CELEX: 32019M9293
Language: en
Date: 2019-05-13 00:00:00
Title: Commission Decision of 13/05/2019 declaring a concentration to be compatible with the common market (Case No COMP/M.9293 - Iconex / Hansol Paper Co. Ltd. / Mirae Asset Daewoo Hunters Private Equity Fund) according to Council Regulation (EC) No 139/2004 (Only the English text is authentic)

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                                                                   information omitted has been replaced by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