You are using an outdated browser and your browsing experience will not be optimal. Please update to the latest version of Microsoft Edge, Google Chrome or Mozilla Firefox. Install Microsoft Edge

November 28, 2014

Trade Laws Prohibit Anticompetitive Practices

Bangkok Post, Corporate Counsellor Column

Competition law, which is also called antitrust law in the United States, trade practices law in Australia and Britain, or antimonopoly law in Russia and China, may go by many names, but what most competition laws generally have in common are these three elements:

  • Prohibition of anticompetitive practices, such as price gouging or predatory pricing, by which a company could surreptitiously attain a position of dominance in a market, or deny companies that are already dominating a market, or conduct abusive behavior against competitors and consumers.
  • Prohibition of agreements or practices that repress free trade and competition between companies, as is usually the case with so-called cartels, which are agreements between competitors to fix prices or to deny a new competitor entry into a market.
  • Supervision of the mergers and acquisitions of companies, including some joint ventures.

In today’s economy, it is not uncommon for two or more companies to merge in order to lower their costs by removing duplicate departments or operations (economies of scale); to increase the size of their raw material orders (thereby obtaining bulk-buying discounts); and to increase their market share.

Apart from the commercial considerations of potential financial and structural benefits influencing a decision to merge, management must also take into account the so-called merger control rules of anticompetition law.

Any merger or acquisition, which usually means one company buying out another company’s shares, always involves the concentration of economic power in the hands of fewer entities than before.

Legal control of mergers and acquisitions of large corporations, including joint ventures, is therefore necessary to protect consumers from companies obtaining too much market power, which in turn could enable them to raise their prices to an unreasonable level.

The difference between a merger control regime and rules against anticompetitive practices is that the former works proactively. It requires the merging entities or joint ventures to apply for permission with the relevant competition authorities of the affected jurisdictions before a merger takes place.

If the competition authority finds that such a merger would lead to a market-dominant position and significantly impede or substantially lessen effective competition, it can either demand remedies, such as divesting part of the merged business allowing access to facilities, or it can prohibit the merger altogether.

Merger regulation began in the United States under the Clayton Antitrust Act of 1914, in the European Union with Merger Regulation 139/2004 (known as the ECMR) in 2004 (although different member states had their own national merger control laws long before that), and in Japan with Law No.54, the Anti-Monopoly Act in 1947.

The duty to notify the competition authority in an affected jurisdiction about an intended merger is triggered at specific threshold amounts.

In Japan, the Japan Fair Trade Commission must be notified of an intended merger if the aggregate domestic sales in Japan of all corporations within the same combined business group of one of the merging companies exceed JPY 20 billion (about THB 5.58 billion), and if the aggregate domestic sales of all corporations within the same combined business group of one of the other merging companies exceeds JPY 5 billion.

In the European Union, the European Commission must be notified if all the entities related to the intended merger have a combined worldwide turnover of more than EUR 2.5 billion (THB 102 billion); each of at least two of the entities concerned has EU-wide turnover exceeding EUR 100 million; and each of at least two of the entities has national turnover of more than EUR 25 million, unless each entity achieved more than two-thirds of its EU-wide turnover in one and the same member state.

Thailand has also introduced a merger control regulation in Section 26 of its Trade Competition Act of 1999. It states: “A business operator shall not carry out a business merger which may result in monopoly or unfair competition as prescribed and published in the Government Gazette by the Trade Competition Commission unless the commission’s permission is obtained. The publication by the commission under paragraph one shall specify the minimum amount or number of market share, sales volume, capital, shares or assets in respect of which the merger of business is governed thereby.”

Unfortunately, to this day, the commission has not specified these threshold amounts. As a result, the country has no merger control regime that is enforced in practice.

It should be noted, however, that the commission did approve a draft rule for merger thresholds in June 2013. It remains to be seen whether these thresholds will be adopted by 2015, in time for the ASEAN Economic Community.

RELATED INSIGHTS​ 

May 8, 2026
The global trade environment for Thai exporters in 2026 has shifted significantly. Recent enforcement developments in both the United States and the European Union show a clear shift in trade policy: regulators are no longer focused solely on tariff levels, but also on whether products genuinely originate where exporters claim they do. Adding to this complexity, the US Supreme Court’s February 2026 decision striking down the use of the International Emergency Economic Powers Act (IEEPA) to impose tariffs has upended the legal basis for a major pillar of US tariff policy, creating significant legal and commercial uncertainty for exporters worldwide, including in Thailand. For Thai companies integrated into regional supply chains, this change carries material implications. Although the IEEPA-based US reciprocal tariffs have been struck down, intensified circumvention enforcement continues under separate legal authorities, and the administration has signaled its intent to reimpose tariffs under alternative statutory frameworks, while EU authorities are using anti-circumvention investigations where trade patterns shift. In both jurisdictions, the decisive issue is whether manufacturing in Thailand constitutes substantial transformation under applicable rules of origin. Such origin determinations increasingly drive duty exposure, audit risk and commercial disputes. In 2026, the ability to defend a product’s Thai origin is not merely a procedural step, it is central to preserving market access in the US and EU. Impact Of US Circumvention Enforcement and an Uncertain Tariff Landscape Following the 2025 Framework for an Agreement on Reciprocal Trade, Thailand saw a shift in its tariff relationship with the US. A substantial range of Thai-origin goods were subject to a 19% reciprocal tariff under the IEEPA. However, the Supreme Court’s ruling invalidating the use of IEEPA for tariffs has removed the legal basis for that rate. The Administration has indicated it intends to pursue replacement tariffs under other statutory authorities,
April 15, 2026
On March 31, 2026, Vietnam’s government issued Decree 102/2026/ND-CP (Decree 102), which amends Decree 75/2019/ND-CP on administrative sanctions for competition law violations (Decree 75). Effective from May 20, 2026, the new decree introduces a number of significant changes aimed at strengthening enforcement, revising penalty structures, and broadening the range of remedial measures, primarily for violations related to economic concentration. Revised Penalties for Economic Concentration Violations Decree 102 significantly revises the penalties for violations related to economic concentration. Failure to notify an economic concentration; implementing an economic concentration before clearance Under the new framework, Articles 14 and 15 of Decree 75 have been amended to impose a range of monetary fines, rather than relying solely on percentage‑based penalties as under the previous regime, for violations involving the failure to notify an economic concentration or the implementation of an economic concentration prior to clearance. The fines range from VND 500 million to VND 1 billion for each enterprise participating in a concentration with combined assets, revenues, or purchase value below VND 3,000 billion in the preceding fiscal year, capped at 5% of the violating enterprise’s total turnover in the relevant market. For concentrations meeting or exceeding the VND 3,000 billion threshold across those same metrics, the fines increase to VND 1 billion to VND 2 billion per enterprise, also subject to the 5% cap. These differentiated thresholds allow penalties to better reflect the size of the transaction and its potential competitive impact. Non-compliance with conditional approvals Enterprises that do not implement or only partially implement the conditions specified in a conditional economic concentration approval decision face fines ranging from 1% to 3% of total turnover in the relevant market during the fiscal year preceding the violation. Decree 102 also adds a new remedial measure requiring enterprises to fully implement all conditions
April 9, 2026
In March 2026, the United States Trade Representative (USTR) initiated two significant investigations under Section 301(b) of the Trade Act of 1974 that directly affect Thailand. The first investigation examines overproduction in manufacturing sectors caused by government support or policies that distort normal market conditions across 16 economies, including Thailand. The second investigation, launched the following day, targets 60 economies, also including Thailand, for alleged failures to impose and effectively enforce prohibitions on the importation of goods produced with forced labor. Taken together, these investigations represent a significant escalation in US trade enforcement and create substantial risk for Thai exporters, manufacturers, and businesses with supply chain connections to the United States. The investigations are moving on an accelerated timeline, with the USTR indicating that potential trade measures, including tariffs, could be imposed as early as July 2026. This article provides an overview of the investigations, highlights their specific implications for Thailand, and outlines practical considerations for affected businesses. Section 301 as a Trade Enforcement Tool Section 301 of the Trade Act of 1974 gives the USTR authority to investigate foreign acts, policies, or practices that are considered unreasonable or discriminatory and that burden or restrict US commerce. If the USTR concludes that such practices exist, the statute allows a wide range of remedial measures, including the imposition of tariffs, nontariff trade restrictions, and negotiated agreements with foreign governments. Unlike other trade authorities, Section 301 does not set limits on the level of tariffs or the duration of measures, giving the USTR considerable flexibility to address perceived trade imbalances or unfair practices. Historically, Section 301 investigations take up to a year to complete. In this instance, however, the USTR has indicated that the investigations will proceed on a much faster timetable, with an unofficial target of concluding by July 2026.
April 1, 2026
On March 30, 2026, Thailand’s Customs Department announced a strategy to raise import duties on a broad range of consumer goods—including plastic items and electronics accessories—to their maximum statutory ceilings, which often sit at 30% or 40%. Many of these goods currently benefit from promotional or incentive rates as low as 5%. For importers, e-commerce platforms, and logistics providers, this development demands immediate attention. While these increases generally require cabinet approval, they do not require full parliamentary amendment of the Customs Tariff Decree B.E. 2530, as the Customs director-general and the finance minister hold delegated authority to adjust rates within existing statutory bounds. Businesses should not assume that the legislative process will provide significant lead time before higher rates take effect. Death of the De Minimis: Abolishing the THB 1,500 Loophole This “ceiling-rate” policy, which is designed to equalize the landed cost of foreign goods with the domestic production costs of Thai manufacturers, builds on a sweeping set of customs reforms that have already begun to reshape Thailand’s trade environment. The foundation of this new regime was laid on January 1, 2026, when Thailand formally abolished the longstanding THB 1,500 duty exemption for small imported parcels under Customs Notification No. 219/2568. Every imported item is now subject to VAT and applicable import duties for its declared value, regardless of parcel size or transaction amount. By narrowing the scope of exemptions previously granted to low-value goods under the Customs Tariff Decree B.E. 2530, the government has made clear that the era of tax-free cross-border micro-imports is over. Three-Phased Strategy and Legal Modernization The March 30 announcement is the second phase of a three-part regulatory roadmap: Immediate enforcement: The removal of the THB 1,500 loophole and the imposition of VAT on all parcels, effective January 1, 2026. Tariff realignment: The current