EU-UK divergence on digital mergers – Case 1: Amazon/iRobot 07 February 24 Miklós Kozma

The UK's exit from the EU in 2021 empowered the UK Competition and Markets Authority (CMA) to probe big global mergers concurrently with the European Commission. So far, six acquisitions in digital markets have faced such parallel merger reviews. In five of them, both the acquirer and the target was a US-based company.

Our new report looks at these cases side by side, shedding light on the different conclusions often reached by the two authorities.

Stay tuned over the next weeks, as we look back at each case that saw divergent outcomes. Complimentary copies of detailed case summaries from Cullen International’s Antitrust & Mergers Database will be available on request.

Case 1: Amazon/iRobot

In January 2024, Amazon abandoned its proposed $1.7bn (€1.58bn) acquisition of iRobot, a supplier of robot vacuum cleaners, after failing to secure clearance for the transaction from the European Commission.

Following an in-depth phase II investigation, the Commission was concerned about Amazon foreclosing iRobot’s rivals by preventing them from selling on its online marketplace or degrading their access to the marketplace.

In contrast, the CMA unconditionally cleared the transaction already in June 2023, after its initial phase I merger review did not identify any competition issues.

The CMA reckoned that Amazon would not have the incentive to foreclose iRobot’s rivals in the UK, mainly because the UK robot vacuum cleaner market is small and not expected to grow significantly in the future.

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