  European  Commission  are 
significant also when compared to  the customer savings figures 
reported by other competition authorities.  

Table 3: Direct customer savings (in EUR bn) as reported by different 
jurisdiction worldwide   

Year 

2012 

2013 

2014 

2015 

EC 

9.2 

6.7 

10.1 

6.0 

US (DOJ + FTC) 

JFTC 

8.1 

1.6 

3.8 

6.3 

1.6 

1.2 

0.8 

0.3 

6 

Macro-modelling  efforts  based  on  customer 
savings estimates 

As already explained above the customer savings reported in this 
policy  brief  are  only  partial  estimates  which  only  measure  the 
direct  price  effects  of  interventions  for  customers.  Therefore, 
these estimates do for instance not capture the deterrent effects 
of  competition  enforcement  nor  the  macroeconomic  impact 
resulting  from  the  decrease  in  prices  and  economic  ‘mark-ups’ 
(i.e. the difference between the average selling price and average 
marginal costs) associated with these interventions in the whole 
economy.  

In  order  to  obtain  a  more  accurate  estimation  of  these 
macroeconomic  effects,  DG  Competition  in  cooperation  with 
colleagues from DG ECFIN and  the Commission’s Joint Research 
Centre  has  conducted  over  several  years  consecutive  macro-
modelling  efforts 
in  order  to  estimate  how  competition 
enforcement might affect EU GDP and prices.10 

According  to  these  macro-modelling  efforts,  the  output  of  EU 
competition  enforcement  as  measured  by  the  number  and 
market impact of merger, cartel and other antitrust interventions 
over the period 2012-2021 is used to calibrate a mark-up shock 
applied  to  a  Dynamic  Stochastic  General  Equilibrium  (DSGE) 
model,  the  so-called  QUEST  III  model.  This  model  has  been 
developed by the Directorate-General for Economic and Financial 
Affairs  (DG  ECFIN)  and  is  used  routinely  by  the  Commission  for 
instance  for  macro-economic  forecasting.  The  QUEST  III  model 
allows  evaluating  the  impact  of  competition  enforcement  on 
economy-wide  measures  of  performance  such  as  GDP, 
employment,  prices  and  productivity.  The  economic  assumption 
underlying  the  model  is  that  reduced  prices  and  mark-ups  will 
lead  to  increased  demand,  output  and  investment  and  raise 
demand for the factors of productions (capital, labour). 

The  QUEST  model  is  complemented  by  an  input-output  model, 
which  explores  the  price  effects  of  EU  competition  policy 

10 European Commission (2022), “Modelling the macroeconomic impact of 
competition  policy:  2021  update  and  further  development”,  report 
prepared  by  the  Directorate-General  for  Competition,  the  Joint 
Research  Centre  and  the  Directorate-General  for  Economic  and 
Financial Affairs, Publications Office of the European Union. 

 
 
 
 
 
 
 
Customer savings from the Commission’s competition enforcement | Competition Policy Brief No 1/2022) 

level,  by  exploiting 
industry/sector 
interventions  at 
information  on  the  sector  distribution  of  such  interventions  and 
by tracking the interlinkages between industries.  

the 

Simulation  results  based  on  the  QUEST  model  indicate  that  EU 
competition  enforcement  of  the  type  and  magnitude  performed 
during the ten years between 2012 and 2021 is likely to have a 
positive  impact  on  GDP  in  the  range  of  0,6%  -  1.1%  in  the 
medium  to  long  term.  The  model  suggests  that  the  competition 
enforcement  actions  increase  output  and  raise  demand  for  the 
factors  of  productions  (capital,  labour).  The  combination  of  the 
price  decline  and  the  higher  wages  associated  with  increased 
labour demand and higher labour productivity yields an increase 
in  consumption.  Investment  is  also  increasing  because  the 
negative direct effect of mark-ups on future profitability is more 
than offset by the positive effect of the increasing demand due 
to the lower prices. 

These  modelling  estimates  are  based  on  conservative 
assumptions and are likely to underestimate the overall positive 
macro-economic  effects  of  competition  enforcement  as  they  do 
not  take  fully  into  account  the  positive  effects  of  competition 
enforcement  on  productivity  via  the 
in  business 
dynamism or via radical innovation. 

increase 

Further work  

DG  Competition  is  working  on  a  number  of  further  initiatives  to 
improve  the  quantification  of  the  effects  of  competition 
enforcement and of effective competition.  

First,  the  Commission  is  in  discussions  with  the  national 
competition  authorities  within  the  ECN  (European  Competition 
Network)  about  the  feasibility  to  calculate  aggregate  customer 
savings for the entire ECN combining those generated by national 
competition authorities and  by  the  Commission. For  the  purpose 
of  aggregating  these  results,  a  certain  degree  of  alignment  of 
methodology (in line with the OECD guidance) would be desirable. 

Second,  the  Commission  plans  new  research  on  the  scale  (and 
determinants) of the indirect or deterrence effect of competition 
enforcement  actions.  The 
indirect  or  deterrent  effects  of 
enforcement  are  those  customer  savings  generated  by  the 
deterrence  of  anticompetitive  conduct  which  would  have  taken 
place  in  the  absence  of  deterrent  Commission  competition 
enforcement  (e.g.  deterred  cartels,  deterred  anticompetitive 
mergers). A correct estimation of these indirect/deterrent effects 
of  EU  competition  enforcement  is  of  great  importance  for 
determining  the  overall  impact  of  competition  enforcement,  as 
the  economic  literature  considers  that  such  indirect  effects  are 
significantly  larger  than  the  direct  effect  of  competition  policy 
interventions.  

The  most  commonly  used  method  to  estimate  deterrent  effects 
relies on surveys of companies and their legal advisors about the 

interventions  on  company 
effects  of  competition  policy 
behaviour.  The  most  recent  surveys  on  the  deterrent  effects  of 
merger  and  antitrust  enforcement  are  more  than  a  decade  old 
and  cover  the  Netherlands  and  the  UK  only11.  The  intended 
research will have for the first time an EU-wide coverage and is 
expected to provide a much-needed update. 

Thirdly, during a recent workshop including economists from the 
OECD, the IMF and academia12 and as part of a recently launched 
external  study  exploring  a  number  of  aspects  of  the  State  of 
competition  in  the  EU,  DG  Competition  is  exploring  how  to 
quantify  the  benefits  of  well-functioning  competition  for  society 
and  the  reverse  side  of  the  coin,  i.e.  the  societal  costs  of 
malfunctioning competition. 

Economists  consider  that  an  increase  in  competition  has  a 
positive  impact  on  macroeconomic  performance  via  three  main 
transmission channels: changes in allocative efficiency (reduction 
in  prices  and  mark-ups  and  increase  in  business  dynamism), 
productive  efficiency 
(better  management)  and  dynamic 
efficiency  (increase  in  innovation)13.  These  changes  lead  to  a 
reduction  in  costs  and  prices,  an  increase  in  productivity  and 
innovation and ultimately an increase in growth. 

The  objective  of  this  third  workstream  on  the  benefits  of 
effective  competition  goes  beyond  the  work  on  estimating  the 
benefits  of  competition  enforcement  and  seeks  to  estimate  (1) 
how much better off is the EU in welfare/GDP terms as compared 
to  different  benchmarks  characterising  a 
less  competitive 
economy, and (2) how much untapped potential there might still 
be  to  improve  welfare/GDP  further  by  benchmarking  the  EU 
economy against a more competitive economy. 

Conclusion 

The  direct  customer  savings  generated  by  the  Commission 
interventions are large and in the range of EUR 120 to 210 billion 
for the period 2012 and 2021 or EUR 12-21 billion per year. Such 
customer  savings  calculations  allow  a  competition  authority  to 
better explain the benefits of it work to stakeholders and citizens. 

The  overall  estimates  of  direct  customer  savings  generated  by 
the  Commission’s  enforcement actions  during  the  last  ten  years 
are  significant  also  when  compared  to  the  customer  savings 

11 Twynstra  Gudde  (2005),  Research  into  the  anticipation  of  merger 
control,  Report  prepared  for  the  NMa  (Netherlands  Competition 
Authority);  Deloitte  (2007),  The  deterrent  effect  of  competition 
enforcement by the OFT, Report prepared for the Office of Fair Trading; 
Baarsma  B.,  London  Economics  (2011),  The  impact  of  competition 
interventions on compliance and deterrence, OFT Report No. 1391.  

12

See 

https://competition-policy.ec.europa.eu/consumers/reaching-

out/estimating-costs-non-competition_en  

13 Cf.  Scherer,  F.  and  Ross,  D.  (1990),  Industrial  market  structure  and 
economic  performance,  3rd  edition;  J.  B.  Baker  (2019),  The  Antitrust 
Paradigm.  

7 

 
 
 
 
 
Customer savings from the Commission’s competition enforcement | Competition Policy Brief No 1/2022) 

figures  reported  by  other  competition  authorities  from  outside 
the EU. 

though 

Even 
the  direct  customer  savings  generated  by 
Commission  interventions  are  large,  they  only  reflect  the  “tip  of 
the iceberg” in terms of the positive effects of competition policy 
for  society.  Competition  enforcement  also  generates:  (i)  indirect 
deterrence  effects;  and 
(ii)  positive  non-price  effects  on 
innovation,  quality,  and  productivity  which  are  likely  to  be 
significantly larger, but also more difficult to calculate. 

Further  work  will  involve  further  cooperation  and  coordination 
within the ECN as regards customer savings calculations, seek to 
make progress as regards quantification of the deterrent/indirect 
effects  of  competition  enforcement  and  seek  to  make  progress 
on the quantification of the ‘costs of non-competition’. 

8