EUROPEAN COMMISSION
DG Competition
Case M.8569 -
EUROPCAR /
GOLDCAR
Only the English text is available and authentic.
REGULATION (EC) No 139/2004
MERGER PROCEDURE
Article 6(1)(b) NON-OPPOSITION
Date: 05/12/2017
In electronic form on the EUR-Lex website under
document number 32017M8569
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-MERGE[email protected].
EUROPEAN COMMISSION
Brussels, 5.12.2017
C(2017) 8396 final
To the notifying party :
Dear Sir or Madam,
Subject: Case M.8569 – Europcar/Goldcar
Commission decision pursuant to Article 6(1)(b) of Council
Regulation No 139/2004
1
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.
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omitted has been replaced by ranges of figures or a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.
PUBLIC VERSION
2
Table of contents
1. THE PARTIES AND THE OPERATION .................................................................. 3
2. EU DIMENSION ........................................................................................................ 3
3. MARKET DEFINITION ............................................................................................ 4
3.1. Product market definition .................................................................................. 4
3.1.1. Distinction between short-term and long-term car rental
services ................................................................................................ 4
3.1.2. Distinction between rental services for passenger cars and
industrial vehicles ................................................................................ 4
3.1.3. Distinction between corporate and leisure short-term car
rental services ...................................................................................... 5
3.1.4. Distinction between low cost, value and premium car rental
services ................................................................................................ 5
3.1.5. Distinction between on-airport and off-airport car rental
services ................................................................................................ 6
3.1.6. Conclusion ........................................................................................... 8
3.2. Geographic market definition ............................................................................ 8
4. COMPETITION ASSESSMENT ............................................................................... 9
4.1. Elements common to the assessment of the markets for the supply of
short-term car rental services ............................................................................. 9
4.1.1. Market structure ................................................................................... 9
4.1.2. Closeness of competition ................................................................... 10
4.1.3. The role of brokers ............................................................................ 12
4.1.4. Barriers to entry or expansion ........................................................... 13
4.2. Overview of the Parties' market shares ........................................................... 17
4.2.1. Methodology for estimating market shares at local and
national levels .................................................................................... 17
4.2.2. Overlapping markets ......................................................................... 17
4.3. Market-specific analysis .................................................................................. 20
4.3.1. France ................................................................................................ 20
4.3.2. Italy .................................................................................................... 23
4.3.3. Portugal .............................................................................................. 39
4.3.4. Spain .................................................................................................. 45
4.4. Coordinated effects .......................................................................................... 78
5. CONCLUSION ......................................................................................................... 80
3
(1) On 27 October 2017, the European Commission received a notification of a
proposed concentration pursuant to Article 4 of the Merger Regulation by which
Europcar Groupe S.A. ("Europcar", France) acquires within the meaning of
Article 3(1)(b) of the Merger Regulation control of the whole of Car Rentals
Topco, S.L. and its subsidiaries (together "Goldcar", Spain) by way of purchase
of shares (the "Transaction").
2
Europcar and Goldcar are collectively referred to as
the "Parties".
1. THE PARTIES AND THE OPERATION
(2) Europcar is mainly active in the short-term vehicle rental market, with an average
fleet of around 200 000 vehicles and a presence in more than 140 countries
worldwide. Europcar offers rental vehicles through its brands Europcar as well as
InterRent, which focuses on lower cost services. In addition, Europcar is active in
the mobility markets and, to a minor extent, in the sale of used cars.
(3) Goldcar is active in the leisure segment of the short-term vehicle rental market,
with an average fleet of around 35 000 vehicles and 76 offices opened in the EU
(Spain, Portugal, France, Italy, Greece and Croatia). In addition, Goldcar is
marginally active in the sale of used cars.
(4) The Transaction consists in the acquisition by Europcar of 100% of the shares of
Goldcar and, as a result, in the acquisition of sole control over Goldcar.
(5) Therefore, the Transaction constitutes a concentration within the meaning of
Article 3(1)(b) of the Merger Regulation.
2. EU DIMENSION
(6) The undertakings concerned have a combined aggregate world-wide turnover of
more than EUR 2 500 million (Europcar:
3
EUR [>4 000] million; Goldcar: EUR
[>300] million).
4
Each of them has an EU-wide turnover in excess of EUR 100
million (Europcar: EUR […]; Goldcar: EUR […]).
(7) The combined aggregate turnover of Europcar and Goldcar exceeds EUR 100
million in […], […] and […], and each of them has a turnover in excess of EUR
25 million in each of these three Member States.
(8) The two undertakings concerned do not achieve more than two-thirds of their
aggregate EU-wide turnover within one and the same Member State.
(9) The Transaction has therefore an EU dimension according to Article 1(3) of the
Merger Regulation.
2
Publication in the Official Journal of the European Union No C 376, 08.11.2017, p. 6.
3
Based on Europcar's shareholding structure and attendance rate at past shareholders' meetings, it is
assumed, for the purpose of this Decision, that Eurazeo S.A. exercises de facto control over Europcar.
Nevertheless, the Transaction would have an EU dimension even if Europcar were deemed not
controlled by Eurazeo.
4
Turnover calculated in accordance with Article 5 of the Merger Regulation.
4
3. MARKET DEFINITION
(10) The Parties' activities essentially overlap in the supply of short-term car rental
services in France, Italy, Portugal and Spain, in particular at airports, where they
serve airline passengers.
5
3.1. Product market definition
3.1.1. Distinction between short-term and long-term car rental services
(11) The Commission has found in previous decisions that it may be appropriate to
distinguish between short-term car rental services (e.g. provision of cars for an
individually agreed duration for business or leisure trips) and long-term car rental
services (e.g. with a rental period of more than one year).
6
In addition, it has
considered whether other mobility solutions such as car sharing form part of
short-term car rental services.
7
(12) Europcar defines the relevant market as the short-term vehicle rental market.
8
(13) In any case, for the purpose of this Decision, the question of the distinction
between short-term and long-term car rental services and, within the short term
car rental services, between the different mobility solutions can be left open, as
the Transaction would not raise serious doubts as to its compatibility with the
internal market under any plausible market definition.
(14) Considering that Goldcar does neither offer long-term car rental services
9
nor
other mobility services than short-term car rental,
10
the Commission will focus its
analysis on the market for short-term car rental services.
3.1.2. Distinction between rental services for passenger cars and industrial vehicles
(15) The Commission has also considered in previous decisions the possibility of
further dividing the short-term car rental market between passenger cars and
industrial vehicles, i.e. trucks.
11
(16) Europcar considers that there is an overall short-term rental product market.
12
5
The Transaction also relates, to a minor extent, to the sale of used cars. However, given the negligible
activity of the Parties, the Transaction would not lead to any affected market in relation to the sale of
used cars. Therefore, the sale of used cars will not be further considered in this Decision.
6
See e.g. Cases M.6333 ï€ BMW/ING Car Lease, paragraph 17; M.4613 ï€ Eurazeo S.A./Apcoa Parking
Holdings Gmbh, paragraph 16.
7
See e.g. Cases M.8309 – Volvo Car Corporation/First Rent A Car, paragraph 44; M.6333 ï€ BMW/ING
Car Lease, paragraph 18.
8
Form CO, paragraphs 92 and 100.
9
Form CO, paragraph 102.
10
Form CO, Annex 16 ï€ Europcar's reply to QP1 of 14 July 2017.
11
See e.g. Case M.5347 ï€ Mapfre/Salvador Caetano/JVs, paragraph 9.
12
Form CO, paragraph 92.
5
(17) In any case, for the purpose of this Decision, the question of the distinction
between passenger cars and industrial vehicles can be left open, as the
Transaction would not raise serious doubts as to its compatibility with the internal
market under either plausible market definition.
(18) Considering that Goldcar does not offer rental services for industrial vehicles,
13
the Commission will focus its analysis on the market for rental services for
passenger cars.
3.1.3. Distinction between corporate and leisure short-term car rental services
(19) Within the market for short-term car rental services, the Commission has defined
separate markets according to customer groups, differentiating between corporate
and leisure car rentals. Corporate car rentals would mainly be the result of
corporate agreements concluded between major car rental companies and large
corporations. While leisure customers in general rent cars from a wide range of
companies, corporate car rentals are usually book on the basis of corporate
agreements from a small group of large, international reliable rental companies
that have the requisite airport network, reputation, and service levels.
14
(20) Europcar submits that, from the demand-side perspective, there are leisure
customers with similar preferences to corporate customers, while there is a high
degree of supply-side substitutability.
15
(21) In any case, for the purpose of this Decision, the question of the distinction
between corporate and leisure short-term car rental services can be left open, as
the Transaction would not raise serious doubts as to its compatibility with the
internal market under either plausible market definition.
(22) Considering that Goldcar addresses only leisure customers, the Commission will
assess the effects of the Transaction on the basis of (i) all customers (corporate
and leisure rentals), and (ii) leisure customers only.
3.1.4. Distinction between low cost, value and premium car rental services
(23) By analogy to air carriers, some car rental operators (such as Goldcar) market
their services as a "low cost" product, as opposed to value or premium services.
The low cost segment aims at addressing the customers' needs and expectations
through a "no-frills" strategy by which any cost which is not an absolute need is
cut.
16
(24) The Commission has not considered a distinction between car rental companies
based on their operating models yet.
(25) Europcar submits that the market for car rental services should not be divided
between the low cost, value and premium segments, since there are no structural
13
Form CO, paragraph 102.
14
See e.g. Case M.2510 ï€ Cendant/Galileo, paragraph 21.
15
Form CO, paragraphs 93-94.
16
Form CO, Annex 16 ï€ Europcar's reply to QP1 of 14 July 2017.
6
differences between low cost and other brands in the car rental industry.
According to Europcar, the products offered by low cost, value and premium
brands are homogeneous. In addition, they are distributed through the same
channels, very often over the internet, and brokers present the products to
customers in the same way.
17
Finally, Europcar has submitted a "Price
comparison analysis" according to which the differences between the low cost,
value and premium categories are very limited.
18
(26) On this topic, the market investigation is inconclusive. A number of car rental
operators and brokers having expressed a view consider that low cost car rental
services are not interchangeable with value or premium car rental services
provided at the same location.
19
One respondent submitted that "a client booking
with a premium brand would expect a higher level of service, faster pick up
process, better quality of vehicle and transparency in pricing", while "a client
booking with a low cost company should expect longer pick up process, hidden
extras and in certain cases a lower quality of vehicle".
(27) However, a comparable number of market participants highlight that the validity
of this distinction depends on the customers. One competitor noted that, since
"customers base their purchase decision mainly on price the distinction between
low cost, value for money or premium is irrelevant, therefore all companies are
interchangeable." Another competitor indicated that in the country where it
operates, "the difference between low cost services and high-level services is
reduced more and more and the customer looks for the lowest price as first
choice."
20
(28) Overall, the Commission has not found solid-enough evidence to distinguish a
low cost market for car rental services. Therefore, for the purpose of this
Decision, the Commission considers that low cost, value and premium car rental
services form part of one and the same market. The differences between low cost,
value and premium services will nevertheless be taken into account in the
competitive assessment, in particular when looking at closeness of competition.
3.1.5. Distinction between on-airport and off-airport car rental services
(29) Considering the focus of Goldcar's activities on services to airport passengers, the
Commission has assessed whether the services provided by car rental companies
located within the airport and operating under a concession agreement ("on-
airport" services) and the services provided by car rental companies operating in
the surrounding of the airport without a concession agreement ("off-airport"
services) are substitutable.
21
17
Form CO, Annex 16 ï€ Europcar's reply to QP1 of 14 July 2017.
18
Form CO, Annex 19 ï€ Price comparison analysis report prepared by Charles River Associates of 5
September 2017.
19
Replies to Questionnaire 1 to market participants, question 6.
20
Replies to Questionnaire 1 to market participants, question 6.1.
21
Off-airport operators may provide car rental services from a rental station located at a walking distance
from the airport terminal, or through a courtesy bus (free shuttle bus transportation), or through "meet
& greet" services if an assistant receives the customers at the airport to deliver/collect the car.
7
(30) Europcar considers that no distinction should be made between the car rental
services offered on-airport and off-airport. It argues that there are no significant
differences between the products offered by concession holders and non-
concession holders in any of the three phases of the customers' experience
(reservation, pick-up and drop-off).
22
(31) On this topic, the market investigation yielded mixed results. The majority of the
car rental companies having expressed a view submit that customers consider on-
airport and off-airport services as interchangeable, while the majority of brokers
having expressed a view are of the opposite opinion.
23
A number of respondents
explain that the main driver for customers to choose a car rental company is price,
and that the off-airport location of the service does not necessarily drive their
decision, particularly in the leisure segment.
24
(32) Likewise, car rental companies and brokers bring forward the importance of the
location of the car pick-up point (and its distance from the point of interest, such
as the airport) in customers' choice of service providers. They notably indicate
that airport passengers typically prefer on-airport locations. However, they also
rank price as the most important criterion of choice for customers, ahead of the
distance of car pick-up.
25
(33) In this context, only a minority of respondents having expressed a view submit
that customers of on-airport car rental services would not be willing to switch to
off-airport car rental services if the current prices of on-airport services were to
increase by 5%-10% on a permanent basis.
26
(34) In terms of competitive landscape, the Commission notes that car rental
companies holding a network of stations switch from on-airport to off-airport
operations (and vice-versa) depending on business opportunities and profitability.
(35) In addition, the websites of car rental companies and brokers, which are the main
distribution channel of car rental services,
27
advertise similarly on-airport and
off-airport services.
28
(36) Therefore, for the purpose of this Decision, the Commission considers that it is
not appropriate to consider on- and off-airport services as distinct markets, at least
for leisure customers targeted by Goldcar. The differences between on-airport and
off-airport car rental services will nevertheless be taken into account in the
competitive assessment, in particular when looking at closeness of competition.
22
Form CO, paragraph 235 and following.
23
Replies to Questionnaire 1 to market participants, question 8.
24
Replies to Questionnaire 1 to market participants, question 8.1.
25
Replies to Questionnaire 1 to market participants, questions 5 and 5.1.
26
Replies to Questionnaire 1 to market participants, question 10.
27
For example, approximately […]% of the Parties' reservations at airports are done online (Form CO,
paragraph 239).
28
See examples of screenshots provided by Europcar (Form CO, paragraph 240 and following).
8
3.1.6. Conclusion
(37) In light of the above, for the purpose of this Decision, the Commission defines
two relevant product markets, on which it will base its competitive assessment: (i)
the overall market for the short-term passenger car rental services, (ii) the market
for short-term car rental services to leisure customers only.
29
3.2. Geographic market definition
(38) The Commission has considered in previous decisions that the market for short-
term car rental services is national in scope.
30
(39) Europcar submits that there is a strong local angle from the customers'
perspective, since choice is heavily based on location, and to a certain extent price
competition takes place at local level to a certain extent.
31
(40) In this context, and taking into consideration Goldcar's focus on leisure services
provided at airports, the Commission has assessed whether the local dimension is
relevant for the market of short-term car rental services.
(41) The results of the market investigation tend to confirm the local features of the
provision of short-term car rental services. In particular, the majority of car rental
companies and brokers submit that customers do not consider car rental services
offered at airports as interchangeable with car rental services offered downtown.
32
Likewise, all the airport managers that participated in the market investigation
confirm that the car rental services offered at airports are not interchangeable with
the services offered downtown.
33
(42) For the purpose of this Decision, the question of whether the geographic scope of
the market for short-term car rental services is national or local can be left open,
as the Transaction would not raise serious doubts as to its compatibility with the
internal market under either plausible market definition.
(43) The Commission will assess the effects of the Transaction on short-term car rental
services at national level and at local level, the latter defined as services provided
either (i) at the airport (including both on- and off-airport services), or (ii)
downtown.
34
29
The majority of the car rental operators and brokers does not deem relevant any further distinction
between the different services offered by car rental operators (replies to Questionnaire 1 to market
participants, question 12).
30
See e.g. Case M.8309 – Volvo Car Corporation/First Rent A Car, paragraph 45; M.3090
–
Volkswagen/Offset/Crescent/LeasePlan/JV, paragraph 12.
31
Form CO, paragraph 111.
32
Replies to Questionnaire 1 to market participants, questions 7 and 7.1. For instance: "Most of the
services offered at the airports are for inbound tourism whereas downtown is mainly for the domestic
market. The needs of each market differ completely."
33
Replies to Questionnaire 2 to airport managers, question 3.
34
For the purpose of this Decision, car rental services offered at railway stations will be considered as
downtown stations.
9
4. COMPETITION ASSESSMENT
(44) 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 as a
result of the creation or strengthening of a dominant position.
(45) The assessment of the compatibility of the Transaction with the internal market
will focus on the non-coordinated horizontal effects in the markets for short-term
car rental services where the Parties' activities overlap, according to the
framework set out in the Guidelines on the assessment of horizontal mergers
under the Council Regulation on the control of concentrations between
undertakings.
35
(46) For that purpose, the Commission will first analyse the elements common to the
different geographic markets (section 4.1), before providing an overview of the
Parties' market shares (section 4.2) and a more detailed analysis of the national
and local markets where the Parties are both active (section 4.3).
(47) In addition, considering the level of concentration of certain local markets, the
Commission will assess whether the Transaction is likely to give rise to
coordinated effects (section 4.4).
4.1. Elements common to the assessment of the markets for the supply of short-
term car rental services
(48) Given the high number of markets impacted by the Transaction, certain elements
which are common to all the markets are presented in the following sections 4.1.1
to 4.1.4. Those arguments apply to all markets assessed in section 4.3.
4.1.1. Market structure
(49) Europcar considers that the relevant markets and segments are highly
competitive.
36
(50) According to respondents to the market investigation, the market for car rental
services is dynamic and relatively fragmented in the Member States where the
Parties' activities overlap (France, Italy, Portugal and Spain).
(51) Generally, there are five large multi-national car rental companies that operate
under well-established brands and through an extensive footprint of stations
disseminated nation-wide.
37
These largest car rental companies in the EU not only
service corporate customers, but also leisure travellers to a large extent,
38
either
directly under their more recognisable brand or under subsidiary brands, under
35
OJ C 31, 5.2.2004 (the "Horizontal Merger Guidelines"), paragraphs 24 to 38.
36
Form CO, paragraph 205.
37
The five largest car rental companies are Avis, Enterprise, Europcar, Hertz and Sixt.
38
For example, Europcar generated 79% and 73% of its revenues from leisure customers in Portugal and
Spain respectively in 2016 (Europcar's reply to RFI4, question 3).
10
which low cost offerings notably are marketed.
39
In some instances, these large
car rental companies operate in a geographical area through franchisees.
40
(52) In addition to these large multi-national car rental companies, there are currently
other medium-size car rental operators operating national or regional networks of
stations, which generate a sizable volume of sales.
(53) Finally, there are also local car rental companies, which mostly service leisure
customers traveling to touristic destinations. The volume of sales generated by
these smaller players can however be rather significant in certain areas, such as in
certain islands in Portugal and Spain.
(54) The market investigation confirms that large companies like the Parties and
smaller-scale car rental companies compete with each other. A majority of
respondents to the market investigation consider that local and regional car rental
companies exert a strong competitive pressure on national and international car
rental companies, in particular in touristic areas where demand is mainly driven
by price.
41
They notably point to the fact that brokers increase the competitive
pressure exerted by local or regional car rental companies on national or multi-
national car rental companies.
42
(55) In addition, the Commission notes that […].
43
(56) As a consequence, the Commission considers that local and regional car rental
companies do exert a significant competitive constraint on the Parties in France,
Italy, Portugal and Spain.
4.1.2. Closeness of competition
(57) Europcar submits that the Parties are not close competitors because they compete
for different segments. While Europcar is active in both the corporate and leisure
segments (directly or through InterRent), Goldcar is a pure leisure player focusing
mainly on airports.
44
(58) According to respondents to the market investigation, short-term car rental
services, more particularly their leisure segment, tend to be commoditised. The
importance of price was underlined by car rental operators and brokers in the
market investigation, since they both consider that the most important criterion
39
For example, Enterprise caters for leisure customers through its subsidiary brand Alamo, while Avis
does so with Maggiore; in addition Hertz offers value car rental services through its subsidiary brands
Dollar and Thrifty, and low cost services through Firefly – Form CO, paragraph 71, in conjunction
with the Competitive assessment submitted by the Parties to the Commission on 16 November 2016.
40
[…] (Form CO, paragraph 193), the Commission considers that franchises should be treated as third
parties for the purpose of this Decision. In any case, the question of franchises does not have any
material impact on the competitive assessment, […] (Form CO, paragraphs 194-195).
41
Replies to Questionnaire 1 to market participants, question 15; Questionnaire 2 to airport managers,
question 9.
42
Replies to Questionnaire 1 to market participants, question 16.
43
Form CO, Annex 41.
44
Form CO, paragraph 18.
11
for customers in their choice of car rental is by far the price, while the brand of
the car rental operator would play the least important role.
45
The hierarchy in
these criteria was actually confirmed by the consumer associations that
participated in the market investigation.
46
(59) The Parties' competitors and airport managers that participated in the market
investigation did not list Goldcar as a close competitor of Europcar in any of the
Member States where the two Parties operate. They rather identify Avis,
Enterprise, Hertz and Sixt as the closest competitors to Europcar.
47
Conversely,
the respondents to the market investigation considered that a number of car rental
companies, especially with their low cost brands, are close competitors of
Goldcar, particularly in Portugal and Spain. Respondents for instance refer to (i)
Avis' brand Maggiore, Europcar's brand InterRent, Centauro, Hertz, or Guerin
48
in Portugal, and (ii) Budget, Hertz's brands Dollar and Firefly, or Record Go (in
Spain).
49
(60) These responses to the market investigation are linked to the different positioning
of the Europcar group as a multi-brand full-service provider, operating in the low
cost segment through the InterRent brand, and of Goldcar as a pure low cost
player. Goldcar and InterRent are thus perceived as addressing the specific needs
and expectations of customers targeted by low cost services, while the Europcar
group would rather focus value and premium services.
50
(61) The different customers' needs and expectations addressed by the low cost brands
Goldcar and InterRent against the value or premium brand Europcar are also
reflected in the internal documents analysed by the Commission. In the M&A
presentation to Europcar's Supervisory Board of 30 March 2017,
51
it is stated that
[…] (Slide 3). In the same presentation, and in the strategic analysis presented to
the Supervisory Board of 22 May 2017,
52
there are references to the operators
positioned as low cost car rental suppliers […]. Moreover, […] according to the
presentations to the Supervisory Board. Overall, Europcar does not appear to
consider Goldcar as a close competitor according to these internal documents, but
rather as a brand complementary to its current portfolio.
(62) Given that Goldcar is only active in the leisure segment and is positioned as a low
cost operator, compared to the full-range offering of Europcar, and that Europcar
sees the acquisition of Goldcar as fulfilling a gap in its offering, the Commission
45
Replies to Questionnaire 1 to market participants, question 5.
46
Replies to Questionnaire 3 to customer associations, question 3.
47
Replies to Questionnaire 1 to market participants, question 17.
48
Guerin operates in Portugal through their own brands Guerin and Drive for less, as well as through an
exclusive franchise agreement with Enterprise, including the brands National and Alamo – Replies to
Questionnaire 1 to market participants, question 2.
49
Replies to Questionnaire 1 to market participants, question 18.
50
See section 3.1.4 for the definition of low cost, value and premium car rental services.
51
Form CO, Annex 14(b).
52
Form CO, Annex 14(e).
12
considers that Goldcar does not compete as closely against Europcar (as a whole)
as other multi-brand actors, such as Hertz or Avis.
4.1.3. The role of brokers
(63) A large share of leisure car rental services is distributed through internet
aggregators or intermediaries (together "brokers").
53
Brokers can act as (i) agents
of the car rental companies (receiving a commission), or as (ii) resellers that
usually commit to purchase certain volumes from different car rental companies
and then sell the product to the final customer, deciding on the rental price based
on their capacity of purchase and sale.
54
(64) Europcar submits that brokers compete directly against car rental operators in the
market, at least for leisure customers.
55
(65) In this regard, Europcar further submits that the use of technology and
digitalisation has enabled leisure customers to easily compare online rental rates
available from various car rental operators for any given product at any given
location. Customers frequently use on-line price comparison engines and book car
rental services through on-line brokers, which offer services at very competitive
prices and drive price competition.
56
(66) The majority of the car rental operators that participated in the market
investigation submit that they distribute their services through at least one
broker.
57
The features of their distribution agreements with brokers vary, but the
market investigation shows that brokers work mostly as resellers, and they are
capable of setting the final price to be paid by the customer to a large extent.
(67) In their replies to the market investigation, the majority of car rental operators
submitted that brokers compete head-to-head against them,
58
mostly because
brokers acting as resellers can offer rates below the prices set by the pure car
rental companies through their own direct distribution channels.
(68) One competitor to the Parties noted that "customers compare different available
offers and normally choose the lowest price for the same product", while another
competitor added that "internet aggregators can make pressure on car rental
players pricing strategy thanks to their investment on the web as well as their
popularity".
59
53
As a way of example, the revenue generated by Europcar and Goldcar through brokers was [≥40]%
and [≥60]% respectively over their total revenues generated in 2016 (Form CO, Annex 34).
54
Europcar and Goldcar's revenues generated through brokers were split […]% and […]% between the
agent and reseller models respectively in 2016 (Form CO, Annex 34).
55
Form CO, paragraph 11.
56
Form CO, paragraph 9.
57
Replies to Questionnaire 1 to market participants, question
13.
58
Replies to Questionnaire 1 to market participants, question 14.
59
Replies to Questionnaire 1 to market participants, question 14.1.
13
(69) In addition, the majority of the car rental operators that participated in the market
investigation submit that brokers have a significant negotiating power vis-Ã -vis
car rental operators.
60
Indeed, both car rental operators and brokers note that
brokers distributing significant volumes have a correspondingly high influence on
the car rental market. Since an important volume of the car rental reservations is
distributed through brokers (particularly for leisure customers), they can use their
position in the market to negotiate lower prices and more advantageous
conditions.
61
(70) With regard to the effects of the Transaction over the brokers' negotiating power,
none of the car rental companies nor brokers that participated in the market
investigation consider that the Transaction will decrease the negotiating power
that brokers exert vis-Ã -vis the entity combining Europcar and Goldcar, or more
generally vis-Ã -vis car rental companies.
62
(71) As a result, even if brokers differ from car rental operators for not having a
physical presence or a fleet of vehicles in the locations where they offer their
services, brokers control a large share of the on-line distribution channel
(particularly for leisure customers) and decide or influence the price paid by end
customers. In addition, resellers possess a strong countervailing power over car
rental operators.
(72) Brokers therefore exercise a significant competitive constrain over car rental
companies and are likely to continue exerting competitive pressure over the
merged entity after the Transaction.
4.1.4. Barriers to entry or expansion
General
(73) Europcar submits that barriers to enter (or expand within) the car rental markets
are low.
63
(74) First, Europcar submits that brokers lower barriers to entry and expansion (at least
on the leisure segment) by (i) enabling new entrants to quickly get access to
customers, (ii) enabling regional or local operators with limited physical presence
to compete with national/multinational companies without incurring in significant
marketing costs, and (iii) committing to purchase certain fleet volumes allowing
car rental companies (especially local players) to manage their fleet exposure
risk.
64
60
Replies to Questionnaire 1 to market participants, question 25.
61
Replies to Questionnaire 1 to market participants, question 25.1.
62
Replies to Questionnaire 1 to market participants, question 26.
63
Form CO, paragraph 17.
64
Form CO, paragraph 15.
14
(75) Second, Europcar submits that the constitution of a sizable fleet of vehicles is
manageable from a financial perspective due to leasing or buy-back agreements.
65
(76) The results of the market investigation support the influence of brokers over the
barriers to enter the market. The majority of car rental operators and brokers that
participated in the market investigation notably submit that brokers increase the
competitive pressure exerted by local or regional car rental companies over
national or international car rental companies.
66
(77) In this respect, one competitor to the Parties noted that "brokers increase the
competitive pressure exerted by local/regional car rental companies on
national/international companies as they display these companies on their
websites alongside the national/ international companies leading to increased
competition on pricing". The same competitor added that "[i]n Southern Europe
in particular this is even more the case as the brokers are the main distribution
channel for the locals and have high market share of this business".
67
(78) Along the same line, another respondent submitted that "[b]rokers provide a way
for customers (particularly from foreign countries where local and regional car
hire brands may not be well known) to find local and regional companies,
understand their product and prices and book them in a safe and reliable
environment. This lowers barriers to entry or to compete for such companies,
increasing competitive pressure".
68
(79) With regard to the difficulty to constitute a sizable fleet of vehicles, respondents
to the market investigation do not fully concur with Europcar's arguments. The
main barrier to enter the market for car rental services would be the financial
investment required to acquire a proper vehicle fleet.
69
(80) However, the Commission notes that, as far as the leisure segment is concerned,
new entrants would not be confronted to the barrier to entry constituted by brand
loyalty. Indeed, according to Europcar, transactions on the leisure segment are
[…].
70
(81) As regards the effects of the Transaction on the barriers to enter or expand in the
provision of car rental services to leisure customers, the market investigation
yielded mixed results. The Parties' competitors submitted that the effects of the
Transaction over the barriers to entry will mostly depend on the strategy of the
merged entity to consolidate its operations. One competitor noted that any cost
65
Form CO, paragraph 17. Buy-back agreements include a commitment by the car manufacturer to buy-
back the vehicles at a pre-agreed repurchase price; as opposed to the purchase of vehicles "at risk", by
which car rental operators purchase cars to manufacturers without a buy-back commitment.
66
Replies to Questionnaire 1 to market participants, question 16.
67
Replies to Questionnaire 1 to market participants, question 16.1.
68
Replies to Questionnaire 1 to market participants, question 16.1.
69
Replies to Questionnaire 1 to market participants, question 19.
70
For instance, less than […]% of Europcar's leisure customers in Spain in 2016 were also customers in
the previous year – Competitive assessment submitted by the Parties to the Commission on 16
November 2016.
15
saving in the management of the merged entity's fleet might translate in a drop of
the price paid by customers.
71
Specific barriers to entry or expansion at airports
(82) In order to offer their services within the airport terminal (on-airport), car rental
companies need to enter into a concession agreement with the airport manager.
Airport managers generally launch competitive tender procedures for the
commercial exploitation of car rental services within their premises, and grant
licenses or concessions to the car rental operators fulfilling some minimum
requirements and offering the most economically advantageous conditions to the
airport manager. Once the airport operator grants a licence to a car rental
operator, and according to the terms of the concession agreement, on-airport
operators have to pay the airport manager (i) a fixed amount to the airport
manager for the commercial exploitation of a retail space or counter and a parking
area, plus (ii) a variable amount for a value that depends on the turnover
generated from the car rental activities.
(83) Europcar submits that car rental companies can operate at an airport without
holding a concession, from counters and parking slots located outside the airport
facilities, or alternatively they can make use of additional rear parking space at a
short distance from the airport main parking spaces.
72
(84) Respondents to the market investigation indicate that barriers start offering car
rental services on-airport are higher than at other locations, since airport managers
generally grant licenses to operate on-airport through competitive public tenders
that might take place every few years.
73
In addition, once a car rental operator
enters into a licence agreement with an airport manager, it has to commit to pay
the operational fees agreed upon, including any fixed remuneration.
(85) With regard to the time it actually takes to enter into operations in an airport, the
Parties' competitors note some differences between the different countries where
the Parties overlap, most notably related to the tender procedure and criteria
followed by the airport managers. Nevertheless, the majority of the competitors
that participated in the market investigation state that the time between the
business decision to enter an airport and the moment they would be available to
offer car rental services to leisure customers would take between a few days and
one year on average.
74
(86) The market investigation further confirms that, in the case of car rental stations
located off-airport or downtown, there is no such burden to obtain a license and
pay operational fees to the airport manager, and therefore the barriers to enter car
rental operations are lower.
71
Replies to Questionnaire to market participants, question 19.1.
72
Form CO, paragraph 17.
73
Replies to Questionnaire 1 to market participants, question 19. A detailed description of on-airport and
off-airport operation is included in section 3.1.5.
74
Replies to Questionnaire 1 to market participants, question 22.
16
(87) Moreover, over the last two years, a number of new suppliers have entered into
operations at some of the airports where the two Parties offer their car rental
services. New entrants operate either on-airport through an agreement with the
airport managers, or off-airport from counters located in the vicinity of the
airport's terminal.
(88) With regard to the possibility for existing car rental operators to expand their
activities on-airport by using rear parking space located outside the airport
premises, the market investigation did not produce conclusive results, since it
mostly depends on the availability of land in the vicinity of a given airport.
75
The specific case of on-airport car rental services in Spain
(89) In Spain, where Goldcar is mostly active,
76
all airports in which the Parties
overlap are managed by AENA, S.A., which recently organised a competitive
public tender procedure and granted new lease contracts to operate car rental
services in its airports as from October 2016 for the period 2016-2022.
77
(90) However, AENA submits that there remains available car rental space in all the
airports where the Parties' activities overlap, except in Tenerife South.
78
Therefore, any extra demand to operate on-airport car rental services may still be
granted to a new operator through a complementary tender, as long as the new
entrant accepts to pay the maximum fee paid by the operators currently present at
a given airport (i.e. the new entrant must align its offer with the highest bid
received during the 2016 tender).
(91) For instance, at Girona and Jerez airports, Goldcar resumed operations in June
2017, after having exited in October 2016 for not having bid for operating in
these airports.
79
Conclusion
(92) Overall, given that brokers increase the competitive pressure exerted by local and
regional car rental companies, the fact that the main barrier to enter the market is
the constitution of a sizable fleet of vehicles, the limited period of time it takes to
enter into car rental operations, and the large availability of commercial space at
most overlapping airports (either on-airport or off-airport), low barriers to entry
and expansion would be present within the market for the provision of car rental
services.
75
Replies to Questionnaire 1 to market participants, question 23.
76
Goldcar generated more than […] of its 2016 total turnover in Spain – Form CO, Table 4.
77
The lease contracts granted by AENA for the period 2016-2022 can be renewed for two additional
periods of 2 years – See agreed non-confidential minutes with AENA of 17 October 2017, paragraphs
3 and 4.
78
See agreed non-confidential minutes with AENA of 17 October 2017, paragraph 12.
79
See agreed non-confidential minutes with AENA of 17 October 2017, paragraph 12.
17
4.2. Overview of the Parties' market shares
4.2.1. Methodology for estimating market shares at local and national levels
(93) Europcar has provided an estimate of their competitors' market shares at local
level based on an approximation of the number of cars and of the revenue
generated per car by each of their competitors at their rental stations. Given the
reduced visibility of the Parties over their competitors' complete fleet and revenue
at local level, however, the methodology used by Europcar to estimate local
market shares does not appear to be fully reliable.
(94) The Commission has therefore undertaken a market reconstruction exercise to
obtain a more precise overview of the competitive landscape at local level. Within
the frame of the market investigation, the Commission has asked the Parties and
their competitors for the revenues generated during 2016 from short-term car
rental services at all the stations located where the Parties' activities overlap.
80
(95) In addition, airport managers have also provided the revenue reported by the car
rental companies operating on-airport within their premises, which has allowed
the Commission to verify and complement where necessary the data reported by
car rental operators.
(96) Since the Commission could not gather turnover data from the entirety of the
competitors present at each location (particularly from small local or regional
players offering car rental services off-airport or downtown), the market
reconstruction exercise provides a reliable, yet conservative value of the Parties'
combined shares at local level, both at the airports (including off-airport
locations) and at the downtown locations where their activities overlap.
(97) At national level, the market shares reported by Europcar in the Form CO are
more reliable for being based on its competitors' audited annual accounts, data
from national car rental industry associations and publicly available information
(such as press releases or communications to shareholders).
4.2.2. Overlapping markets
(98) The Parties' combined market shares in all of the overlapping markets are listed in
Table 1 below. These market shares have been computed by the Commission on
the basis of confidential turnover data provided by the Parties' competitors and
airport managers under the condition that only the Parties' combined market
shares would be displayed in ranges of 25%.
81
80
In order to ensure the coherence of the data computed, the Commission has collected net turnover data,
– i.e. total sales after deduction of VAT.
81
Considering that the turnover of competitors, hence the total market size, are confidential vis-Ã -vis the
Parties, the use of ranges for the Parties' combined market shares is necessary to respect the
confidentiality claims of participants to the market reconstruction exercise.
18
Table 1: Overlapping markets by type of services and location (2016)
82
Overlapping market
Combined market share (%)
Short-term car rental
services
Short-term leisure car
rental services
France (national)
< 20%
< 20%
Bordeaux airport
[25-50]%
[25-50]%
Marseille airport
[25-50]%
[25-50]%
Nice airport
[25-50]%
[25-50]%
Toulouse airport
[25-50]%
[25-50]%
Italy (national)
[20-30]%
< 20%
Bari airport
[0-25]%
[25-50]%
Bergamo airport
[0-25]%
[25-50]%
Bologna airport
[25-50]%
[25-50]%
Brindisi airport
[0-25]%
[25-50]%
Cagliari airport
[25-50]%
[25-50]%
Catania airport
[25-50]%
[25-50]%
Florence airport
[0-25]%
[0-25]%
Lamezia Terme airport
[0-25]%
[25-50]%
Milan Linate airport
[0-25]%
[0-25]%
Milan Malpensa airport
[0-25]%
[25-50]%
Olbia airport
[25-50]%
[25-50]%
Palermo airport
[0-25]%
[25-50]%
Pisa airport
[25-50]%
[25-50]%
Rome Ciampino airport
[0-25]%
[25-50]%
Rome Fiumicino airport
[0-25]%
[25-50]%
Trapani airport
[0-25]%
[0-25]%
Treviso airport
[0-25]%
[25-50]%
Venice airport
[0-25]%
[0-25]%
Verona airport
[0-25]%
[25-50]%
Portugal (national)
[20-30]%
[20-30]%
Faro airport
[25-50]%
[25-50]%
Lisbon airport
[25-50]%
[25-50]%
Madeira airport
[25-50]%
[25-50]%
Ponta Delgada airport
[0-25]%
[0-25]%
Porto airport
[25-50]%
[25-50]%
Spain (national)
[20-30]%
[20-30]%
Alicante airport
[25-50]%
[25-50]%
Alicante downtown
[25-50]%
[25-50]%
82
The value of the national market shares was provided by Europcar in the Form CO. The value of the
local market shares was computed by the Commission on the basis of the turnover data gathered in the
frame of the market investigation. The same applies to all the tables in section 4.3 below.
19
Almeria airport
[50-75]%
[75-100]%
Asturias airport
[25-50]%
[25-50]%
Barcelona airport
[25-50]%
[25-50]%
Barcelona downtown
[0-25]%
[0-25]%
Benidorm downtown
[0-25]%
[0-25]%
Bilbao airport
[25-50]%
[25-50]%
Fuerteventura airport
[0-25]%
[0-25]%
Girona airport
[50-75]%
[50-75]%
Gran Canaria airport
[25-50]%
[25-50]%
Granada airport
[25-50]%
[50-75]%
Ibiza airport
[25-50]%
[25-50]%
Jerez airport
[25-50]%
[25-50]%
La Linea downtown
[25-50]%
[25-50]%
Lanzarote airport
[0-25]%
[0-25]%
Madrid airport
[25-50]%
[25-50]%
Madrid downtown
[0-25]%
[0-25]%
Malaga airport
[25-50]%
[25-50]%
Malaga downtown
[25-50]%
[25-50]%
Mallorca downtown
[0-25]%
[0-25]%
Menorca airport
[25-50]%
[0-25]%
Murcia airport
[25-50]%
[25-50]%
Palma de Mallorca airport
[25-50]%
[25-50]%
Reus airport
[50-75]%
[50-75]%
Sancti Petri downtown
[50-75]%
[50-75]%
Santander airport
[25-50]%
[25-50]%
Santiago airport
[25-50]%
[25-50]%
Seville airport
[25-50]%
[25-50]%
Seville downtown
[25-50]%
[25-50]%
Tenerife North airport
[25-50]%
[0-25]%
Tenerife South airport
[25-50]%
[25-50]%
Valencia airport
[25-50]%
[25-50]%
Valencia downtown
[0-25]%
[0-25]%
(99) A detailed competitive assessment market is provided in the market-specific
section below.
(100) The Commission will assess each market according to the Parties' combined
market share range in the table above, considering that, according to the
Horizontal Merger Guidelines, concentrations where the market share of the
20
undertakings concerned does not exceed 25% are not liable to impede effective
competition.
83
4.3. Market-specific analysis
4.3.1. France
4.3.1.1. At national level
Table 2 - Overlaps in France
Overlapping market
Combined market share (%)
Short-term car rental
services
Short-term leisure car
rental services
France
< 20%
< 20%
(101) The Transaction does not give rise to an affected market in France, since the
Parties' combined market shares would remain below 20% at national level.
(102) Therefore, the Commission considers that the Transaction does not raise serious
doubts as concerns the market for short-term car rental services in France, under
any plausible segmentation.
4.3.1.2. Bordeaux airport
Table 3 - Overlaps at Bordeaux airport
Overlapping market
Combined market share (%)
Short-term car rental
services
Short-term leisure car
rental services
Bordeaux Airport
[25-50]%
[25-50]%
(103) The market share of the merged entity on the market for short-term car rental
services would reach [25-50]%. On a plausible narrower market for short-term
leisure car rental services, the combined market share of the merged entity would
be [25-50]%.
(104) Significant competitors such as Avis, Hertz or Sixt are active in the market for
short-term car rental services and short-term leisure car rental services at
Bordeaux airport.
84
(105) Moreover no respondent to the market investigation raised any material concern
as to the effect of the Transaction at Bordeaux airport.
85
83
Horizontal Merger Guidelines, paragraph 18.
84
Form CO, Annex 27; and replies to Questionnaire 1 to market participants, question 4.2.
85
Replies to Questionnaire 1 to market participants, question 29.2; replies to Questionnaire 2 to airport
managers, questions 15 and 18; and replies to Questionnaire 3 to customer associations, question 18.
21
(106) Overall, given the market shares of the Parties, the presence of significant
competitors and the fact that no material concern was expressed during the market
investigation, the Commission considers that the Transaction is unlikely to lead to
any significant competition concerns for the market for short-term car rental
services at Bordeaux airport, under any plausible segmentation.
Conclusion
(107) In view of the above, and considering all evidence available to the Commission,
the Transaction does not raise serious doubts as concerns the market for short-
term car rental services at Bordeaux airport, under any plausible segmentation.
4.3.1.3. Marseille airport
Table 4 - Overlaps at Marseille airport
Overlapping market
Combined market share (%)
Short-term car rental
services
Short-term leisure car
rental services
Marseille Airport
[25-50]%
[25-50]%
(108) The market share of the merged entity on the market for short-term car rental
services would reach [25-50]%. On a plausible narrower market for short-term
leisure car rental services, the combined market share of the merged entity would
be [25-50]%.
(109) Significant competitors such as Avis, Hertz or Sixt are active in the market for
short-term car rental services and short-term leisure car rental services at
Marseille airport.
86
(110) Moreover no respondent to the market investigation raised any material concern
as to the effect of the Transaction at Marseille airport.
87
(111) Overall, given the market shares of the Parties, the presence of significant
competitors and the fact that no material concern was expressed during the market
investigation, the Commission considers that the Transaction is unlikely to lead to
any significant competition concerns for the market for short-term car rental
services at Marseille airport, under any plausible segmentation.
Conclusion
(112) In view of the above, and considering all evidence available to the Commission,
the Transaction does not raise serious doubts as concerns the market for short-
term car rental services at Marseille airport, under any plausible segmentation.
86
Form CO, Annex 27; replies to Questionnaire 1 to market participants, question 4.2.
87
Replies to Questionnaire 1 to market participants, question 29.2; replies to Questionnaire 2 to airport
managers, questions 15 and 18; and replies to Questionnaire 3 to customer associations, question 18.
22
4.3.1.4. Nice airport
Table 5 - Overlaps at Nice airport
Overlapping market
Combined market share (%)
Short-term car rental
services
Short-term leisure car
rental services
Nice Airport
[25-50]%
[25-50]%
(113) The market share of the merged entity on the market for short-term car rental
services would reach [25-50]%. On a plausible narrower market for short-term
leisure car rental services, the combined market share of the merged entity would
be [25-50]%.
(114) Significant competitors such as Avis, Hertz or Sixt are active in the market for
short-term car rental services and short-term leisure car rental services at Nice
airport.
88
(115) Moreover no respondent to the market investigation raised any material concern
as to the effect of the Transaction at Nice airport.
89
(116) Overall, given the market shares of the Parties, the presence of significant
competitors and the fact that no material concern was expressed during the market
investigation, the Commission considers that the Transaction is unlikely to lead to
any significant competition concerns for the market for short-term car rental
services at Nice airport, under any plausible segmentation.
Conclusion
(117) In view of the above, and considering all evidence available to the Commission,
the Transaction does not raise serious doubts as concerns the market for short-
term car rental services at Nice airport, under any plausible segmentation.
4.3.1.5. Toulouse airport
Table 6 - Overlaps at Toulouse airport
Overlapping market
Combined market share (%)
Short-term car rental
services
Short-term leisure car
rental services
Toulouse Airport
[25-50]%
[25-50]%
(118) The market share of the merged entity on the market for short-term car rental
services would reach [25-50]%. On a plausible narrower market for short-term
leisure car rental services, the combined market share of the merged entity would
be [25-50]%.
88
Form CO, Annex 27; replies to Questionnaire 1 to market participants, question 4.2.
89
Replies to Questionnaire 1 to market participants, question 29.2; replies to Questionnaire 2 to airport
managers, questions 15 and 18; and replies to Questionnaire 3 to customer associations, question 18.
23
(119) Significant competitors such as Avis, Hertz or Sixt are active in the market for
short-term car rental services and short-term leisure car rental services at
Toulouse airport.
90
(120) Moreover no respondent to the market investigation raised any material concern
as to the effect of the Transaction at Toulouse airport.
91
(121) Overall, given the market shares of the Parties, the presence of significant
competitors and the fact that no material concern was expressed during the market
investigation, the Commission considers that the Transaction is unlikely to lead to
any significant competition concerns for the market for short-term car rental
services at Toulouse airport, under any plausible segmentation.
Conclusion
(122) In view of the above, and considering all evidence available to the Commission,
the Transaction does not raise serious doubts as concerns the market for short-
term car rental services at Toulouse airport, under any plausible segmentation.
4.3.2. Italy
4.3.2.1. At national level
Table 7 - Overlaps in Italy
Overlapping market
Combined market share (%)
Short-term car rental
services
Short-term leisure car
rental services
Italy
[20-30]%
< 20%
(123) The market shares of the merged entity on the market for short-term car rental
services would remain limited at [20-30]%. The plausible narrower market for
short-term leisure car rental services would not be affected.
(124) Significant competitors such as Avis, Hertz, Locauto or Sicily by Car are active in
the market for short-term car rental services at national level in Italy.
92
(125) In addition, a majority of the respondents to the market investigation submitted
that there will be sufficient competition post-transaction in Italy to prevent the
merged entity from raising prices.
93
(126) Moreover no respondent to the market investigation raised any material concern
as to the effect of the Transaction in Italy.
94
90
Form CO, Annex 27; replies to Questionnaire 1 to market participants, question 4.3.
91
Replies to Questionnaires to market participants, question 29.2; replies to Questionnaire 2 to airport
managers, questions 15 and 18; and replies to Questionnaire 3 to customer associations, question 18.
92
Form CO, Annex 27; and replies to Questionnaire 1 to market participants, question 4.5 and/or to a
Request for Information by the Commission.
93
Replies to Questionnaire 1 to market participants, question 28; replies to Questionnaire 2 to airport
managers, question 16; and replies to Questionnaire 3 to customer associations, question 16.
24
(127) Overall, given the limited market shares of the Parties, the presence of significant
competitors, the fact that the Parties' competitors expect sufficient competition to
prevent the merged entity from raising prices, and the fact that no material
concern was expressed during the market investigation, the Commission
considers that the Transaction is unlikely to lead to any significant competition
concerns for the market for short-term car rental services in Italy, under any
plausible segmentation.
Conclusion
(128) In view of the above, and considering all evidence available to the Commission,
the Transaction does not raise serious doubts as concerns the market for short-
term car rental services in Italy, under any plausible segmentation.
4.3.2.2. Bari airport
Table 8 - Overlaps at Bari airport
Overlapping market
Combined market share (%)
Short-term car rental
services
Short-term leisure car
rental services
Bari airport
[0-25]%
[25-50]%
(129) The market share of the merged entity on the market for short-term car rental
services would reach [0-25]%. On a plausible narrower market for short-term
leisure car rental services, the combined market share of the merged entity would
be [25-50]%.
(130) Significant competitors such as Avis, Hertz or Sicily by Car are active in the
market for short-term car rental services and short-term leisure car rental services
at Bari airport.
95
(131) In addition, a majority of the respondents to the market investigation submitted
that there will be sufficient competition post-transaction at Bari airport to prevent
the merged entity from raising prices.
96
(132) Moreover no respondent to the market investigation raised any material concern
as to the effect of the Transaction at Bari airport.
97
(133) Overall, given the market shares of the Parties, the presence of significant
competitors, the fact that the Parties' competitors expect sufficient competition to
prevent the merged entity from raising prices, and the fact that no material
94
Replies to Questionnaire 1 to market participants, question 29.2; replies to Questionnaire 2 to airport
managers, questions 15 and 18; and replies to Questionnaire 3 to customer associations, question 18.
95
Form CO, Annex 27; replies to Questionnaire 1 to market participants, question 4.3.
96
Replies to Questionnaire 1 to market participants, question 28; replies to Questionnaire 2 to airport
managers, question 16; and replies to Questionnaire 3 to customer associations, question 16.
97
Replies to Questionnaire 1 to market participants, question 29; replies to Questionnaire 2 to airport
managers, questions 15 and 17; and replies to Questionnaire 3 to customer associations, question 17.
25
concern was expressed during the market investigation, the Commission
considers that the Transaction is unlikely to lead to any significant competition
concerns for the market for short-term car rental services at Bari airport, under
any plausible segmentation.
Conclusion
(134) In view of the above, and considering all evidence available to the Commission,
the Transaction does not raise serious doubts as concerns the market for short-
term car rental services at Bari airport, under any plausible segmentation.
4.3.2.3. Bergamo airport
Table 9 - Overlaps at Bergamo airport
Overlapping market
Combined market share (%)
Short-term car rental
services
Short-term leisure car
rental services
Bergamo airport
[0-25]%
[25-50]%
(135) The market share of the merged entity on the market for short-term car rental
services would reach [0-25]%. On a plausible narrower market for short-term
leisure car rental services, the combined market share of the merged entity would
be [25-50]%.
(136) Significant competitors such as Avis, Hertz or Sicily by Car are active in the
market for short-term car rental services and short-term leisure car rental services
at Bergamo airport.
98
(137) Moreover no respondent to the market investigation raised any material concern
as to the effect of the Transaction at Bergamo airport.
99
(138) Overall, given the market shares of the Parties, the presence of significant
competitors and the fact that no material concern was expressed during the market
investigation, the Commission considers that the Transaction is unlikely to lead to
any significant competition concerns for the market for short-term car rental
services at Bergamo airport, under any plausible segmentation.
Conclusion
(139) In view of the above, and considering all evidence available to the Commission,
the Transaction does not raise serious doubts as concerns the market for short-
term car rental services at Bergamo airport, under any plausible segmentation.
98
Form CO, Annex 27; replies to Questionnaire 1 to market participants, question 4.3.
99
Replies to Questionnaire 1 to market participants, question 29.2; replies to Questionnaire 2 to airport
managers, questions 15 and 18; and replies to Questionnaire 3 to customer associations, question 18.
26
4.3.2.4. Bologna airport
Table 10 - Overlaps at Bologna airport
Overlapping market
Combined market share (%)
Short-term car rental
services
Short-term leisure car
rental services
Bologna airport
[25-50]%
[25-50]%
(140) The market share of the merged entity on the market for short-term car rental
services would reach [25-50]%. On a plausible narrower market for short-term
leisure car rental services, the combined market share of the merged entity would
be [25-50]%.
(141) Significant competitors such as Avis, Hertz, Locauto, Sicily by Car or WinRent
are active in the market for short-term car rental services and short-term leisure
car rental services at Bologna airport.
100
(142) Moreover no respondent to the market investigation raised any material concern
as to the effect of the Transaction at Bologna airport.
101
(143) Overall, given the market shares of the Parties, the presence of significant
competitors and the fact that no material concern was expressed during the market
investigation, the Commission considers that the Transaction is unlikely to lead to
any significant competition concerns for the market for short-term car rental
services at Bologna airport, under any plausible segmentation.
Conclusion
(144) In view of the above, and considering all evidence available to the Commission,
the Transaction does not raise serious doubts as concerns the market for short-
term car rental services at Bologna airport, under any plausible segmentation.
4.3.2.5. Brindisi airport
Table 11 - Overlaps at Brindisi airport
Overlapping market
Combined market share (%)
Short-term car rental
services
Short-term leisure car
rental services
Brindisi airport
[0-25]%
[25-50]%
(145) The market share of the merged entity on the market for short-term car rental
services would reach [0-25]%. On a plausible narrower market for short-term
100
Form CO, Annex 27; replies to Questionnaire 1 to market participants, question 4.3.
101
Replies to Questionnaire 1 to market participants, question 29.2; replies to Questionnaire 2 to airport
managers, questions 15 and 18; and replies to Questionnaire 3 to customer associations, question 18.
27
leisure car rental services, the combined market share of the merged entity would
be [25-50]%.
(146) Significant competitors such as Avis, Hertz, Locauto or Sicily by Car are active in
the market for short-term car rental services and short-term leisure car rental
services at Brindisi airport.
102
(147) In addition, a majority of the respondents to the market investigation submitted
that there will be sufficient competition post-transaction at Brindisi airport to
prevent the merged entity from raising prices.
103
(148) Moreover no respondent to the market investigation raised any material concern
as to the effect of the Transaction at Brindisi airport.
104
(149) Overall, given the market shares of the Parties, the presence of significant
competitors, the fact that the Parties' competitors expect sufficient competition to
prevent the merged entity from raising prices, and the fact that no material
concern was expressed during the market investigation, the Commission
considers that the Transaction is unlikely to lead to any significant competition
concerns for the market for short-term car rental services at Brindisi airport, under
any plausible segmentation.
Conclusion
(150) In view of the above, and considering all evidence available to the Commission,
the Transaction does not raise serious doubts as concerns the market for short-
term car rental services at Brindisi airport, under any plausible segmentation.
4.3.2.6. Cagliari airport
Table 12 - Overlaps at Cagliari airport
Overlapping market
Combined market share (%)
Short-term car rental
services
Short-term leisure car
rental services
Cagliari airport
[25-50]%
[25-50]%
(151) The market share of the merged entity on the market for short-term car rental
services would reach [25-50]%. On a plausible narrower market for short-term
leisure car rental services, the combined market share of the merged entity would
be [25-50]%.
102
Form CO, Annex 27; replies to Questionnaire 1 to market participants, question 4.3.
103
Replies to Questionnaire 1 to market participants, question 28; replies to Questionnaire 2 to airport
managers, question 16; and replies to Questionnaire 3 to customer associations, question 16.
104
Replies to Questionnaire 1 to market participants, question 29; replies to Questionnaire 2 to airport
managers, questions 15 and 17; and replies to Questionnaire 3 to customer associations, question 17.
28
(152) Significant competitors such as Avis, Hertz, Locauto or Sicily by Car are active in
the market for short-term car rental services and short-term leisure car rental
services at Cagliari airport.
105
(153) Moreover no respondent to the market investigation raised any material concern
as to the effect of the Transaction at Cagliari airport.
106
(154) Overall, given the market shares of the Parties, the presence of significant
competitors and the fact that no material concern was expressed during the market
investigation, the Commission considers that the Transaction is unlikely to lead to
any significant competition concerns for the market for short-term car rental
services at Cagliari airport, under any plausible segmentation.
Conclusion
(155) In view of the above, and considering all evidence available to the Commission,
the Transaction does not raise serious doubts as concerns the market for short-
term car rental services at Cagliari airport, under any plausible segmentation.
4.3.2.7. Catania airport
Table 13 - Overlaps at Catania airport
Overlapping market
Combined market share (%)
Short-term car rental
services
Short-term leisure car
rental services
Catania airport
[25-50]%
[25-50]%
(156) The market share of the merged entity on the market for short-term car rental
services would reach [25-50]%. On a plausible narrower market for short-term
leisure car rental services, the combined market share of the merged entity would
be [25-50]%.
(157) Significant competitors such as Avis, Hertz, Locauto or Sicily by Car are active in
the market for short-term car rental services and short-term leisure car rental
services at Catania airport.
107
(158) In addition, a majority of the respondents to the market investigation submitted
that there will be sufficient competition post-transaction at Catania airport to
prevent the merged entity from raising prices.
108
(159) Moreover no respondent to the market investigation raised any material concern
as to the effect of the Transaction at Catania airport.
109
105
Form CO, Annex 27; replies to Questionnaire 1 to market participants, question 4.3.
106
Replies to Questionnaire 1 to market participants, question 29.2; replies to Questionnaire 2 to airport
managers, questions 15 and 18; and replies to Questionnaire 3 to customer associations, question 18.
107
Form CO, Annex 27; replies to Questionnaire 1 to market participants, question 4.3.
108
Replies to Questionnaire 1 to market participants, question 28; replies to Questionnaire 2 to airport
managers, question 16; and replies to Questionnaire 3 to customer associations, question 16.
29
(160) Overall, given the market shares of the Parties, the presence of significant
competitors, the fact that the Parties' competitors expect sufficient competition to
prevent the merged entity from raising prices, and the fact that no material
concern was expressed during the market investigation, the Commission
considers that the Transaction is unlikely to lead to any significant competition
concerns for the market for short-term car rental services at Catania airport, under
any plausible segmentation.
Conclusion
(161) In view of the above, and considering all evidence available to the Commission,
the Transaction does not raise serious doubts as concerns the market for short-
term car rental services at Catania airport, under any plausible segmentation.
4.3.2.8. Florence airport
Table 14 - Overlaps at Florence airport
Overlapping market
Combined market share (%)
Short-term car rental
services
Short-term leisure car
rental services
Florence airport
[0-25]%
[0-25]%
(162) The market share of the merged entity on the market for short-term car rental
services would reach [0-25]%. On a plausible narrower market for short-term
leisure car rental services, the combined market share of the merged entity would
be [0-25]%.
(163) Significant competitors such as Avis, Hertz, Locauto or WinRent are active in the
market for short-term car rental services and short-term leisure car rental services
at Florence airport.
110
(164) In addition, a majority of the respondents to the market investigation submitted
that there will be sufficient competition post-transaction at Florence airport to
prevent the merged entity from raising prices.
111
(165) Moreover no respondent to the market investigation raised any material concern
as to the effect of the Transaction at Florence airport.
112
(166) Overall, given the market shares of the Parties, the presence of significant
competitors, the fact that the Parties' competitors expect sufficient competition to
prevent the merged entity from raising prices, and the fact that no material
109
Replies to Questionnaire 1 to market participants, question 29; replies to Questionnaire 2 to airport
managers, questions 15 and 17; and replies to Questionnaire 3 to customer associations, question 17.
110
Form CO, Annex 27; replies to Questionnaire 1 to market participants, question 4.3.
111
Replies to Questionnaire 1 to market participants, question 28; replies to Questionnaire 2 to airport
managers, question 16; and replies to Questionnaire 3 to customer associations, question 16.
112
Replies to Questionnaire 1 to market participants, question 29; replies to Questionnaire 2 to airport
managers, questions 15 and 17; and replies to Questionnaire 3 to customer associations, question 17.
30
concern was expressed during the market investigation, the Commission
considers that the Transaction is unlikely to lead to any significant competition
concerns for the market for short-term car rental services at Florence airport,
under any plausible segmentation.
Conclusion
(167) In view of the above, and considering all evidence available to the Commission,
the Transaction does not raise serious doubts as concerns the market for short-
term car rental services at Florence airport, under any plausible segmentation.
4.3.2.9. Lamezia Terme airport
Table 15 - Overlaps at Lamezia Terme airport
Overlapping market
Combined market share (%)
Short-term car rental
services
Short-term leisure car
rental services
Lamezia Terme airport
[0-25]%
[25-50]%
(168) The market share of the merged entity on the market for short-term car rental
services would reach [0-25]%. On a plausible narrower market for short-term
leisure car rental services, the combined market share of the merged entity would
be [25-50]%.
(169) Significant competitors such as Avis, Hertz, Locauto, Sicily by Car or WinRent
are active in the market for short-term car rental services and short-term leisure
car rental services at Lamezia Terme airport.
113
(170) Moreover no respondent to the market investigation raised any material concern
as to the effect of the Transaction at Lamezia Terme airport.
114
(171) Overall, given the market shares of the Parties, the presence of significant
competitors, and the fact that no material concern was expressed during the
market investigation, the Commission considers that the Transaction is unlikely to
lead to any significant competition concerns for the market for short-term car
rental services at Lamezia Terme airport, under any plausible segmentation.
Conclusion
(172) In view of the above, and considering all evidence available to the Commission,
the Transaction does not raise serious doubts as concerns the market for short-
term car rental services at Lamezia Terme airport, under any plausible
segmentation.
113
Form CO, Annex 27; replies to Questionnaire 1 to market participants, question 4.3.
114
Replies to Questionnaire 1 to market participants, question 29.2; replies to Questionnaire 2 to airport
managers, questions 15 and 18; and replies to Questionnaire 3 to customer associations, question 18.
31
4.3.2.10. Milan Linate airport
Table 16 - Overlaps at Milan Linate airport
Overlapping market
Combined market share (%)
Short-term car rental
services
Short-term leisure car
rental services
Milan Linate airport
[0-25]%
[0-25]%
(173) The market share of the merged entity on the market for short-term car rental
services would reach [0-25]%. On a plausible narrower market for short-term
leisure car rental services, the combined market share of the merged entity would
be [0-25]%.
(174) Significant competitors such as Avis, Hertz, Locauto or Sicily by Car are active in
the market for short-term car rental services and short-term leisure car rental
services at Milan Linate airport.
115
(175) Moreover no respondent to the market investigation raised any material concern
as to the effect of the Transaction at Milan Linate airport.
116
(176) Overall, given the market shares of the Parties, the presence of significant
competitors and the fact that no material concern was expressed during the market
investigation, the Commission considers that the Transaction is unlikely to lead to
any significant competition concerns for the market for short-term car rental
services at Milan Linate airport, under any plausible segmentation.
Conclusion
(177) In view of the above, and considering all evidence available to the Commission,
the Transaction does not raise serious doubts as concerns the market for short-
term car rental services at Milan Linate airport, under any plausible segmentation.
4.3.2.11. Milan Malpensa airport
Table 17 - Overlaps at Milan Malpensa airport
Overlapping market
Combined market share (%)
Short-term car rental
services
Short-term leisure car
rental services
Milan Malpensa airport
[0-25]%
[25-50]%
(178) The market share of the merged entity on the market for short-term car rental
services would reach [0-25]%. On a plausible narrower market for short-term
115
Form CO, Annex 27; replies to Questionnaire 1 to market participants, question 4.3.
116
Replies to Questionnaire 1 to market participants, question 29.2; replies to Questionnaire 2 to airport
managers, questions 15 and 18; and replies to Questionnaire 3 to customer associations, question 18.
32
leisure car rental services, the combined market share of the merged entity would
be [25-50]%.
(179) Significant competitors such as Avis, Hertz, Locauto or WinRent are active in the
market for short-term car rental services and short-term leisure car rental services
at Milan Malpensa airport.
117
(180) Moreover no respondent to the market investigation raised any material concern
as to the effect of the Transaction at Milan Malpensa airport.
118
(181) Overall, given the market shares of the Parties, the presence of significant
competitors and the fact that no material concern was expressed during the market
investigation, the Commission considers that the Transaction is unlikely to lead to
any significant competition concerns for the market for short-term car rental
services at Milan Malpensa airport, under any plausible segmentation.
Conclusion
(182) In view of the above, and considering all evidence available to the Commission,
the Transaction does not raise serious doubts as concerns the market for short-
term car rental services at Milan Malpensa airport, under any plausible
segmentation.
4.3.2.12. Olbia airport
Table 18 - Overlaps at Olbia airport
Overlapping market
Combined market share (%)
Short-term car rental
services
Short-term leisure car
rental services
Olbia airport
[25-50]%
[25-50]%
(183) The market share of the merged entity on the market for short-term car rental
services would reach [25-50]%. On a plausible narrower market for short-term
leisure car rental services, the combined market share of the merged entity would
be [25-50]%.
(184) Significant competitors such as Avis, Hertz, Locauto or Sicily by Car are active in
the market for short-term car rental services and short-term leisure car rental
services at Olbia airport.
119
(185) In addition, a majority of the respondents to the market investigation submitted
that there will be sufficient competition post-transaction at Olbia airport to
prevent the merged entity from raising prices.
120
117
Form CO, Annex 27; replies to Questionnaire 1 to market participants, question 4.3.
118
Replies to Questionnaire 1 to market participants, question 29.2; replies to Questionnaire 2 to airport
managers, questions 15 and 18; and replies to Questionnaire 3 to customer associations, question 18.
119
Form CO, Annex 27; replies to Questionnaire 1 to market participants, question 4.3
33
(186) Moreover no respondent to the market investigation raised any material concern
as to the effect of the Transaction at Olbia airport.
121
(187) Overall, given the market shares of the Parties, the presence of significant
competitors, the fact that the Parties' competitors expect sufficient competition to
prevent the merged entity from raising prices, and the fact that no material
concern was expressed during the market investigation, the Commission
considers that the Transaction is unlikely to lead to any significant competition
concerns for the market for short-term car rental services at Olbia airport, under
any plausible segmentation.
Conclusion
(188) In view of the above, and considering all evidence available to the Commission,
the Transaction does not raise serious doubts as concerns the market for short-
term car rental services at Olbia airport, under any plausible segmentation.
4.3.2.13. Palermo airport
Table 19 - Overlaps at Palermo airport
Overlapping market
Combined market share (%)
Short-term car rental
services
Short-term leisure car
rental services
Palermo airport
[0-25]%
[25-50]%
(189) The market share of the merged entity on the market for short-term car rental
services would reach [0-25]%. On a plausible narrower market for short-term
leisure car rental services, the combined market share of the merged entity would
be [25-50]%.
(190) Significant competitors such as Avis, Hertz, or Sicily by Car are active in the
market for short-term car rental services and short-term leisure car rental services
at Palermo airport.
122
(191) Moreover no respondent to the market investigation raised any material concern
as to the effect of the Transaction at Palermo airport.
123
(192) Overall, given the market shares of the Parties, the presence of significant
competitors and the fact that no material concern was expressed during the market
investigation, the Commission considers that the Transaction is unlikely to lead to
120
Replies to Questionnaire 1 to market participants, question 28; replies to Questionnaire 2 to airport
managers, question 16; and replies to Questionnaire 3 to customer associations, question 16.
121
Replies to Questionnaire 1 to market participants, question 29; replies to Questionnaire 2 to airport
managers, questions 15 and 17; and replies to Questionnaire 3 to customer associations, question 17.
122
Form CO, Annex 27; replies to Questionnaire 1 to market participants, question 4.3
123
Replies to Questionnaire 1 to market participants, question 29.2; replies to Questionnaire 2 to airport
managers, questions 15 and 18; and replies to Questionnaire 3 to customer associations, question 18.
34
any significant competition concerns for the market for short-term car rental
services at Palermo airport, under any plausible segmentation.
Conclusion
(193) In view of the above, and considering all evidence available to the Commission,
the Transaction does not raise serious doubts as concerns the market for short-
term car rental services at Palermo airport, under any plausible segmentation.
4.3.2.14. Pisa airport
Table 20 - Overlaps at Pisa airport
Overlapping market
Combined market share (%)
Short-term car rental
services
Short-term leisure car
rental services
Pisa airport
[25-50]%
[25-50]%
(194) The market share of the merged entity on the market for short-term car rental
services would reach [25-50]%. On a plausible narrower market for short-term
leisure car rental services, the combined market share of the merged entity would
be [25-50]%.
(195) Significant competitors such as Avis, Hertz, Locauto or Sicily by Car are active in
the market for short-term car rental services and short-term leisure car rental
services at Pisa airport.
124
(196) In addition, a majority of the respondents to the market investigation submitted
that there will be sufficient competition post-transaction at Pisa airport to prevent
the merged entity from raising prices.
125
(197) Moreover no respondent to the market investigation raised any material concern
as to the effect of the Transaction at Pisa airport.
126
(198) Overall, given the market shares of the Parties, the presence of significant
competitors, the fact that the Parties' competitors expect sufficient competition to
prevent the merged entity from raising prices, and the fact that no material
concern was expressed during the market investigation, the Commission
considers that the Transaction is unlikely to lead to any significant competition
concerns for the market for short-term car rental services at Pisa airport, under
any plausible segmentation.
124
Form CO, Annex 27; replies to Questionnaire 1 to market participants, question 4.3.
125
Replies to Questionnaire 1 to market participants, question 28; replies to Questionnaire 2 to airport
managers, question 16; and replies to Questionnaire 3 to customer associations, question 16.
126
Replies to Questionnaire 1 to market participants, question 29; replies to Questionnaire 2 to airport
managers, questions 15 and 17; and replies to Questionnaire 3 to customer associations, question 17.
35
Conclusion
(199) In view of the above, and considering all evidence available to the Commission,
the Transaction does not raise serious doubts as concerns the market for short-
term car rental services at Pisa airport, under any plausible segmentation.
4.3.2.15. Rome Ciampino airport
Table 21 - Overlaps at Rome Ciampino airport
Overlapping market
Combined market share (%)
Short-term car rental
services
Short-term leisure car
rental services
Rome Ciampino airport
[0-25]%
[25-50]%
(200) The market share of the merged entity on the market for short-term car rental
services would reach [0-25]%. On a plausible narrower market for short-term
leisure car rental services, the combined market share of the merged entity would
be [25-50]%.
(201) Significant competitors such as Avis, Hertz or Sicily by Car are active in the
market for short-term car rental services and short-term leisure car rental services
at Rome Ciampino airport.
127
(202) Moreover no respondent to the market investigation raised any material concern
as to the effect of the Transaction at Rome Ciampino airport.
128
(203) Overall, given the market shares of the Parties, the presence of significant
competitors and the fact that no material concern was expressed during the market
investigation, the Commission considers that the Transaction is unlikely to lead to
any significant competition concerns for the market for short-term car rental
services at Rome Ciampino airport, under any plausible segmentation.
Conclusion
(204) In view of the above, and considering all evidence available to the Commission,
the Transaction does not raise serious doubts as concerns the market for short-
term car rental services at Rome Ciampino airport, under any plausible
segmentation.
127
Form CO, Annex 27; replies to Questionnaire 1 to market participants, question 4.3.
128
Replies to Questionnaire 1 to market participants, question 29.2; replies to Questionnaire 2 to airport
managers, questions 15 and 18; and replies to Questionnaire 3 to customer associations, question 18.
36
4.3.2.16. Rome Fiumicino airport
Table 22 - Overlaps at Rome Fiumicino airport
Overlapping market
Combined market share (%)
Short-term car rental
services
Short-term leisure car
rental services
Rome Fiumicino airport
[0-25]%
[25-50]%
(205) The market share of the merged entity on the market for short-term car rental
services would reach [0-25]%. On a plausible narrower market for short-term
leisure car rental services, the combined market share of the merged entity would
be [25-50]%.
(206) Significant competitors such as Avis, Hertz or Locauto are active in the market
for short-term car rental services and short-term leisure car rental services at
Rome Fiumicino airport.
129
(207) Moreover no respondent to the market investigation raised any material concern
as to the effect of the Transaction at Rome Fiumicino airport.
130
(208) Overall, given the market shares of the Parties, the presence of significant
competitors and the fact that no material concern was expressed during the market
investigation, the Commission considers that the Transaction is unlikely to lead to
any significant competition concerns for the market for short-term car rental
services at Rome Fiumicino airport, under any plausible segmentation.
Conclusion
(209) In view of the above, and considering all evidence available to the Commission,
the Transaction does not raise serious doubts as concerns the market for short-
term car rental services at Rome Fiumicino airport, under any plausible
segmentation.
4.3.2.17. Trapani airport
Table 23 - Overlaps at Trapani airport
Overlapping market
Combined market share (%)
Short-term car rental
services
Short-term leisure car
rental services
Trapani airport
[0-25]%
[0-25]%
(210) The market share of the merged entity on the market for short-term car rental
services would reach [0-25]%. On a plausible narrower market for short-term
129
Form CO, Annex 27; replies to Questionnaire 1 to market participants, question 4.3.
130
Replies to Questionnaire 1 to market participants, question 29.2; replies to Questionnaire 2 to airport
managers, questions 15 and 18; and replies to Questionnaire 3 to customer associations, question 18.
37
leisure car rental services, the combined market share of the merged entity would
be [0-25]%.
(211) Significant competitors such as Avis, Hertz, Locauto or Sicily by Car are active in
the market for short-term car rental services and short-term leisure car rental
services at Trapani airport.
131
(212) Moreover no respondent to the market investigation raised any material concern
as to the effect of the Transaction at Trapani airport.
132
(213) Overall, given the market shares of the Parties, the presence of significant
competitors and the fact that no material concern was expressed during the market
investigation, the Commission considers that the Transaction is unlikely to lead to
any significant competition concerns for the market for short-term car rental
services at Trapani airport, under any plausible segmentation.
Conclusion
(214) In view of the above, and considering all evidence available to the Commission,
the Transaction does not raise serious doubts as concerns the market for short-
term car rental services at Trapani airport, under any plausible segmentation.
4.3.2.18. Treviso airport
Table 24 - Overlaps at Treviso airport
Overlapping market
Combined market share (%)
Short-term car rental
services
Short-term leisure car
rental services
Treviso airport
[0-25]%
[25-50]%
(215) The market share of the merged entity on the market for short-term car rental
services would reach [0-25]%. On a plausible narrower market for short-term
leisure car rental services, the combined market share of the merged entity would
be [25-50]%.
(216) Significant competitors such as Avis, Hertz, Locauto or Sicily by Car are active in
the market for short-term car rental services and short-term leisure car rental
services at Treviso airport.
133
(217) Moreover no respondent to the market investigation raised any material concern
as to the effect of the Transaction at Treviso airport.
134
131
Form CO, Annex 27; replies to Questionnaire 1 to market participants, question 4.3.
132
Replies to Questionnaire 1 to market participants, question 29.2; replies to Questionnaire 2 to airport
managers, questions 15 and 18; and replies to Questionnaire 3 to customer associations, question 18.
133
Form CO, Annex 27; replies to Questionnaire 1 to market participants, question 4.3.
134
Replies to Questionnaire 1 to market participants, question 29.2; replies to Questionnaire 2 to airport
managers, questions 15 and 18; and replies to Questionnaire 3 to customer associations, question 18.
38
(218) Overall, given the market shares of the Parties, the presence of significant
competitors and the fact that no material concern was expressed during the market
investigation, the Commission considers that the Transaction is unlikely to lead to
any significant competition concerns for the market for short-term car rental
services at Treviso airport, under any plausible segmentation.
Conclusion
(219) In view of the above, and considering all evidence available to the Commission,
the Transaction does not raise serious doubts as concerns the market for short-
term car rental services at Treviso airport, under any plausible segmentation.
4.3.2.19. Venice airport
Table 25 - Overlaps at Venice airport
Overlapping market
Combined market share (%)
Short-term car rental
services
Short-term leisure car
rental services
Venice airport
[0-25]%
[0-25]%
(220) The market share of the merged entity on the market for short-term car rental
services would reach [0-25]%. On a plausible narrower market for short-term
leisure car rental services, the combined market share of the merged entity would
be [0-25]%.
(221) Significant competitors such as Avis, Hertz or Locauto are active in the market
for short-term car rental services and short-term leisure car rental services at
Venice airport.
135
(222) Moreover no respondent to the market investigation raised any material concern
as to the effect of the Transaction at Venice airport.
136
(223) Overall, given the market shares of the Parties, the presence of significant
competitors and the fact that no material concern was expressed during the market
investigation, the Commission considers that the Transaction is unlikely to lead to
any significant competition concerns for the market for short-term car rental
services at Venice airport, under any plausible segmentation.
Conclusion
(224) In view of the above, and considering all evidence available to the Commission,
the Transaction does not raise serious doubts as concerns the market for short-
term car rental services at Venice airport, under any plausible segmentation.
135
Form CO, Annex 27; replies to Questionnaire 1 to market participants, question 4.3.
136
Replies to Questionnaire 1 to market participants, question 29.2replies to Questionnaire 2 to airport
managers, questions 15 and 18; and replies to Questionnaire 3 to customer associations, question 18.
39
4.3.2.20. Verona airport
Table 26 - Overlaps at Verona airport
Overlapping market
Combined market share (%)
Short-term car rental
services
Short-term leisure car
rental services
Verona airport
[0-25]%
[25-50]%
(225) The market share of the merged entity on the market for short-term car rental
services would reach [0-25]%. On a plausible narrower market for short-term
leisure car rental services, the combined market share of the merged entity would
be [25-50]%.
(226) Significant competitors such as Avis, Hertz, Locauto, or Sicily by Car are active
in the market for short-term car rental services and short-term leisure car rental
services at Verona airport.
137
(227) Moreover no respondent to the market investigation raised any material concern
as to the effect of the Transaction at Verona airport.
138
(228) Overall, given the market shares of the Parties, the presence of significant
competitors and the fact that no material concern was expressed during the market
investigation, the Commission considers that the Transaction is unlikely to lead to
any significant competition concerns for the market for short-term car rental
services at Verona airport, under any plausible segmentation.
Conclusion
(229) In view of the above, and considering all evidence available to the Commission,
the Transaction does not raise serious doubts as concerns the market for short-
term car rental services at Verona airport, under any plausible segmentation.
4.3.3. Portugal
4.3.3.1. At national level
Table 27 - Overlaps in Portugal
Overlapping market
Combined market share (%)
Short-term car rental
services
Short-term leisure car
rental services
Portugal
[20-30]%
[20-30]%
(230) The market shares of the merged entity on the market for short-term car rental
services would remain limited at [20-30]%. On a plausible narrower market for
137
Form CO, Annex 27; replies to Questionnaire 1 to market participants, question 4.3.
138
Replies to Questionnaire 1 to market participants, question 29.2 replies to Questionnaire 2 to airport
managers, questions 15 and 18; and replies to Questionnaire 3 to customer associations, question 18.
40
short-term leisure car rental services, the combined market share of the merged
entity would be [20-30]%.
(231) Significant competitors such as Avis, Hertz or Sixt are active in the market for
short-term car rental services and short-term leisure car rental services at national
level in Portugal.
139
(232) In addition, a majority of the respondents to the market investigation submitted
that there will be sufficient competition post-transaction in Portugal to prevent the
merged entity from raising prices.
140
(233) Moreover no respondent to the market investigation raised any material concern
as to the effect of the Transaction in Portugal.
141
(234) Overall, given the limited market shares of the Parties, the presence of significant
competitors, the fact that the Parties' competitors expect sufficient competition to
prevent the merged entity from raising prices, and the fact that no material
concern was expressed during the market investigation, the Commission
considers that the Transaction is unlikely to lead to any significant competition
concerns for the market for short-term car rental services in Portugal, under any
plausible segmentation.
Conclusion
(235) In view of the above, and considering all evidence available to the Commission,
the Transaction does not raise serious doubts as concerns the market for short-
term car rental services in Portugal, under any plausible segmentation.
4.3.3.2. Faro airport
Table 28 - Overlaps at Faro airport
Overlapping market
Combined market share (%)
Short-term car rental
services
Short-term leisure car
rental services
Faro airport
[25-50]%
[25-50]%
(236) The market share of the merged entity on the market for short-term car rental
services would reach [25-50]%. On a plausible narrower market for short-term
leisure car rental services, the combined market share of the merged entity would
be [25-50]%.
139
Form CO, Annex 27; and replies to Questionnaire 1 to market participants, question 4.5 and/or to a
Request for Information by the Commission.
140
Replies to Questionnaire 1 to market participants, question 28; replies to Questionnaire 2 to airport
managers, question 16; and replies to Questionnaire 3 to customer associations, question 16.
141
Replies to Questionnaire 1 to market participants, question 29.2; replies to Questionnaire 2 to airport
managers, questions 15 and 18; and replies to Questionnaire 3 to customer associations, question 18.
41
(237) Significant competitors such as Avis, Hertz, Sixt or Guerin are active in the
market for short-term car rental services and short-term leisure car rental services
at Faro airport.
142
(238) Moreover no respondent to the market investigation raised any material concern
as to the effect of the Transaction at Faro airport.
143
(239) Overall, given the market shares of the Parties, the presence of significant
competitors and the fact that no material concern was expressed during the market
investigation, the Commission considers that the Transaction is unlikely to lead to
any significant competition concerns for the market for short-term car rental
services at Faro airport, under any plausible segmentation.
Conclusion
(240) In view of the above, and considering all evidence available to the Commission,
the Transaction does not raise serious doubts as concerns the market for short-
term car rental services at Faro airport, under any plausible segmentation.
4.3.3.3. Lisbon airport
Table 29 - Overlaps at Lisbon airport
Overlapping market
Combined market share (%)
Short-term car rental
services
Short-term leisure car
rental services
Lisbon airport
[25-50]%
[25-50]%
(241) The market share of the merged entity on the market for short-term car rental
services would reach [25-50]%. On a plausible narrower market for short-term
leisure car rental services, the combined market share of the merged entity would
be [25-50]%.
(242) Significant competitors such as Avis, Hertz, Sixt or Guerin are active in the
market for short-term car rental services and short-term leisure car rental services
at Lisbon airport.
144
(243) Moreover no respondent to the market investigation raised any material concern
as to the effect of the Transaction at Lisbon airport.
145
(244) Overall, given the market shares of the Parties, the presence of significant
competitors and the fact that no material concern was expressed during the market
142
Form CO, Annex 27; replies to Questionnaire 1 to market participants, question 4.4.
143
Replies to Questionnaire 1 to market participants, question 29.2; replies to Questionnaire 2 to airport
managers, questions 15 and 18; and replies to Questionnaire 3 to customer associations, question 18.
144
Form CO, Annex 27; replies to Questionnaire 1 to market participants, question 4.4.
145
Replies to Questionnaire 1 to market participants, question 29.2; replies to Questionnaire 2 to airport
managers, questions 15 and 18; and replies to Questionnaire 3 to customer associations, question 18.
42
investigation, the Commission considers that the Transaction is unlikely to lead to
any significant competition concerns for the market for short-term car rental
services at Lisbon airport, under any plausible segmentation.
Conclusion
(245) In view of the above, and considering all evidence available to the Commission,
the Transaction does not raise serious doubts as concerns the market for short-
term car rental services at Lisbon airport, under any plausible segmentation.
4.3.3.4. Madeira airport
Table 30 - Overlaps at Madeira airport
Overlapping market
Combined market share (%)
Short-term car rental
services
Short-term leisure car
rental services
Madeira airport
[25-50]%
[25-50]%
(246) The market share of the merged entity on the market for short-term car rental
services would reach [25-50]%. On a plausible narrower market for short-term
leisure car rental services, the combined market share of the merged entity would
be [25-50]%.
(247) Significant competitors such as Avis, Guerin, Hertz or Rodavante are active in the
market for short-term car rental services and short-term leisure car rental services
at Madeira airport.
146
(248) Moreover no respondent to the market investigation raised any material concern
as to the effect of the Transaction at Madeira airport.
147
(249) Overall, given the market shares of the Parties, the presence of significant
competitors and the fact that no material concern was expressed during the market
investigation, the Commission considers that the Transaction is unlikely to lead to
any significant competition concerns for the market for short-term car rental
services at Madeira airport, under any plausible segmentation.
Conclusion
(250) In view of the above, and considering all evidence available to the Commission,
the Transaction does not raise serious doubts as concerns the market for short-
term car rental services at Madeira airport, under any plausible segmentation.
146
Form CO, Annex 27; replies to Questionnaire 1 to market participants, question 4.4.
147
Replies to Questionnaire 1 to market participants, question 29.2; replies to Questionnaire 2 to airport
managers, questions 15 and 18; and replies to Questionnaire 3 to customer associations, question 18.
43
4.3.3.5. Ponta Delgada airport
Table 31 - Overlaps at Ponta Delgada airport
Overlapping market
Combined market share (%)
Short-term car rental
services
Short-term leisure car
rental services
Ponta Delgada airport
[0-25]%
[0-25]%
(251) The Parties currently overlap in the provision of short-term car rental services at
Ponta Delgada airport (Azores). However, Goldcar entered operations only in
2017.
(252) The market share of the merged entity on the market for short-term car rental
services would reach [0-25]%. On a plausible narrower market for short-term
leisure car rental services, the combined market share of the merged entity would
be [0-25]%.
(253) Significant competitors such as Hertz or IlhaVerde are active in the market for
short-term car rental services and short-term leisure car rental services at Ponta
Delgada airport.
148
(254) Moreover no respondent to the market investigation raised any material concern
as to the effect of the Transaction at Ponta Delgada airport.
149
(255) Overall, given the market shares of the Parties, the presence of significant
competitors and the fact that no material concern was expressed during the market
investigation, the Commission considers that the Transaction is unlikely to lead to
any significant competition concerns for the market for short-term car rental
services at Ponta Delgada airport, under any plausible segmentation.
Conclusion
(256) In view of the above, and considering all evidence available to the Commission,
the Transaction does not raise serious doubts as concerns the market for short-
term car rental services at Ponta Delgada airport, under any plausible
segmentation.
148
Form CO, Annex 27; replies to Questionnaire 1 to market participants, question 4.4.
149
Replies to Questionnaire 1 to market participants, question 29.2; replies to Questionnaire 2 to airport
managers, questions 15 and 18; and replies to Questionnaire 3 to customer associations, question 18.
44
4.3.3.6. Porto airport
Table 32 - Overlaps at Porto airport
Overlapping market
Combined market share (%)
Short-term car rental
services
Short-term leisure car
rental services
Porto airport
[25-50]%
[25-50]%
(257) The market share of the merged entity on the market for short-term car rental
services would reach [25-50]%. On a plausible narrower market for short-term
leisure car rental services, the combined market share of the merged entity would
be [25-50]%.
(258) Significant competitors such as Avis, Hertz, Sixt or Guerin are active in the
market for short-term car rental services and short-term leisure car rental services
at Porto airport.
150
(259) In addition, a majority of the respondents to the market investigation submitted
that there will be sufficient competition post-transaction at Porto airport to
prevent the merged entity from raising prices.
151
(260) Moreover no respondent to the market investigation raised any material concern
as to the effect of the Transaction at Porto airport.
152
(261) Overall, given the market shares of the Parties, the presence of significant
competitors, the fact that the Parties' competitors expect sufficient competition to
prevent the merged entity from raising prices, and the fact that no material
concern was expressed during the market investigation, the Commission
considers that the Transaction is unlikely to lead to any significant competition
concerns for the market for short-term car rental services at Porto airport, under
any plausible segmentation.
Conclusion
(262) In view of the above, and considering all evidence available to the Commission,
the Transaction does not raise serious doubts as concerns the market for short-
term car rental services at Porto airport, under any plausible segmentation.
150
Form CO, Annex 27; replies to Questionnaire 1 to market participants, question 4.4.
151
Replies to Questionnaire 1 to market participants, question 28; replies to Questionnaire 2 to airport
managers, question 16; and replies to Questionnaire 3 to customer associations, question 16.
152
Replies to Questionnaire 1 to market participants, question 29; replies to Questionnaire 2 to airport
managers, questions 15 and 17; and replies to Questionnaire 3 to customer associations, question 17.
45
4.3.4. Spain
4.3.4.1. At national level
Table 33 - Overlaps in Spain
Overlapping market
Combined market share (%)
Short-term car rental
services
Short-term leisure car
rental services
Spain
[20-30]%
[20-30]%
(263) The market shares of the merged entity on the market for short-term car rental
services would remain limited at [20-30]%. On a plausible narrower market for
short-term leisure car rental services, the combined market share of the merged
entity would be [20-30]%.
(264) Significant competitors such as Avis, Enterprise, Hertz or Sixt are active in the
market for short-term car rental services and short-term leisure car rental services
at national level in Spain.
153
(265) In addition, a majority of the respondents to the market investigation submitted
that there will be sufficient competition post-transaction in Spain to prevent the
merged entity from raising prices.
154
(266) Moreover a majority of respondents to the market investigation did not raise
material concerns as to the effect of the Transaction in Spain.
155
(267) Overall, given the limited market shares of the Parties, the presence of significant
competitors, the fact that the Parties' competitors expect sufficient competition to
prevent the merged entity from raising prices, and the fact that no material
concern was expressed during the market investigation, the Commission
considers that the Transaction is unlikely to lead to any significant competition
concerns for the market for short-term car rental services in Spain, under any
plausible segmentation.
Conclusion
(268) In view of the above, and considering all evidence available to the Commission,
the Transaction does not raise serious doubts as concerns the market for short-
term car rental services in Spain, under any plausible segmentation.
153
Form CO, Annex 27; and replies to Questionnaire 1 to market participants, question 4.5 and/or to a
Request for Information by the Commission.
154
Replies to Questionnaire 1 to market participants, question 28; replies to Questionnaire 2 to airport
managers, question 16; and replies to Questionnaire 3 to customer associations, question 16.
155
Replies to Questionnaire 1 to market participants, question 29.2; replies to Questionnaire 2 to airport
managers, questions 15 and 18; and replies to Questionnaire 3 to customer associations, question 18.
46
4.3.4.2. Alicante airport
Table 34 - Overlaps at Alicante airport
Overlapping market
Combined market share (%)
Short-term car rental
services
Short-term leisure car
rental services
Alicante airport
[25-50]%
[25-50]%
(269) The market share of the merged entity on the market for short-term car rental
services would reach [25-50]%. On a plausible narrower market for short-term
leisure car rental services, the combined market share of the merged entity would
be [25-50]%.
(270) Significant competitors such as Avis, Centauro, Hertz or Record Go are active in
the market for short-term car rental services and short-term leisure car rental
services at Alicante airport.
156
(271) Moreover no respondent to the market investigation raised any material concern
as to the effect of the Transaction at Alicante airport.
157
(272) Overall, given the market shares of the Parties, the presence of significant
competitors and the fact that no material concern was expressed during the market
investigation, the Commission considers that the Transaction is unlikely to lead to
any significant competition concerns for the market for short-term car rental
services at Alicante airport, under any plausible segmentation.
Conclusion
(273) In view of the above, and considering all evidence available to the Commission,
the Transaction does not raise serious doubts as concerns the market for short-
term car rental services at Alicante airport, under any plausible segmentation.
156
Form CO, Annex 27; and replies to Questionnaire 1 to market participants, question 4.5 and/or to a
Request for Information by the Commission.
157
Replies to Questionnaire 1 to market participants, question 29.2; replies to Questionnaire 2 to airport
managers, questions 15 and 18; and replies to Questionnaire 3 to customer associations, question 18.
47
4.3.4.3. Alicante downtown
Table 35 - Overlaps at Alicante downtown
Overlapping market
Combined market share (%)
Short-term car rental
services
Short-term leisure car
rental services
Alicante downtown
[25-50]%
[25-50]%
(274) The market share of the merged entity on the market for short-term car rental
services would reach [25-50]%. On a plausible narrower market for short-term
leisure car rental services, the combined market share of the merged entity would
be [25-50]%.
(275) Significant competitors such as Avis, Enterprise, Hertz or Sixt are active in the
market for short-term car rental services and short-term leisure car rental services
at Alicante downtown.
158
(276) Moreover no respondent to the market investigation raised any material concern
as to the effect of the Transaction at Alicante downtown.
159
(277) Overall, given the market shares of the Parties, the presence of significant
competitors and the fact that no material concern was expressed during the market
investigation, the Commission considers that the Transaction is unlikely to lead to
any significant competition concerns for the market for short-term car rental
services at Alicante downtown, under any plausible segmentation.
Conclusion
(278) In view of the above, and considering all evidence available to the Commission,
the Transaction does not raise serious doubts as concerns the market for short-
term car rental services at Alicante downtown, under any plausible segmentation.
4.3.4.4. Almeria airport
Table 36 - Overlaps at Almeria airport
Overlapping market
Combined market share (%)
Short-term car rental
services
Short-term leisure car
rental services
Almeria airport
[50-75]%
[75-100]%
(279) The market share of the merged entity on the market for short-term car rental
services would reach [50-75]% at Almeria airport. On a plausible narrower
158
Form CO, Annex 27; replies to Questionnaire 1 to market participants, question 4.6.
159
Replies to Questionnaire 1 to market participants, question 29.2; replies to Questionnaire 2 to airport
managers, questions 15 and 18; and replies to Questionnaire 3 to customer associations, question 18.
48
market for short-term leisure car rental services, the combined market share of the
merged entity would be [75-100]%.
(280) Nevertheless, despite the high combined market shares of the Parties at Almeria
airport (where both operate on-airport), some structural specificities of the market
for the provision of short-term car rental services need to be considered in the
assessment.
(281) First, as mentioned in section 4.1 above, the barriers to operate car rental services
are low. The investment required and the time necessary to start or expand
operations in a given airport are relatively low, and brokers exert competitive
pressure over car rental operators. In the particular case of Almeria airport, there
remains additional commercial and parking space available so that a competitor
could start to operate on-airport services relatively quickly.
160
(282) Second, significant competitors such as Avis or Hertz are active in the market for
short-term car rental services and short-term leisure car rental services at Almeria
airport.
161
These competitors have a multi-brand portfolio addressing both
corporate and leisure services, and they are considered closer competitors to
Europcar than Goldcar.
(283) Hertz is also active on-airport and it could easily re-deploy its fleet and sales
channels (directly or through any of its subsidiary brands such as Dollar or
Firefly) to re-balance its offer between corporate and leisure customers if the
merged entity attempts to increase prices in any or both of the two segments.
(284) In addition, a competitor operating off-airport at Almeria airport submitted that
on-airport and off-airport services are interchangeable in the particular case of
Almeria airport.
162
(285) Third, and importantly, a respondent to the market investigation provided a clear
indication that another low cost car rental supplier will likely enter at Almeria
airport in 2018, which would likely exert sufficient competitive pressure to
counter any potential price increase by the merged entity.
163
(286) Fourth, a majority of the respondents to the market investigation having expressed
an opinion submitted that there will be sufficient competition post-Transaction at
Almeria airport to prevent the merged entity from raising prices.
164
(287) Moreover no respondent to the market investigation raised any material concern
as to the effect of the Transaction at Almeria airport.
165
160
See Section 4.1.4 for a description on the entry into on-airport operations in the Spanish airports
managed by AENA.
161
Form CO, Annex 27; replies to Questionnaire 1 to market participants, question 4.2.
162
Replies to Questionnaire 1 to market participants, question 9.3.1.
163
Reply to Questionnaire 1 to market participants, question 28.1 in conjunction with an e-mail by a
market participant of 29 November 2017.
164
Replies to Questionnaire 1 to market participants, question 28.
49
(288) On balance, given the low barriers to entry, the presence of significant close
competitors, the likelihood of timely and sufficient entry, the fact that the
majority of respondents to the market investigation expect sufficient competition
to prevent the merged entity from raising prices, and the fact that no material
concern was expressed during the market investigation, the Commission
considers that the Transaction is unlikely to lead to any significant competition
concerns for the market for short-term car rental services at Almeria airport,
under any plausible segmentation.
Conclusion
(289) In view of the above, and considering all evidence available to the Commission,
the Transaction does not raise serious doubts as concerns the market for short-
term car rental services at Almeria airport, under any plausible segmentation.
4.3.4.5. Asturias airport
Table 37 - Overlaps at Asturias airport
Overlapping market
Combined market share (%)
Short-term car rental
services
Short-term leisure car
rental services
Asturias airport
[25-50]%
[25-50]%
(290) The market share of the merged entity on the market for short-term car rental
services would reach [25-50]%. On a plausible narrower market for short-term
leisure car rental services, the combined market share of the merged entity would
be [25-50]%.
(291) Significant competitors such as Avis, Enterprise or Hertz are active in the market
for short-term car rental services and short-term leisure car rental services at
Asturias airport.
166
(292) In addition, a majority of the respondents to the market investigation submitted
that there will be sufficient competition post-transaction at Asturias airport to
prevent the merged entity from raising prices.
167
(293) Moreover no respondent to the market investigation raised any material concern
as to the effect of the Transaction at Asturias airport.
168
165
Replies to Questionnaire 1 to market participants, question 29; replies to Questionnaire 2 to airport
managers, questions 15 and 17; and replies to Questionnaire 3 to customer associations, questions 17.
166
Form CO, Annex 27; and replies to Questionnaire 1 to market participants, question 4.5 and/or to a
Request for Information by the Commission.
167
Replies to Questionnaire 1 to market participants, question 28; replies to Questionnaire 2 to airport
managers, question 16; and replies to Questionnaire 3 to customer associations, question 16.
168
Replies to Questionnaire 1 to market participants, question 29; replies to Questionnaire 2 to airport
managers, questions 15 and 17; and replies to Questionnaire 3 to customer associations, question 17.
50
(294) Overall, given the market shares of the Parties, the presence of significant
competitors, the fact that the Parties' competitors expect sufficient competition to
prevent the merged entity from raising prices, and the fact that no material
concern was expressed during the market investigation, the Commission
considers that the Transaction is unlikely to lead to any significant competition
concerns for the market for short-term car rental services at Asturias airport,
under any plausible segmentation.
Conclusion
(295) In view of the above, and considering all evidence available to the Commission,
the Transaction does not raise serious doubts as concerns the market for short-
term car rental services at Asturias airport, under any plausible segmentation.
4.3.4.6. Barcelona airport
Table 38 - Overlaps at Barcelona airport
Overlapping market
Combined market share (%)
Short-term car rental
services
Short-term leisure car
rental services
Barcelona airport
[25-50]%
[25-50]%
(296) The market share of the merged entity on the market for short-term car rental
services would reach [25-50]%. On a plausible narrower market for short-term
leisure car rental services, the combined market share of the merged entity would
be [25-50]%.
(297) Significant competitors such as Avis, Enterprise, Hertz or Sixt are active in the
market for short-term car rental services and short-term leisure car rental services
at Barcelona airport.
169
(298) Moreover no respondent to the market investigation raised any material concern
as to the effect of the Transaction at Barcelona airport.
170
(299) Overall, given the market shares of the Parties, the presence of significant
competitors and the fact that no material concern was expressed during the market
investigation, the Commission considers that the Transaction is unlikely to lead to
any significant competition concerns for the market for short-term car rental
services at Barcelona airport, under any plausible segmentation.
169
Form CO, Annex 27; and replies to Questionnaire 1 to market participants, question 4.5 and/or to a
Request for Information by the Commission.
170
Replies to Questionnaire 1 to market participants, question 29.2; replies to Questionnaire 2 to airport
managers, questions 15 and 18; and replies to Questionnaire 3 to customer associations, question 18.
51
Conclusion
(300) In view of the above, and considering all evidence available to the Commission,
the Transaction does not raise serious doubts as concerns the market for short-
term car rental services at Barcelona airport, under any plausible segmentation.
4.3.4.7. Barcelona downtown
Table 39 - Overlaps at Barcelona downtown
Overlapping market
Combined market share (%)
Short-term car rental
services
Short-term leisure car
rental services
Barcelona downtown
[0-25]%
[0-25]%
(301) The market share of the merged entity on the market for short-term car rental
services would reach [0-25]%. On a plausible narrower market for short-term
leisure car rental services, the combined market share of the merged entity would
be [0-25]%.
(302) Significant competitors such as Avis, Enterprise, Hertz or Sixt, are active in the
market for short-term car rental services and short-term leisure car rental services
at Barcelona downtown.
171
(303) Moreover no respondent to the market investigation raised any material concern
as to the effect of the Transaction at Barcelona downtown.
172
(304) Overall, given the market shares of the Parties, the presence of significant
competitors and the fact that no material concern was expressed during the market
investigation, the Commission considers that the Transaction is unlikely to lead to
any significant competition concerns for the market for short-term car rental
services at Barcelona downtown, under any plausible segmentation.
Conclusion
(305) In view of the above, and considering all evidence available to the Commission,
the Transaction does not raise serious doubts as concerns the market for short-
term car rental services at Barcelona downtown, under any plausible
segmentation.
171
Form CO, Annex 27; replies to Questionnaire 1 to market participants, question 4.6.
172
Replies to Questionnaire 1 to market participants, question 29.2; replies to Questionnaire 2 to airport
managers, questions 15 and 18; and replies to Questionnaire 3 to customer associations, question 18.
52
4.3.4.8. Benidorm downtown
Table 40 - Overlaps at Benidorm downtown
Overlapping market
Combined market share (%)
Short-term car rental
services
Short-term leisure car
rental services
Benidorm downtown
[0-25]%
[0-25]%
(306) The market share of the merged entity on the market for short-term car rental
services would reach [0-25]%. On a plausible narrower market for short-term
leisure car rental services, the combined market share of the merged entity would
be [0-25]%.
(307) Significant competitors such as Avis, Centauro or Enterprise are active in the
market for short-term car rental services and short-term leisure car rental services
at Benidorm downtown.
173
(308) Moreover no respondent to the market investigation raised any material concern
as to the effect of the Transaction at Benidorm downtown.
174
(309) Overall, given the market shares of the Parties, the presence of significant
competitors and the fact that no material concern was expressed during the market
investigation, the Commission considers that the Transaction is unlikely to lead to
any significant competition concerns for the market for short-term car rental
services at Benidorm downtown, under any plausible segmentation.
Conclusion
(310) In view of the above, and considering all evidence available to the Commission,
the Transaction does not raise serious doubts as concerns the market for short-
term car rental services at Benidorm downtown, under any plausible
segmentation.
173
Form CO, Annex 27; replies to Questionnaire 1 to market participants, question 4.6.
174
Replies to Questionnaire 1 to market participants, question 29.2; replies to Questionnaire 2 to airport
managers, questions 15 and 18; and replies to Questionnaire 3 to customer associations, question 18.
53
4.3.4.9. Bilbao airport
Table 41 - Overlaps at Bilbao airport
Overlapping market
Combined market share (%)
Short-term car rental
services
Short-term leisure car
rental services
Bilbao airport
[25-50]%
[25-50]%
(311) The market share of the merged entity on the market for short-term car rental
services would reach [25-50]%. On a plausible narrower market for short-term
leisure car rental services, the combined market share of the merged entity would
be [25-50]%.
(312) Significant competitors such as Avis, Enterprise, Hertz or Sixt are active in the
market for short-term car rental services and short-term leisure car rental services
at Bilbao airport.
175
(313) Moreover no respondent to the market investigation raised any material concern
as to the effect of the Transaction at Bilbao airport.
176
(314) Overall, given the market shares of the Parties, the presence of significant
competitors and the fact that no material concern was expressed during the market
investigation, the Commission considers that the Transaction is unlikely to lead to
any significant competition concerns for the market for short-term car rental
services at Bilbao airport, under any plausible segmentation.
Conclusion
(315) In view of the above, and considering all evidence available to the Commission,
the Transaction does not raise serious doubts as concerns the market for short-
term car rental services at Bilbao airport, under any plausible segmentation.
175
Form CO, Annex 27; and replies to Questionnaire 1 to market participants, question 4.5 and/or to a
Request for Information by the Commission.
176
Replies to Questionnaire 1 to market participants, question 29.2; replies to Questionnaire 2 to airport
managers, questions 15 and 18; and replies to Questionnaire 3 to customer associations, question 18.
54
4.3.4.10. Fuerteventura airport
Table 42 - Overlaps at Fuerteventura airport
Overlapping market
Combined market share (%)
Short-term car rental
services
Short-term leisure car
rental services
Fuerteventura airport
[0-25]%
[0-25]%
(316) The market share of the merged entity on the market for short-term car rental
services would reach [0-25]%. On a plausible narrower market for short-term
leisure car rental services, the combined market share of the merged entity would
be [0-25]%.
(317) Significant competitors such as Avis, Cicar, Hertz or TopCar are active in the
market for short-term car rental services and short-term leisure car rental services
at Fuerteventura airport.
177
(318) Moreover no respondent to the market investigation raised any material concern
as to the effect of the Transaction at Fuerteventura airport.
178
(319) Overall, given the market shares of the Parties, the presence of significant
competitors and the fact that no material concern was expressed during the market
investigation, the Commission considers that the Transaction is unlikely to lead to
any significant competition concerns for the market for short-term car rental
services at Fuerteventura airport, under any plausible segmentation.
Conclusion
(320) In view of the above, and considering all evidence available to the Commission,
the Transaction does not raise serious doubts as concerns the market for short-
term car rental services at Fuerteventura airport, under any plausible
segmentation.
177
Form CO, Annex 27; and replies to Questionnaire 1 to market participants, question 4.5 and/or to a
Request for Information by the Commission.
178
Replies to Questionnaire 1 to market participants, question 29.2; replies to Questionnaire 2 to airport
managers, questions 15 and 18; and replies to Questionnaire 3 to customer associations, question 18.
55
4.3.4.11. Girona airport
Table 43 - Overlaps at Girona airport
Overlapping market
Combined market share (%)
Short-term car rental
services
Short-term leisure car
rental services
Girona airport
[50-75]%
[50-75]%
(321) The market share of the merged entity on the market for short-term car rental
services would reach [50-75]% at Girona airport. On a plausible narrower market
for short-term leisure car rental services, the combined market share of the
merged entity would be [50-75]%.
(322) Nevertheless, despite the high combined market shares of the Parties at Girona
airport, some specificities of the market for the provision of short-term car rental
services need to be considered in the assessment.
(323) First, as mentioned in section 4.1 above, the barriers to operate car rental services
are low. The investment required and the time necessary to start or expand
operations in a given airport are relatively low, and brokers exert competitive
pressure over car rental operators. In the case of Girona airport (where Europcar
operates off-airport and Goldcar operates on-airport), there remains additional
commercial and parking space available so that a competitor could start to operate
on-airport services relatively quickly.
179
(324) As a way of example to illustrate the market dynamics, Sixt entered operations in
May 2017;
180
Goldcar exited Girona airport in October 2016, but re-entered in
June 2017; and Europcar stopped operating on-airport at Girona airport in
October 2016 to resume operations immediately afterwards from a station located
off-airport.
(325) Second, significant competitors such as Avis, Hertz or Sixt are active in the
market for short-term car rental services and short-term leisure car rental services
at Girona airport.
181
Most of these competitors have a multi-brand portfolio
addressing both corporate and leisure services, and they are considered closer
competitor to Europcar than Goldcar.
(326) Third, a majority of respondents to the market investigation having expressed an
opinion submitted that there will be sufficient competition post-transaction at
Girona airport to prevent the merged entity from raising prices.
182
179
See section 4.1.4 for a description on the entry into on-airport operations in the Spanish airports
managed by AENA.
180
See e-mail of Sixt of 23 October 2017.
181
Form CO, Annex 27; replies to Questionnaire 1 to market participants, question 4.2.
182
Replies to Questionnaire 1 to market participants, question 28.
56
(327) Moreover no respondent to the market investigation raised any material concern
as to the effect of the Transaction at Girona airport.
183
(328) On balance, given the low barriers to entry, the market dynamics, the presence of
significant close competitors, the fact that a majority of respondents to the market
investigation expect sufficient competition to prevent the merged entity from
raising prices, and the fact that no material concern was expressed during the
market investigation, the Commission considers that the Transaction is unlikely to
lead to any significant competition concerns for the market for short-term car
rental services at Girona airport, under any plausible segmentation.
Conclusion
(329) In view of the above, and considering all evidence available to the Commission,
the Transaction does not raise serious doubts as concerns the market for short-
term car rental services at Girona airport, under any plausible segmentation.
4.3.4.12. Gran Canaria airport
Table 44 - Overlaps at Gran Canaria airport
Overlapping market
Combined market share (%)
Short-term car rental
services
Short-term leisure car
rental services
Gran Canaria airport
[25-50]%
[25-50]%
(330) The market share of the merged entity on the market for short-term car rental
services would reach [25-50]%. On a plausible narrower market for short-term
leisure car rental services, the combined market share of the merged entity would
be [25-50]%.
(331) Significant competitors such as Avis, Cicar, Hertz or Topcar are active in the
market for short-term car rental services and short-term leisure car rental services
at Gran Canaria airport.
184
(332) Moreover no respondent to the market investigation raised any material concern
as to the effect of the Transaction at Gran Canaria airport.
185
(333) Overall, given the market shares of the Parties, the presence of significant
competitors and the fact that no material concern was expressed during the market
investigation, the Commission considers that the Transaction is unlikely to lead to
any significant competition concerns for the market for short-term car rental
services at Gran Canaria airport, under any plausible segmentation.
183
Replies to Questionnaire 1 to market participants, question 29; replies to Questionnaire 2 to airport
managers, questions 15 and 17; and replies to Questionnaire 3 to customer associations, questions 17.
184
Form CO, Annex 27; and replies to Questionnaire 1 to market participants, question 4.5 and/or to a
Request for Information by the Commission.
185
Replies to Questionnaire 1 to market participants, question 29.2; replies to Questionnaire 2 to airport
managers, questions 15 and 18; and replies to Questionnaire 3 to customer associations, question 18.
57
Conclusion
(334) In view of the above, and considering all evidence available to the Commission,
the Transaction does not raise serious doubts as concerns the market for short-
term car rental services at Gran Canaria airport, under any plausible
segmentation.
4.3.4.13. Granada airport
Table 45 - Overlaps at Granada airport
Overlapping market
Combined market share (%)
Short-term car rental
services
Short-term leisure car
rental services
Granada airport
[25-50]%
[50-75]%
(335) The market share of the merged entity on the market for short-term car rental
services would reach [25-50]% at Granada airport. On a plausible narrower
market for short-term leisure car rental services, the combined market share of the
merged entity would be [50-75]%.
(336) Nevertheless, despite the high combined market shares of the Parties at Granada
airport for leisure customers, some specificities of the market for the provision of
short-term car rental services need to be considered in the assessment.
(337) First, as mentioned in section 4.1 above, the barriers to operate car rental services
are low. The investment required and the time necessary to start or expand
operations in a given airport are relatively low, and brokers exert competitive
pressure over car rental operators. In the case of Granada airport (where both
Europcar and Goldcar operate off-airport), there remains additional commercial
and parking space available so that a competitor could start to operate on-airport
services relatively quickly.
186
(338) As a way of example to illustrate the market dynamics, both Goldcar and
Europcar stopped operating on-airport at Granada airport in October 2016 to
resume operations immediately afterwards from stations located off-airport; and
OK Rent a Car entered Granada airport in 2017.
187
(339) Second, significant competitors such as Avis, Enterprise or OK Rent a Car are
active in the market for short-term car rental services and short-term leisure car
rental services at Granada airport.
188
Most of these competitors have a multi-
brand portfolio addressing both corporate and leisure services, and they are closer
competitor to Europcar than Goldcar.
186
See section 4.1.4 for a description on the entry into on-airport operations in the Spanish airports
managed by AENA.
187
Competitive assessment submitted by the Parties to the Commission on 16 November 2016.
188
Form CO, Annex 27; replies to Questionnaire 1 to market participants, question 4.2.
58
(340) Third, a majority of the respondents to the market investigation having expressed
an opinion submitted that there will be sufficient competition post-transaction at
Granada airport to prevent the merged entity from raising prices.
189
(341) Moreover no respondent to the market investigation raised any material concern
as to the effect of the Transaction at Granada airport.
190
(342) Finally, the market for short-term leisure car rental services at Granada airport is
limited in size, with only […] and […] contracts reserved with Europcar and
Goldcar respectively in 2016.
191
(343) On balance, given the low barriers to entry, the market dynamics, the presence of
significant close competitors, the fact that the Parties' competitors expect
sufficient competition to prevent the merged entity from raising prices, the fact
that no material concern was expressed during the market investigation, and the
limited size of the market for short-term car rental services at Granada airport, the
Commission considers that the Transaction is unlikely to lead to any significant
competition concerns for the market for short-term car rental services at Granada
airport, under any plausible segmentation.
Conclusion
(344) In view of the above, and considering all evidence available to the Commission,
the Transaction does not raise serious doubts as concerns the market for short-
term car rental services at Granada airport, under any plausible segmentation.
4.3.4.14. Ibiza airport
Table 46 - Overlaps at Ibiza airport
Overlapping market
Combined market share (%)
Short-term car rental
services
Short-term leisure car
rental services
Ibiza airport
[25-50]%
[25-50]%
(345) The market share of the merged entity on the market for short-term car rental
services would reach [25-50]%. On a plausible narrower market for short-term
leisure car rental services, the combined market share of the merged entity would
be [25-50]%.
(346) Significant competitors such as Avis, Hertz, OK Rent a Car or Sixt are active in
the market for short-term car rental services and short-term leisure car rental
services at Ibiza airport.
192
189
Replies to Questionnaire 1 to market participants, question 28.
190
Replies to Questionnaire 1 to market participants, question 29; replies to Questionnaire 2 to airport
managers, questions 15 and 17; and replies to Questionnaire 3 to customer associations, questions 17.
191
Europcar's replies to RFI-5 of 9 November 2017.
59
(347) In addition, a majority of the respondents to the market investigation submitted
that there will be sufficient competition post-transaction at Ibiza airport to prevent
the merged entity from raising prices.
193
(348) Moreover no respondent to the market investigation raised any material concern
as to the effect of the Transaction at Ibiza airport.
194
(349) Overall, given the market shares of the Parties, the presence of significant
competitors, the fact that the Parties' competitors expect sufficient competition to
prevent the merged entity from raising prices, and the fact that no material
concern was expressed during the market investigation, the Commission
considers that the Transaction is unlikely to lead to any significant competition
concerns for the market for short-term car rental services at Ibiza airport, under
any plausible segmentation.
Conclusion
(350) In view of the above, and considering all evidence available to the Commission,
the Transaction does not raise serious doubts as concerns the market for short-
term car rental services at Ibiza airport, under any plausible segmentation.
4.3.4.15. Jerez airport
Table 47 - Overlaps at Jerez airport
Overlapping market
Combined market share (%)
Short-term car rental
services
Short-term leisure car
rental services
Jerez airport
[25-50]%
[25-50]%
(351) The market share of the merged entity on the market for short-term car rental
services would reach [25-50]%. On a plausible narrower market for short-term
leisure car rental services, the combined market share of the merged entity would
be [25-50]%.
(352) Significant competitors such as Avis, Enterprise, Hertz or Sixt are active in the
market for short-term car rental services and short-term leisure car rental services
at Jerez airport.
195
192
Form CO, Annex 27; and replies to Questionnaire 1 to market participants, question 4.5 and/or to a
Request for Information by the Commission.
193
Replies to Questionnaire 1 to market participants, question 28; replies to Questionnaire 2 to airport
managers, question 16; and replies to Questionnaire 3 to customer associations, question 16.
194
Replies to Questionnaire 1 to market participants, question 29; replies to Questionnaire 2 to airport
managers, questions 15 and 17; and replies to Questionnaire 3 to customer associations, question 17.
195
Form CO, Annex 27; and replies to Questionnaire 1 to market participants, question 4.5 and/or to a
Request for Information by the Commission.
60
(353) In addition, a majority of the respondents to the market investigation submitted
that there will be sufficient competition post-transaction at Jerez airport to prevent
the merged entity from raising prices.
196
(354) Moreover no respondent to the market investigation raised any material concern
as to the effect of the Transaction at Jerez airport.
197
(355) Overall, given the market shares of the Parties, the presence of significant
competitors, the fact that the Parties' competitors expect sufficient competition to
prevent the merged entity from raising prices, and the fact that no material
concern was expressed during the market investigation, the Commission
considers that the Transaction is unlikely to lead to any significant competition
concerns for the market for short-term car rental services at Jerez airport, under
any plausible segmentation.
Conclusion
(356) In view of the above, and considering all evidence available to the Commission,
the Transaction does not raise serious doubts as concerns the market for short-
term car rental services at Jerez airport, under any plausible segmentation.
4.3.4.16. La Linea downtown
Table 48 - Overlaps at La Linea downtown
Overlapping market
Combined market share (%)
Short-term car rental
services
Short-term leisure car
rental services
La Linea downtown
[25-50]%
[25-50]%
(357) Car rental stations located in La LÃnea de la Concepción ("La Linea", Spain)
mostly service airline customers flying to/from the airport in Gibraltar (British
Overseas Territory) in an off-airport manner.
198
(358) The market share of the merged entity on the market for short-term car rental
services would reach [25-50]%. On a plausible narrower market for short-term
leisure car rental services, the combined market share of the merged entity would
be [25-50]%.
196
Replies to Questionnaire 1 to market participants, question 28; replies to Questionnaire 2 to airport
managers, question 16; and replies to Questionnaire 3 to customer associations, question 16.
197
Replies to Questionnaire 1 to market participants, question 29; replies to Questionnaire 2 to airport
managers, questions 15 and 17; and replies to Questionnaire 3 to customer associations, question 17.
198
The Parties do not offer pick up/drop off services at Gibraltar airport, but estimate that [80-90]% and
[90-100]% of the contracts closed with Europcar and Goldcar respectively at la Linea are signed by
airline passengers flying to/from Gibraltar airport – Europcar's replies to RFI-5 of 9 November 2017.
Therefore, considering those exceptional local circumstances and as an exception to the geographic
market definition referred to in section 3.2, no distinction will be made at local level between La Linea
downtown and Gibraltar airport, which are at walking distance from each other.
61
(359) Significant competitors such as Avis or Autos Aguirre are active in the market for
short-term car rental services and short-term leisure car rental services at La Linea
downtown/Gibraltar airport.
199
(360) Moreover no respondent to the market investigation raised any material concern
as to the effect of the Transaction at La Linea downtown/Gibraltar airport.
200
(361) Overall, given the market shares of the Parties, the presence of significant
competitors, the fact that the Parties' competitors expect sufficient competition to
prevent the merged entity from raising prices, and the fact that no material
concern was expressed during the market investigation, the Commission
considers that the Transaction is unlikely to lead to any significant competition
concerns for the market for short-term car rental services at La Linea
downtown/Gibraltar airport, under any plausible segmentation.
Conclusion
(362) In view of the above, and considering all evidence available to the Commission,
the Transaction does not raise serious doubts as concerns the market for short-
term car rental services at La Linea downtown/Gibraltar airport, under any
plausible segmentation.
4.3.4.17. Lanzarote airport
Table 49 - Overlaps at Lanzarote airport
Overlapping market
Combined market share (%)
Short-term car rental
services
Short-term leisure car
rental services
Lanzarote airport
[0-25]%
[0-25]%
(363) The market share of the merged entity on the market for short-term car rental
services would reach [0-25]%. On a plausible narrower market for short-term
leisure car rental services, the combined market share of the merged entity would
be [0-25]%.
(364) Significant competitors such as AutoReisen, Avis, Cicar, or Hertz are active in
the market for short-term car rental services and short-term leisure car rental
services at Lanzarote airport.
201
(365) Moreover no respondent to the market investigation raised any material concern
as to the effect of the Transaction at Lanzarote airport.
202
199
Form CO, Annex 27; replies to Questionnaire 1 to market participants, question 4.6
200
Replies to Questionnaire 1 to market participants, question 29.2; replies to Questionnaire 2 to airport
managers, questions 15 and 18; and replies to Questionnaire 3 to customer associations, question 18.
201
Form CO, Annex 27; and replies to Questionnaire 1 to market participants, question 4.5 and/or to a
Request for Information by the Commission.
62
(366) Overall, given the market shares of the Parties, the presence of significant
competitors and the fact that no material concern was expressed during the market
investigation, the Commission considers that the Transaction is unlikely to lead to
any significant competition concerns for the market for short-term car rental
services at Lanzarote airport, under any plausible segmentation.
Conclusion
(367) In view of the above, and considering all evidence available to the Commission,
the Transaction does not raise serious doubts as concerns the market for short-
term car rental services at Lanzarote airport, under any plausible segmentation.
4.3.4.18. Madrid airport
Table 50 - Overlaps at Madrid airport
Overlapping market
Combined market share (%)
Short-term car rental
services
Short-term leisure car
rental services
Madrid airport
[25-50]%
[25-50]%
(368) The market share of the merged entity on the market for short-term car rental
services would reach [25-50]%. On a plausible narrower market for short-term
leisure car rental services, the combined market share of the merged entity would
be [25-50]%.
(369) Significant competitors such as Avis, Enterprise, Hertz or Sixt are active in the
market for short-term car rental services and short-term leisure car rental services
at Madrid airport.
203
(370) Moreover no respondent to the market investigation raised any material concern
as to the effect of the Transaction at Madrid airport.
204
(371) Overall, given the market shares of the Parties, the presence of significant
competitors, the Commission considers that the Transaction is unlikely to lead to
any significant competition concerns for the market for short-term car rental
services at Madrid airport, under any plausible segmentation.
Conclusion
(372) In view of the above, and considering all evidence available to the Commission,
the Transaction does not raise serious doubts as concerns the market for short-
term car rental services at Madrid airport, under any plausible segmentation.
202
Replies to Questionnaire 1 to market participants, question 29.2; replies to Questionnaire 2 to airport
managers, questions 15 and 18; and replies to Questionnaire 3 to customer associations, question 18.
203
Form CO, Annex 27; and replies to Questionnaire 1 to market participants, question 4.5 and/or to a
Request for Information by the Commission.
204
Replies to Questionnaire 1 to market participants, question 29.2; replies to Questionnaire 2 to airport
managers, questions 15 and 18; and replies to Questionnaire 3 to customer associations, question 18.
63
4.3.4.19. Madrid downtown
Table 51 - Overlaps at Madrid downtown
Overlapping market
Combined market share (%)
Short-term car rental
services
Short-term leisure car
rental services
Madrid downtown
[0-25]%
[0-25]%
(373) The market share of the merged entity on the market for short-term car rental
services would reach [0-25]%. On a plausible narrower market for short-term
leisure car rental services, the combined market share of the merged entity would
be [0-25]%.
(374) Significant competitors such as Avis, Enterprise, Hertz or Sixt are active in the
market for short-term car rental services and short-term leisure car rental services
at Madrid downtown.
205
(375) Moreover no respondent to the market investigation raised any material concern
as to the effect of the Transaction at Madrid downtown.
206
(376) Overall, given the market shares of the Parties, the presence of significant
competitors and the fact that no material concern was expressed during the market
investigation, the Commission considers that the Transaction is unlikely to lead to
any significant competition concerns for the market for short-term car rental
services at Madrid downtown, under any plausible segmentation.
Conclusion
(377) In view of the above, and considering all evidence available to the Commission,
the Transaction does not raise serious doubts as concerns the market for short-
term car rental services at Madrid downtown, under any plausible segmentation.
4.3.4.20. Malaga airport
Table 52 - Overlaps at Malaga airport
Overlapping market
Combined market share (%)
Short-term car rental
services
Short-term leisure car
rental services
Malaga airport
[25-50]%
[25-50]%
(378) The market share of the merged entity on the market for short-term car rental
services would reach [25-50]%. On a plausible narrower market for short-term
205
Form CO, Annex 27; replies to Questionnaire 1 to market participants, question 4.6.
206
Replies to Questionnaire 1 to market participants, question 29.2; replies to Questionnaire 2 to airport
managers, questions 15 and 18; and replies to Questionnaire 3 to customer associations, question 18.
64
leisure car rental services, the combined market share of the merged entity would
be [25-50]%.
(379) Significant competitors such as Avis, Hertz, Record Go or Sixt are active in the
market for short-term car rental services and short-term leisure car rental services
at Malaga airport.
207
(380) Moreover no respondent to the market investigation raised any material concern
as to the effect of the Transaction at Malaga airport.
208
(381) Overall, given the market shares of the Parties, the presence of significant
competitors and the fact that no material concern was expressed during the market
investigation, the Commission considers that the Transaction is unlikely to lead to
any significant competition concerns for the market for short-term car rental
services at Malaga airport, under any plausible segmentation.
Conclusion
(382) In view of the above, and considering all evidence available to the Commission,
the Transaction does not raise serious doubts as concerns the market for short-
term car rental services at Malaga airport, under any plausible segmentation.
4.3.4.21. Malaga downtown
Table 53 - Overlaps at Malaga downtown
Overlapping market
Combined market share (%)
Short-term car rental
services
Short-term leisure car
rental services
Malaga downtown
[25-50]%
[25-50]%
(383) The market share of the merged entity on the market for short-term car rental
services would reach [25-50]%. On a plausible narrower market for short-term
leisure car rental services, the combined market share of the merged entity would
be [25-50]%.
(384) Significant competitors such as Avis, Enterprise, Hertz or Sixt are active in the
market for short-term car rental services and short-term leisure car rental services
at Malaga downtown.
209
(385) Moreover no respondent to the market investigation raised any material concern
as to the effect of the Transaction at Malaga downtown.
210
207
Form CO, Annex 27; and replies to Questionnaire 1 to market participants, question 4.5 and/or to a
Request for Information by the Commission.
208
Replies to Questionnaire 1 to market participants, question 29.2; replies to Questionnaire 2 to airport
managers, questions 15 and 18; and replies to Questionnaire 3 to customer associations, question 18.
209
Form CO, Annex 27; replies to Questionnaire 1 to market participants, question 4.6.
65
(386) Overall, given the market shares of the Parties, the presence of significant
competitors and the fact that no material concern was expressed during the market
investigation, the Commission considers that the Transaction is unlikely to lead to
any significant competition concerns for the market for short-term car rental
services at Malaga downtown, under any plausible segmentation.
Conclusion
(387) In view of the above, and considering all evidence available to the Commission,
the Transaction does not raise serious doubts as concerns the market for short-
term car rental services at Malaga downtown, under any plausible segmentation.
4.3.4.22. Mallorca downtown
Table 54 - Overlaps at Mallorca downtown
Overlapping market
Combined market share (%)
Short-term car rental
services
Short-term leisure car
rental services
Mallorca downtown
[0-25]%
[0-25]%
(388) The market share of the merged entity on the market for short-term car rental
services would reach [0-25]%. On a plausible narrower market for short-term
leisure car rental services, the combined market share of the merged entity would
be [0-25]%.
(389) Significant competitors such as Avis, Enterprise, Hertz, Hiper, OK Rent a Car, or
Sixt are active in the market for short-term car rental services and short-term
leisure car rental services at Mallorca downtown.
211
(390) Moreover no respondent to the market investigation raised any material concern
as to the effect of the Transaction at Mallorca downtown.
212
(391) Overall, given the market shares of the Parties, the presence of significant
competitors and the fact that no material concern was expressed during the market
investigation, the Commission considers that the Transaction is unlikely to lead to
any significant competition concerns for the market for short-term car rental
services at Mallorca downtown, under any plausible segmentation.
Conclusion
(392) In view of the above, and considering all evidence available to the Commission,
the Transaction does not raise serious doubts as concerns the market for short-
term car rental services at Mallorca downtown, under any plausible segmentation.
210
Replies to Questionnaire 1 to market participants, question 29.2; replies to Questionnaire 2 to airport
managers, questions 15 and 18; and replies to Questionnaire 3 to customer associations, question 18.
211
Form CO, Annex 27; replies to Questionnaire 1 to market participants, question 4.6.
212
Replies to Questionnaire 1 to market participants, question 29.2; replies to Questionnaire 2 to airport
managers, questions 15 and 18; and replies to Questionnaire 3 to customer associations, question 18.
66
4.3.4.23. Menorca airport
Table 55 - Overlaps at Menorca airport
Overlapping market
Combined market share (%)
Short-term car rental
services
Short-term leisure car
rental services
Menorca airport
[25-50]%
[0-25]%
(393) The market share of the merged entity on the market for short-term car rental
services would reach [25-50]%. On a plausible narrower market for short-term
leisure car rental services, the combined market share of the merged entity would
be [0-25]%.
(394) Significant competitors such as Avis, Hertz, OK Rent a Car or Ownerscars are
active in the market for short-term car rental services and short-term leisure car
rental services at Menorca airport.
213
(395) Moreover no respondent to the market investigation raised any material concern
as to the effect of the Transaction at Menorca airport.
214
(396) Overall, given the market shares of the Parties, the presence of significant
competitors and the fact that no material concern was expressed during the market
investigation, the Commission considers that the Transaction is unlikely to lead to
any significant competition concerns for the market for short-term car rental
services at Menorca airport, under any plausible segmentation.
Conclusion
(397) In view of the above, and considering all evidence available to the Commission,
the Transaction does not raise serious doubts as concerns the market for short-
term car rental services at Menorca airport, under any plausible segmentation.
213
Form CO, Annex 27; and replies to Questionnaire 1 to market participants, question 4.5 and/or to a
Request for Information by the Commission.
214
Replies to Questionnaire 1 to market participants, question 29.2; replies to Questionnaire 2 to airport
managers, questions 15 and 18; and replies to Questionnaire 3 to customer associations, question 18.
67
4.3.4.24. Murcia airport
Table 56 - Overlaps at Murcia airport
Overlapping market
Combined market share (%)
Short-term car rental
services
Short-term leisure car
rental services
Murcia airport
[25-50]%
[25-50]%
(398) The market share of the merged entity on the market for short-term car rental
services would reach [25-50]%. On a plausible narrower market for short-term
leisure car rental services, the combined market share of the merged entity would
be [25-50]%.
(399) Significant competitors such as Centauro, Hertz, or Solmar are active in the
market for short-term car rental services and short-term leisure car rental services
at Murcia airport.
215
(400) In addition, a majority of the respondents to the market investigation submitted
that there will be sufficient competition post-transaction at Murcia airport to
prevent the merged entity from raising prices.
216
(401) Moreover no respondent to the market investigation raised any material concern
as to the effect of the Transaction at Murcia airport.
217
(402) Overall, given the market shares of the Parties, the presence of significant
competitors, the fact that the Parties' competitors expect sufficient competition to
prevent the merged entity from raising prices, and the fact that no material
concern was expressed during the market investigation, the Commission
considers that the Transaction is unlikely to lead to any significant competition
concerns for the market for short-term car rental services at Murcia airport, under
any plausible segmentation.
Conclusion
(403) In view of the above, and considering all evidence available to the Commission,
the Transaction does not raise serious doubts as concerns the market for short-
term car rental services at Murcia airport, under any plausible segmentation.
215
Form CO, Annex 27; and replies to Questionnaire 1 to market participants, question 4.5 and/or to a
Request for Information by the Commission.
216
Replies to Questionnaire 1 to market participants, question 28; replies to Questionnaire 2 to airport
managers, question 16; and replies to Questionnaire 3 to customer associations, question 16.
217
Replies to Questionnaire 1 to market participants, question 29; replies to Questionnaire 2 to airport
managers, questions 15 and 17; and replies to Questionnaire 3 to customer associations, question 17.
68
4.3.4.25. Palma de Mallorca airport
Table 57 - Overlaps at Palma de Mallorca airport
Overlapping market
Combined market share (%)
Short-term car rental
services
Short-term leisure car
rental services
Palma de Mallorca airport
[25-50]%
[25-50]%
(404) The market share of the merged entity on the market for short-term car rental
services would reach [25-50]%. On a plausible narrower market for short-term
leisure car rental services, the combined market share of the merged entity would
be [25-50]%.
(405) Significant competitors such as Hertz, Record Go or Sixt are active in the market
for short-term car rental services and short-term leisure car rental services at
Palma de Mallorca airport.
218
(406) Moreover no respondent to the market investigation raised any material concern
as to the effect of the Transaction at Palma de Mallorca airport.
219
(407) Overall, given the market shares of the Parties, the presence of significant
competitors and the fact that no material concern was expressed during the market
investigation, the Commission considers that the Transaction is unlikely to lead to
any significant competition concerns for the market for short-term car rental
services at Palma de Mallorca airport, under any plausible segmentation.
Conclusion
(408) In view of the above, and considering all evidence available to the Commission,
the Transaction does not raise serious doubts as concerns the market for short-
term car rental services at Palma de Mallorca airport, under any plausible
segmentation.
218
Form CO, Annex 27; and replies to Questionnaire 1 to market participants, question 4.5 and/or to a
Request for Information by the Commission.
219
Replies to Questionnaire 1 to market participants, question 29.2; replies to Questionnaire 2 to airport
managers, questions 15 and 18; and replies to Questionnaire 3 to customer associations, question 18.
69
4.3.4.26. Reus airport
Table 58 - Overlaps at Reus airport
Overlapping market
Combined market share (%)
Short-term car rental
services
Short-term leisure car
rental services
Reus airport
[50-75]%
[50-75]%
(409) The market share of the merged entity on the market for short-term car rental
services would reach [50-75]% at Reus airport. On a plausible narrower market
for short-term leisure car rental services, the combined market share of the
merged entity would be [50-75]%.
(410) Nevertheless, despite the high combined market shares of the Parties at Reus
airport, some specificities of the market for the provision of short-term car rental
services need to be considered in the assessment.
(411) First, as mentioned in section 4.1 above, the barriers to operate car rental services
are low. The investment required and the time necessary to start or expand
operations in a given airport are relatively low, and brokers exert competitive
pressure over car rental operators. In the case of Reus airport (where Europcar
operates off-airport and Goldcar operates on-airport), there remains additional
commercial and parking space available so that a competitor could start to operate
on-airport services relatively quickly.
220
(412) As a way of example to illustrate the market dynamics, Europcar stopped
operating on-airport at Reus airport in October 2016 to resume operations
immediately afterwards from a station located off-airport.
(413) Second, significant competitors such as Hertz and Sixt are active in both the
market for short-term car rental services and the short-term leisure car rental
services at Reus airport.
221
Most of these competitors have a multi-brand portfolio
addressing both corporate and leisure services, and they are closer competitor to
Europcar than Goldcar.
(414) In addition, Europcar operates off-airport, while Goldcar operates on-airport.
(415) Third, a majority of the respondents to the market investigation having expressed
an opinion submitted that there will be sufficient competition post-Transaction at
Reus airport to prevent the merged entity from raising prices.
222
(416) Moreover no respondent to the market investigation raised any material concern
as to the effect of the Transaction at Reus airport.
223
220
See Section 4.1.4 for a description on the entry into on-airport operations in the Spanish airports
managed by AENA.
221
Form CO, Annex 27; replies to Questionnaire 1 to market participants, question 4.2.
222
Replies to Questionnaire 1 to market participants, question 28.
70
(417) Finally, the market for short-term car rental services at Reus airport is limited in
size, with only […] and […] contracts reserved with Europcar and Goldcar
respectively in 2016 (and even less if the market is narrowed to short-term leisure
car rental services only).
224
(418) On balance, given the low barriers to entry, the market dynamics, the presence of
significant close competitors, the fact that a majority of respondents to the market
investigation expect sufficient competition to prevent the merged entity from
raising prices, the fact that no material concern was expressed during the market
investigation, and the limited size of the market for short-term car rental services
at Reus airport, the Commission considers that the Transaction is unlikely to lead
to any significant competition concerns for the market for short-term car rental
services at Reus airport, under any plausible segmentation.
Conclusion
(419) In view of the above, and considering all evidence available to the Commission,
the Transaction does not raise serious doubts as concerns the market for short-
term car rental services at Reus airport, under any plausible segmentation.
4.3.4.27. Sancti Petri downtown
Table 59 - Overlaps at Sancti Petri downtown
Overlapping market
Combined market share (%)
Short-term car rental
services
Short-term leisure car
rental services
Sancti Petri downtown
[50-75]%
[50-75]%
(420) The market share of the merged entity on the market for short-term car rental
services would reach [50-75]%. On a plausible narrower market for short-term
leisure car rental services, the combined market share of the merged entity would
be [50-75]%.
(421) Nevertheless, despite the high combined market shares of the Parties at Sancti
Petri, some specificities of the market for the provision of short-term car rental
services need to be considered in the assessment.
(422) First, as mentioned in section 4.1 above, the barriers to operate car rental services
are low. The investment required and the time necessary to start or expand
operations in a given location are relatively low, and brokers exert competitive
pressure over car rental operators. In the case of downtown locations, barriers to
entry are even lower than at airports, since there generally more commercial and
parking space available downtown, and no licence fees are due.
223
Replies to Questionnaire 1 to market participants, question 29; replies to Questionnaire 2 to airport
managers, questions 15 and 17; and replies to Questionnaire 3 to customer associations, questions 17.
224
Europcar's replies to RFI-5 of 9 November 2017.
71
(423) In the particular case of Sancti Petri, Europcar has provided evidence of sufficient
commercial space available in the same shopping centre where the Parties, Avis,
Sixt and Albitana have their car rental stations (Novocener).
225
(424) Second, significant competitors such as Avis or Sixt are active in the market for
short-term car rental services and short-term leisure car rental services at Sancti
Petri downtown.
226
Most of these competitors have a multi-brand portfolio
addressing both corporate and leisure services, and they are considered closer
competitor to Europcar than Goldcar.
(425) Third, no respondent to the market investigation raised any material concern as to
the effect of the Transaction at Sancti Petri downtown.
227
(426) Finally, the market for short-term car rental services at Sancti Petri downtown is
limited in size, with only […] and […] contracts reserved with Europcar and
Goldcar respectively in 2016 (and even less if the market is narrowed to short-
term leisure car rental services).
228
(427) Overall, given the low barriers to entry, the presence of significant close
competitors, the fact that no material concern was expressed during the market
investigation, and the limited size of the market for short-term car rental services
at Sancti Petri, the Commission considers that the Transaction is unlikely to lead
to any significant competition concerns for the market for short-term car rental
services at Sancti Petri, under any plausible segmentation.
Conclusion
(428) In view of the above, and considering all evidence available to the Commission,
the Transaction does not raise serious doubts as concerns the market for short-
term car rental services at Sancti Petri downtown, under any plausible
segmentation.
4.3.4.28. Santander airport
Table 60 - Overlaps at Santander airport
Overlapping market
Combined market share (%)
Short-term car rental
services
Short-term leisure car
rental services
Santander airport
[25-50]%
[25-50]%
(429) The market share of the merged entity on the market for short-term car rental
services would reach [25-50]%. On a plausible narrower market for short-term
225
See Competitive assessment submitted by the Parties to the Commission on 16 November 2016.
226
Form CO, Annex 27; replies to Questionnaire 1 to market participants, question 4.6
227
Replies to Questionnaire 1 to market participants, question 29.2; replies to Questionnaire 2 to airport
managers, questions 15 and 18; and replies to Questionnaire 3 to customer associations, question 18.
228
Europcar's replies to RFI-5 of 9 November 2017.
72
leisure car rental services, the combined market share of the merged entity would
be [25-50]%.
(430) Significant competitors such as Avis, Enterprise or Hertz are active in the market
for short-term car rental services and short-term leisure car rental services at
Santander airport.
229
(431) Moreover no respondent to the market investigation raised any material concern
as to the effect of the Transaction at Santander airport.
230
(432) Overall, given the market shares of the Parties, the presence of significant
competitors and the fact that no material concern was expressed during the market
investigation, the Commission considers that the Transaction is unlikely to lead to
any significant competition concerns for the market for short-term car rental
services at Santander airport, under any plausible segmentation.
Conclusion
(433) In view of the above, and considering all evidence available to the Commission,
the Transaction does not raise serious doubts as concerns the market for short-
term car rental services at Santander airport, under any plausible segmentation.
4.3.4.29. Santiago airport
Table 61 - Overlaps at Santiago airport
Overlapping market
Combined market share (%)
Short-term car rental
services
Short-term leisure car
rental services
Santiago airport
[25-50]%
[25-50]%
(434) The market share of the merged entity on the market for short-term car rental
services would reach [25-50]%. On a plausible narrower market for short-term
leisure car rental services, the combined market share of the merged entity would
be [25-50]%.
(435) Significant competitors such as Avis, Enterprise or Hertz are active in the market
for short-term car rental services and short-term leisure car rental services at
Santiago airport.
231
(436) In addition, a majority of the respondents to the market investigation submitted
that there will be sufficient competition post-transaction at Santiago airport to
prevent the merged entity from raising prices.
232
229
Form CO, Annex 27; and replies to Questionnaire 1 to market participants, question 4.5 and/or to a
Request for Information by the Commission.
230
Replies to Questionnaire 1 to market participants, question 29.2; replies to Questionnaire 2 to airport
managers, questions 15 and 18; and replies to Questionnaire 3 to customer associations, question 18.
231
Form CO, Annex 27; and replies to Questionnaire 1 to market participants, question 4.5 and/or to a
Request for Information by the Commission.
73
(437) Moreover no respondent to the market investigation raised any material concern
as to the effect of the Transaction at Santiago airport.
233
(438) Overall, given the market shares of the Parties, the presence of significant
competitors, the fact that the Parties' competitors expect sufficient competition to
prevent the merged entity from raising prices, and the fact that no material
concern was expressed during the market investigation, the Commission
considers that the Transaction is unlikely to lead to any significant competition
concerns for the market for short-term car rental services at Santiago airport,
under any plausible segmentation.
Conclusion
(439) In view of the above, and considering all evidence available to the Commission,
the Transaction does not raise serious doubts as concerns the market for short-
term car rental services at Santiago airport, under any plausible segmentation.
4.3.4.30. Seville airport
Table 62 - Overlaps at Seville airport
Overlapping market
Combined market share (%)
Short-term car rental
services
Short-term leisure car
rental services
Seville airport
[25-50]%
[25-50]%
(440) The market share of the merged entity on the market for short-term car rental
services would reach [25-50]%. On a plausible narrower market for short-term
leisure car rental services, the combined market share of the merged entity would
be [25-50]%.
(441) Significant competitors such as Avis, Enterprise, Hertz or Sixt or are active in the
market for short-term car rental services and short-term leisure car rental services
at Seville airport.
234
(442) In addition, a majority of the respondents to the market investigation submitted
that there will be sufficient competition post-transaction at Seville airport to
prevent the merged entity from raising prices.
235
(443) Moreover no respondent to the market investigation raised any material concern
as to the effect of the Transaction at Seville airport.
236
232
Replies to Questionnaire 1 to market participants, question 28; replies to Questionnaire 2 to airport
managers, question 16; and replies to Questionnaire 3 to customer associations, question 16.
233
Replies to Questionnaire 1 to market participants, question 29; replies to Questionnaire 2 to airport
managers, questions 15 and 17; and replies to Questionnaire 3 to customer associations, question 17.
234
Form CO, Annex 27; and replies to Questionnaire 1 to market participants, question 4.5 and/or to a
Request for Information by the Commission.
235
Replies to Questionnaire 1 to market participants, question 28; replies to Questionnaire 2 to airport
managers, question 16; and replies to Questionnaire 3 to customer associations, question 16.
74
(444) Overall, given the market shares of the Parties, the presence of significant
competitors, the fact that the Parties' competitors expect sufficient competition to
prevent the merged entity from raising prices, and the fact that no material
concern was expressed during the market investigation, the Commission
considers that the Transaction is unlikely to lead to any significant competition
concerns for the market for short-term car rental services at Seville airport, under
any plausible segmentation.
Conclusion
(445) In view of the above, and considering all evidence available to the Commission,
the Transaction does not raise serious doubts as concerns the market for short-
term car rental services at Seville airport, under any plausible segmentation.
4.3.4.31. Seville downtown
Table 63 - Overlaps at Seville downtown
Overlapping market
Combined market share (%)
Short-term car rental
services
Short-term leisure car
rental services
Seville downtown
[25-50]%
[25-50]%
(446) The market share of the merged entity on the market for short-term car rental
services would reach [25-50]%. On a plausible narrower market for short-term
leisure car rental services, the combined market share of the merged entity would
be [25-50]%.
(447) Significant competitors such as Avis, Enterprise, Hertz or Sixt are active in the
market for short-term car rental services and short-term leisure car rental services
at Seville downtown.
237
(448) Moreover no respondent to the market investigation raised any material concern
as to the effect of the Transaction at Seville downtown.
238
(449) Overall, given the market shares of the Parties, the presence of significant
competitors and the fact that no material concern was expressed during the market
investigation, the Commission considers that the Transaction is unlikely to lead to
any significant competition concerns for the market for short-term car rental
services at Seville downtown, under any plausible segmentation.
236
Replies to Questionnaire 1 to market participants, question 29; replies to Questionnaire 2 to airport
managers, questions 15 and 17; and replies to Questionnaire 3 to customer associations, question 17.
237
Form CO, Annex 27; replies to Questionnaire 1 to market participants, question 4.6.
238
Replies to Questionnaire 1 to market participants, question 29.2; replies to Questionnaire 2 to airport
managers, questions 15 and 18; and replies to Questionnaire 3 to customer associations, question 18.
75
Conclusion
(450) In view of the above, and considering all evidence available to the Commission,
the Transaction does not raise serious doubts as concerns the market for short-
term car rental services at Seville downtown, under any plausible segmentation.
4.3.4.32. Tenerife North airport
Table 64 - Overlaps at Tenerife North airport
Overlapping market
Combined market share (%)
Short-term car rental
services
Short-term leisure car
rental services
Tenerife North airport
[25-50]%
[0-25]%
(451) The market share of the merged entity on the market for short-term car rental
services would reach [25-50]%. On a plausible narrower market for short-term
leisure car rental services, the combined market share of the merged entity would
be [0-25]%.
(452) Significant competitors such as AutoReisen, Avis, Cicar, or Hertz are active in
the market for short-term car rental services and short-term leisure car rental
services at Tenerife North airport.
239
(453) Moreover no respondent to the market investigation raised any material concern
as to the effect of the Transaction at Tenerife North airport.
240
(454) Overall, given the market shares of the Parties, the presence of significant
competitors and the fact that no material concern was expressed during the market
investigation the Commission considers that the Transaction is unlikely to lead to
any significant competition concerns for the market for short-term car rental
services at Tenerife North airport, under any plausible segmentation.
Conclusion
(455) In view of the above, and considering all evidence available to the Commission,
the Transaction does not raise serious doubts as concerns the market for short-
term car rental services at Tenerife North airport, under any plausible
segmentation.
239
Form CO, Annex 27; and replies to Questionnaire 1 to market participants, question 4.5 and/or to a
Request for Information by the Commission.
240
Replies to Questionnaire 1 to market participants, question 29.2; replies to Questionnaire 2 to airport
managers, questions 15 and 18; and replies to Questionnaire 3 to customer associations, question 18.
76
4.3.4.33. Tenerife South airport
Table 65 - Overlaps at Tenerife South airport
Overlapping market
Combined market share (%)
Short-term car rental
services
Short-term leisure car
rental services
Tenerife South airport
[25-50]%
[25-50]%
(456) The market share of the merged entity on the market for short-term car rental
services would reach [25-50]%. On a plausible narrower market for short-term
leisure car rental services, the combined market share of the merged entity would
be [25-50]%.
(457) Significant competitors such as AutoReisen, Avis, or Hertz are active in the
market for short-term car rental services and short-term leisure car rental services
at Tenerife South airport.
241
(458) Moreover no respondent to the market investigation raised any material concern
as to the effect of the Transaction at Tenerife South airport.
242
(459) Overall, given the market shares of the Parties, the presence of significant
competitors and the fact that no material concern was expressed during the market
investigation, the Commission considers that the Transaction is unlikely to lead to
any significant competition concerns for the market for short-term car rental
services at Tenerife South airport, under any plausible segmentation.
Conclusion
(460) In view of the above, and considering all evidence available to the Commission,
the Transaction does not raise serious doubts as concerns the market for short-
term car rental services at Tenerife South airport, under any plausible
segmentation.
241
Form CO, Annex 27; and replies to Questionnaire 1 to market participants, question 4.5 and/or to a
Request for Information by the Commission.
242
Replies to Questionnaire 1 to market participants, question 29.2; replies to Questionnaire 2 to airport
managers, questions 15 and 18; and replies to Questionnaire 3 to customer associations, question 18.
77
4.3.4.34. Valencia airport
Table 66 - Overlaps at Valencia airport
Overlapping market
Combined market share (%)
Short-term car rental
services
Short-term leisure car
rental services
Valencia airport
[25-50]%
[25-50]%
(461) The market share of the merged entity on the market for short-term car rental
services would reach [25-50]%. On a plausible narrower market for short-term
leisure car rental services, the combined market share of the merged entity would
be [25-50]%.
(462) Significant competitors such as Avis, Centauro, Hertz or Sixt Enterprise are
active in the market for short-term car rental services and short-term leisure car
rental services at Valencia airport.
243
(463) Moreover no respondent to the market investigation raised any material concern
as to the effect of the Transaction at Valencia airport.
244
(464) Overall, given the market shares of the Parties, the presence of significant
competitors and the fact that no material concern was expressed during the market
investigation, the Commission considers that the Transaction is unlikely to lead to
any significant competition concerns for the market for short-term car rental
services at Valencia airport, under any plausible segmentation.
Conclusion
(465) In view of the above, and considering all evidence available to the Commission,
the Transaction does not raise serious doubts as concerns the market for short-
term car rental services at Valencia airport, under any plausible segmentation.
243
Form CO, Annex 27; and replies to Questionnaire 1 to market participants, question 4.5 and/or to a
Request for Information by the Commission.
244
Replies to Questionnaire 1 to market participants, question 29.2; replies to Questionnaire 2 to airport
managers, questions 15 and 18; and replies to Questionnaire 3 to customer associations, question 18.
78
4.3.4.35. Valencia downtown
Table 67 - Overlaps at Valencia downtown
Overlapping market
Combined market share (%)
Short-term car rental
services
Short-term leisure car
rental services
Valencia downtown
[0-25]%
[0-25]%
(466) The market share of the merged entity on the market for short-term car rental
services would reach [0-25]%. On a plausible narrower market for short-term
leisure car rental services, the combined market share of the merged entity would
be [0-25]%.
(467) Significant competitors such as Avis, Enterprise, Hertz or Sixt are active in the
market for short-term car rental services and short-term leisure car rental services
at Valencia downtown.
245
(468) Moreover no respondent to the market investigation raised any material concern
as to the effect of the Transaction at Valencia downtown.
246
(469) Overall, given the market shares of the Parties, the presence of significant
competitors and the fact that no material concern was expressed during the market
investigation, the Commission considers that the Transaction is unlikely to lead to
any significant competition concerns for the market for short-term car rental
services at Valencia downtown, under any plausible segmentation.
Conclusion
(470) In view of the above, and considering all evidence available to the Commission,
the Transaction does not raise serious doubts as concerns the market for short-
term car rental services at Valencia downtown, under any plausible segmentation.
4.4. Coordinated effects
(471) According to the Horizontal Merger Guidelines, coordination is more likely to
emerge in markets where it is relatively simple to reach a common understanding
on the terms of coordination. In addition, three conditions are necessary for
coordination to be sustainable. First, the coordinating firms must be able to
monitor to a sufficient degree whether the terms of coordination are being
adhered to. Second, discipline requires that there is some form of credible
deterrent mechanism that can be activated if deviation is detected. Third, the
reactions of outsiders, such as current and future competitors not participating in
245
Form CO, Annex 27; replies to Questionnaire 1 to market participants, question 4.6.
246
Replies to Questionnaire 1 to market participants, question 29.2; replies to Questionnaire 2 to airport
managers, questions 15 and 18; and replies to Questionnaire 3 to customer associations, question 18.
79
the coordination, as well as customers, should not be able to jeopardise the results
expected from the coordination.
247
(472) The Commission considers that the Transaction does not affect the market
structure in such a way that the conditions for coordination would be fulfilled
post-Transaction.
(473) First, at national level, the combined market shares of the Parties remain below
30% in the four overlapping countries. Even post-Transaction, the market for car
rental services remains characterised by the presence of a large number of
players.
248
Considering that the Transaction does only marginally increase the
level of concentration on the market for car rental services at national level, the
Commission considers it unlikely that the Transaction has a substantial impact on
the likelihood of coordinated effects.
(474) Second, car rental companies distribute a material part of their services to leisure
customers through brokers. The latter purchase large volumes from car rental
operators before re-selling their services to the end customers.
249
The significant
role played by brokers acting as resellers reduces the likelihood of coordination
for three reasons: (i) brokers have business models different from car rental
companies and are unlikely to adopt the same behaviour as them; (ii) by
negotiating prices and discounts bilaterally with car rental operators, brokers
make any monitoring of the intermediary prices agreed on with car rental
companies more difficult; (iii) brokers, which may have a strong countervailing
buyer power, may make coordination more unstable.
(475) Third, thanks to low barriers to entry, the entry or expansion of competitors not
participating in the coordination is relatively easy and could jeopardise any
previously existing coordination.
250
(476) Fourth, the demand for car rental services by leisure customers is not only
seasonal but also volatile, as is the traffic at airports where those services are
provided. The prices of those services are also regularly modified based on the
yield management practices of car rental companies, creating an unstable
economic environment less prone to coordination.
(477) In view of the above, the Commission considers that the Transaction would not
change the nature of competition in such a way that car rental operators could
coordinate and raise the price for their services.
(478) Therefore, considering all evidence available to the Commission, the Transaction
does not raise serious doubts as concerns the coordinated effects on the market for
short-term car rental services, under any plausible segmentation.
247
Horizontal Merger Guidelines, paragraph 41.
248
See section 4.1.1 for a detailed description of the market structure.
249
See section 4.1.3 for a detailed description of the role played by brokers.
250
See section 4.1 for a detailed description of the market structure, the role of brokers, and the barriers to
entry.
80
5. CONCLUSION
(479) 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.
For the Commission
(Signed)
Margrethe VESTAGER
Member of the Commission
