Andreas Heinemann: Keeping competition policy up to date - Schellenberg Wittmer
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Concurrences REVUE DES DROITS DE LA CONCURRENCE | COMPETITION LAW REVIEW Andreas Heinemann: Keeping competition policy up to date Interview l Concurrences N° 2-2022 www.concurrences.com Andreas Heinemann President Swiss Competition Commission, Bern Interview conducted by Dr Pranvera Këllezi, Attorney at law in Geneva and member of the Swiss Competition Commission, and David Mamane, Partner, Schellenberg Wittmer, Zurich
Interview
Andreas Heinemann
Andreas Heine-
constitutes a violation of the publisher's rights and may be punished by up to 3 years imprisonment and up to a € 300 000 fine (Art. L. 335-2 Code de la Propriété Intellectuelle). Personal use of this document is authorised within the limits of Art. L 122-5 Code de la Propriété Intellectuelle and DRM protection.
Ce document est protégé au titre du droit d'auteur par les conventions internationales en vigueur et le Code de la propriété intellectuelle du 1er juillet 1992. Toute utilisation non autorisée constitue une contrefaçon, délit pénalement sanctionné jusqu'à 3 ans d'emprisonnement et 300 000 € d'amende (art.
President
L. 335-2 CPI). L’utilisation personnelle est strictement autorisée dans les limites de l’article L. 122 5 CPI et des mesures techniques de protection pouvant accompagner ce document. This document is protected by copyright laws and international copyright treaties. Non-authorised use of this document
Swiss Competition Commission, Bern
Interview conducted by Dr Pranvera
Këllezi, Attorney at law in Geneva and
member of the Swiss Competition mann: Keeping
competition
Commission, and David Mamane,
Partner, Schellenberg Wittmer, Zurich
policy up to date
Since 2019 Last year marked the 25th anniversary of the current Swiss Cartel Act and the
Member of the Bureau of the OECD organizational setup of the COMCO. What changed with the Cartel Act of 1995
Competition Committee that came into force in 1996? What are, in your view, the most important mile-
stones over the last twenty-five years?
We have had competition laws before 1996, but they were full of loopholes, and
Since 2011 the old institutions did not have the necessary powers. The Swiss economy was
Member of the Swiss Competition characterized by a large number of cartels that were disappearing only gradually.
Commission, since 2012 as Vice- The Cartel Act of 1995 brought a paradigm shift: For the first time, the goal of
President, since 2018 as President the law was to protect effective competition. Precise rules have been formulated,
and it is not possible any longer (except for the government) to justify restrictive
behaviour based on public interest considerations as was the case before.
Since 2001 A preventive merger control has been introduced. And, most importantly, the
Professor at the Universities of
COMCO has been given the competence to take its own decisions. Before, you
Lausanne and Zurich with a focus
had to ask the ministry, which then decided whether to act. This considerably
on competition law
weakened enforcement. However, even with the Cartel Act of 1995, one element
was still missing. The law did not provide for fines against infringements. Firms
could only be fined for not complying with a COMCO decision. In 2004, fines
for competition law violations as well as a leniency system were introduced. Since
then, public enforcement in Switzerland has been state of the art and follows the
leading enforcement model in Europe—i.e. the administrative system where the
authority has the competence to take decisions and to impose fines, under the
control of the courts, of course.
Milestones have been the procedures against hardcore cartels, including but not
limited to the construction sector. The large number of procedures against bid
rigging in the Canton of Grisons has attracted great public attention. Another
series of cases concerned restrictions of parallel imports into Switzerland.
The GABA, BMW and Nikon cases set out the principles based on which the
COMCO fights against the foreclosure of Swiss markets to foreign markets. These
decisions, all confirmed by the courts, have had important practical consequences.
In the past, so-called European Economic Area (EEA) clauses were common in
European distribution contracts. They prohibited exports to countries outside
the EEA and thus also to Switzerland. Today, contracts have been adapted so
that exports not only to EEA countries but also to Switzerland are allowed. And
finally, it is worth mentioning the proceedings against network monopolies in
infrastructure: Twenty years ago, the COMCO opened up electricity markets, and
in 2020 we did the same in the gas sector.
Concurrences N° 2-2022 I Interview I Andreas Heinemann: Keeping competition policy up to date 13Is Switzerland still the land where the cartelists meet You have been a member of the COMCO since
constitutes a violation of the publisher's rights and may be punished by up to 3 years imprisonment and up to a € 300 000 fine (Art. L. 335-2 Code de la Propriété Intellectuelle). Personal use of this document is authorised within the limits of Art. L 122-5 Code de la Propriété Intellectuelle and DRM protection.
without being disturbed? What are the most recent focal 2011 and have been the president of the COMCO
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points of the COMCO, and what are your main concerns since 2018. What do you consider as your biggest
for the near future? accomplishments, and is there anything that you regret?
Thanks to the vigorous enforcement of the law, including The work of competition authorities is teamwork.
the possibility to impose fines, the attitude towards cartels Accomplishments have to be attributed to the whole
has considerably changed. Firms and their associations authority, in our case both to the Secretariat with its
have adopted a competition culture, not only in their full-time professionals and to the Commission, the
mission statements and their codes of conduct but also in decision-making panel, composed of experts in law and
their actual behaviour. So, cartelists no longer feel at ease economics. The greatest achievement of the authority
in Switzerland. However, this does not mean that there has been the successful defence of our decisions in
are no more cartels in the country. Therefore, one of the court in most cases. This has not only implemented the
focal points of the COMCO remains the fight against legislation, but has profoundly shaped Swiss competition
hardcore cartels. Another focus is the policy against law. What I have especially promoted is the adaptation of
absolute territorial protection in distribution agreements our practice to the challenges of our time. It is essential
sealing off Switzerland and thus contributing to the to keep competition policy up to date. Therefore, I have
higher price level that we observe in Switzerland. My been very much interested in the mutual relationship
main concern for the future is that the successful practice between competition law, on the one hand, and questions
of the COMCO in these areas may be put at risk by a of innovation, digitization and sustainability, on the
current legislative proposal. other hand. Moreover, I have always emphasized the
necessity of basing competition law on a solid economic
foundation. However, this does not mean that in each
You are alluding to a current draft legislation that plans and every case, a full-fledged effects-based approach has
to reintroduce the need to assess anti-competitive
to be pursued. Modern competition laws are based on a
effects for all types of agreements. The bill is a reaction
mix of form-based elements providing for legal security
to the GABA judgment of the Federal Supreme
Court (FSC), according to which anti-competitive and effects-based elements ensuring economic coherence.
effects do not have to be considered in assessing An example is EU competition law with its distinction
certain types of agreements (e.g. price restrictions between restrictions by object and by effect and the
or prohibition of parallel trade). The ruling was criticized availability of an efficiency defence.
by commentators as being too broad and formal.
The legislature has entrusted us
What do you think of the legislative proposal?
This legislative proposal is a major threat to the with the task of combating the foreclosure
effectiveness of the Cartel Act. It is based on the
argument that the GABA judgment has impaired legal
of Swiss markets.
certainty and that cooperation between companies is
I regret that I do not seem to have conveyed this message
made more difficult. In the parliamentary debate, it was
sufficiently. The legislative proposal just mentioned,
also argued that consortia and purchasing groups were in
adopted by the Swiss Parliament, aims at abolishing the
danger. None of these arguments is correct: The GABA
category of restrictions by object. If this becomes law,
decision has not weakened legal certainty, but, on the
legal certainty will be seriously affected. The proponents
contrary, has strengthened it. The twists and turns that
of this motion overlook the fact that the economics of
have been taken in interpreting the requirement of a
competition law have to take into consideration not only
“significant” restriction of competition are breathtaking.
substantive law but also enforcement, including its costs
In the GABA decision, the Federal Supreme Court has
and duration. The COMCO will bring these points of
restored legal certainty by returning to the will of the
view into the debate.
legislator, who construed “significance” as a de minimis
rule, comparable to the condition of “appreciability” in
EU competition law. Cooperation between companies is Your academic career has given you a very broad
not made more difficult. The COMCO does not get tired knowledge of international competition law
of pointing out the legality of consortia and purchasing developments, and you regularly also publish on EU
groups. If doubts remain, the legislator could introduce competition law. How has this influenced your work with
specific rules on consortia and purchasing groups. The the COMCO? Conversely, do you think that there are any
proposal as it is on the table now would strike at the specific Swiss law approaches that should be of interest
to foreign competition authorities?
heart of current enforcement. Cartelists and firms sealing
off Swiss markets would try to defend themselves with Swiss competition law is strongly influenced by EU law,
the argument that they are small fry or that the proven but to varying degrees. The prohibition of the abuse
restrictions only had a small market coverage. The of a dominant position closely follows the EU model,
deterrent effect of the law and legal certainty would be while merger control is based on a different approach.
compromised. The rules on restrictive agreements are constructed
differently but aim at leading to the same results as EU
competition law. For example, the FSC has decided that
the rules on vertical agreements are “materially identical”
with EU law. We are following the developments in the
14 Concurrences N° 2-2022 I Interview I Andreas Heinemann: Keeping competition policy up to dateEU closely, and this has been very fruitful for our work. what will be needed for the application of the DMA.
constitutes a violation of the publisher's rights and may be punished by up to 3 years imprisonment and up to a € 300 000 fine (Art. L. 335-2 Code de la Propriété Intellectuelle). Personal use of this document is authorised within the limits of Art. L 122-5 Code de la Propriété Intellectuelle and DRM protection.
Moreover, thanks to the Cooperation Agreement on Even without a “Swiss DMA,” traditional competition
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competition matters with the EU, in force since 2014, law could be adapted to the specific challenges of the
we can even exchange confidential information under platform economy, either by legislative changes or by
certain conditions. However, these influences should not application of the general rules. In Switzerland, short
obscure the fact that Swiss competition law has its own laws with rather broad concepts are given preference. For
objectives and features. For example, the legislature has example, there are no explicit rules on provider liability
entrusted us with the task of combating the foreclosure as provided for in the EU e-Commerce Directive or in
of Swiss markets. We, therefore, do not hesitate to the draft DSA. Authorities and courts are entrusted with
oppose territorial protection even more strictly than EU applying the existing rules to the new phenomena.
competition law already does.
Regarding the topics covered by the DMA, it will be
Modern competition laws are based on the task of the COMCO to deal with them by applying
a mix of form-based elements providing
general competition law concepts. I could imagine the
notion of abuse being opened up to the behaviours
for legal security and effects-based banned by the DMA, but in a competition law way,
elements ensuring economic coherence. i.e. after a careful analysis of the single case and taking
into account legitimate business reasons. The COMCO
Regarding developments of Swiss competition law that has already dealt with competition law problems of
could be of interest abroad, I would like to stress the cases GAFAM. We regularly contact platform companies
where we have broken new ground. For example, in the when a competition law procedure is opened in the EU
Swatch case on an obligation to supply mechanical watch in order to ensure that the solution found in the EU will
movements to competing watch manufacturers under the be applied to Switzerland as well. And we have our own
abuse of dominance rules, we created a “phasing out” GAFAM cases. For example, the Swiss mobile payment
model that allowed the dominant firm to stop deliveries app TWINT faced problems on iPhones because Apple
after six years. The idea was to create incentives for Pay, in some cases, automatically launched when users
market participants to build up an alternative production tried to pay with TWINT. We agreed with Apple that
of watch movements. According to our observations, a technical solution is offered to TWINT in order to
this strategy has been successful. Moreover, innovation guarantee an undisturbed payment process.
has been promoted since the market has generated
watch movements with new features. The example shows
It would be an excellent side effect if
private enforcement, which is totally
that it may be fruitful to limit in time an obligation to
supply imposed on a dominant firm because market
participants thus know that they cannot rely on supplies unsatisfactory in Switzerland today,
by the dominant firm forever. Another interesting case is were fuelled by the new concept of relative
Hors-Liste. Here, the COMCO, confirmed by the FSC, market power.
fined manufacturers for vertical price fixing because
their allegedly non-binding price recommendations were
followed in the market widely. The decision has been This year the Swiss Parliament has reinforced
criticized by some observers because no pressure and no the concept of economic dependence, and the
incentives in order to respect the recommended prices new rules entered into force on 1 January 2022.
were involved. What the critics overlook is that the price What will be the main challenges for the COMCO
when investigating and assessing this new piece
recommendations were constantly conveyed to retailers
of legislation?
by independent third parties via an electronic database
and appeared as soon as retailers scanned the barcode Explicit rules on economic dependence and relative
of the product. Apparently, the COMCO was the first market power are new to Swiss law. It will be an important
to deal with a vertical price-fixing scenario in the digital task for the COMCO to unfold these rules. On the one
economy and has developed new “plus factors” that hand, it has to be clarified under which conditions one
transform a non-binding price recommendation into company is dependent on another. On the other hand,
illegal resale price maintenance. it has to be worked out which behaviour is prohibited
for a firm with relative market power. Contrary to other
jurisdictions, all the general rules of conduct for dominant
The EU is about to introduce new legislation to ensure firms apply. It will be challenging to develop what sense
contestability of digital markets (DMA and DSA).
these prohibitions have in the context of relative market
Do you think Switzerland needs a similar legislation?
power. In order to create a common starting point, we
If not, how does the COMCO deal with market power
in the digital economy? Have there been examples have published on our website an explanatory note and
of procedures against the GAFAM, and will COMCO a form for filing a complaint. In this context, I would
get inspired by the material rules in the DMA? like to stress the following point: The application of
the new rules is not in the exclusive competence of
Small and medium-sized jurisdictions do not have the the COMCO. Private litigation is supposed to play a
capacity to set up a new organism dealing with ex ante major role. The COMCO would like to make guiding
regulation of the world’s leading platforms. The number decisions and to contribute its expertise to the civil
of employees of our entire authority is smaller than proceedings through its amicus curiae function. It would
Concurrences N° 2-2022 I Interview I Andreas Heinemann: Keeping competition policy up to date 15be an excellent side effect if private enforcement, which is Often, the positive effects of functioning
markets are not directly observable.
constitutes a violation of the publisher's rights and may be punished by up to 3 years imprisonment and up to a € 300 000 fine (Art. L. 335-2 Code de la Propriété Intellectuelle). Personal use of this document is authorised within the limits of Art. L 122-5 Code de la Propriété Intellectuelle and DRM protection.
totally unsatisfactory in Switzerland today, were fuelled
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L. 335-2 CPI). L’utilisation personnelle est strictement autorisée dans les limites de l’article L. 122 5 CPI et des mesures techniques de protection pouvant accompagner ce document. This document is protected by copyright laws and international copyright treaties. Non-authorised use of this document
by the new concept of relative market power. At best,
civil courts could take over completely after some leading Therefore, the contribution of competition
cases and enough experience. law to general well-being is frequently
underestimated.
In particular, the new rules would force suppliers
outside of Switzerland to provide Swiss buyers with If we look at COMCO’s action over the years,
products at the same price and market conditions in any the COMCO has built a two-fold tradition, on the
country worldwide. Does the mere fact that a product is one hand, in regulating markets—e.g. in the watch or
commercialized at a higher price in Switzerland than in the card payment industry—and, on the other hand,
any other country already imply a position of economic in using competition law to deregulate markets—e.g.
dependence? in the electricity and gas supply industries. What is the
right blend in your view of regulation and competition,
Relative market power and abusive behaviour are two
and is the competition law regime always a good basis
prerequisites that have to be distinguished. It is true that for regulating markets?
a new rule in the law declares abusive the restriction of
the opportunity for buyers to purchase certain goods In Switzerland, we have an approach towards regulation
or services at foreign prices. However, this rule only that differs considerably from the situation in the
applies to firms with relative market power. Therefore, EU: The danger of excessive interventionism by the
relative market power has to be proved separately. One regulator is emphasized. This leads to a preference
of the reasons to introduce the new concept was to for self-regulation and negotiated solutions. It is only
create a level playing field between domestic and foreign when decentralized solutions fail that state regulation is
manufacturers. Swiss firms shall not be disadvantaged considered necessary, and then only ex post and not ex
vis-à-vis their foreign competitors by having to pay higher ante like in the EU. The reluctance to regulate is regularly
factor prices. Therefore, one could think about assuming accompanied by the argument that any problems that
dependence when the access to cheaper input factors may arise could be solved by general competition law.
abroad is indispensable in order to create or maintain Thus, the COMCO has an additional task: We have to
international competitiveness. On the other hand, this ensure competition in sectors that in other jurisdictions
would go beyond the concept of economic dependence in would be liberalized and supervised by a specific sector
other jurisdictions. The COMCO will deal with this and regulation. Examples of liberalization by competition
many other questions as and when relevant complaints law concern the electricity and gas supply industries.
arrive. An example of supervision by competition law is the card
payment industry: In the EU, interchange fees for card-
based payment transactions are the object of detailed
It can also be noted that the courts had to deal with regulation. As we do not have that, it is the COMCO’s
a number of procedural aspects of the investigations job to intervene against excessive tariffs.
by the COMCO. Would you be in favour of clarifying
procedural rules in a procedural act for competition law
Our case law in the watch industry is different. Here, we
investigations?
had to deal with a classical question of competition law:
Procedural issues occupy the authority intensively. Under which conditions is a dominant firm under a duty
The COMCO has developed best practices for example to supply? In this case, as already mentioned, we have
regarding the right to be heard, nemo tenetur, access developed an innovative phasing-out model. According
to files, the conduct of dawn raids and the publication to our observations, this approach has been successful.
of decisions and case reports. Our decisions have been In sum, in a jurisdiction characterized by a prudent
confirmed by the courts in most cases, sometimes approach to regulation, the competition authority is
corrected. Of course, procedural rules could be laid charged with several tasks: Not only do the general
down in more detail. However, one should not have too goals of competition law have to be fulfilled, but also the
high expectations. Even if procedural rules are further absence of regulatory law has to be compensated. In my
elaborated, problems in practice are often so specific that view, the COMCO is well up to this multitasking.
you will not find the answer in the law, no matter how
detailed it has been drafted. Just to give one example: We
had to deal with whether former directors can be heard as
It belongs to the DNA of competition law
witnesses (under a duty to testify) or as parties (with the to have its rules applied equally to domestic
right to refuse to testify). The FSC eventually confirmed and foreign companies.
that former directors are witnesses. I doubt if such a
detail would be part of new procedural rules. Against
You have a long career in competition law as an
this backdrop, the added value of a specific procedural
academic and enforcer. How were you introduced
act would be limited.
to competition law? Have your views changed
with the time on any position on competition law?
Do you see a change in the perception of the public
and politicians towards competition law?
16 Concurrences N° 2-2022 I Interview I Andreas Heinemann: Keeping competition policy up to dateI studied both law and economics in the 1980s, before you cannot show clear and tangible improvements, or
constitutes a violation of the publisher's rights and may be punished by up to 3 years imprisonment and up to a € 300 000 fine (Art. L. 335-2 Code de la Propriété Intellectuelle). Personal use of this document is authorised within the limits of Art. L 122-5 Code de la Propriété Intellectuelle and DRM protection.
the fall of the Iron Curtain. In that era, newspapers, to fight anti-competitive reforms if you cannot present
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L. 335-2 CPI). L’utilisation personnelle est strictement autorisée dans les limites de l’article L. 122 5 CPI et des mesures techniques de protection pouvant accompagner ce document. This document is protected by copyright laws and international copyright treaties. Non-authorised use of this document
politicians, scholars and the general public were still direct harm. For example, a specific characteristic of
discussing intensively the comparison between market our time is protectionist tendencies, also in competition
economy and centrally planned economy, between Adam policy. In Switzerland, a “reimport clause” was on the
Smith and Karl Marx, so to speak. In economics, the table that would have exempted domestic manufacturers
history of economic thought was my favourite subject. from certain consequences of the relative market power
I was fascinated to see how Walter Eucken had dissected rules. Eventually, this proposal did not prevail, but that
the weaknesses of laissez-faire, on the one hand, and was a close call. I think that it belongs to the DNA of
central planning, on the other hand. The ordoliberals competition law to have its rules applied equally to
opted for a market economy based on competition and domestic and foreign companies. Competition authorities
therefore strongly condemned cartels. Convinced by should use their advocacy role in order to inform the
these insights, I turned to competition law and policy public debate in this sense.
at an early stage. I think that this subject is more than
just an area of law (although I am aware that every
specialist feels this way about her field). The decision on What would you recommend to a young student or
practitioner who is interested in competition law?
how the economy should be organized has far-reaching
Should she pursue a career in academics, in the
consequences, also for the flourishing of democracy. The
authority or private practice, or a blend of all that?
most important extension of my view on competition law
occurred in the 1990s when I worked on a book dealing I would recommend that students start already at
with the relationship between competition law and university, focusing not only on competition law but
intellectual property protection. Fields that had been seen also on neighbouring fields like intellectual property
as conflicting turned out to share the same goal, namely, protection, public procurement, international trade law,
to foster innovation. This dynamic interpretation has had and the internal market law of the European Union,
a strong impact on my concept of competition law. no matter if they live in or outside this area. The next
step could be an internship at the authority or with a
The public perception of competition law varies over law firm specialized in competition law. Then the young
time. However, there is one constant. The market colleague will see if the fascination lasts. I am sure that
mechanism works in a decentralized way. Often, the this will be the case for many who immerse themselves
positive effects of functioning markets are not directly in this matter. Competition law is the field where law
observable. Therefore, the contribution of competition and economics meet in the closest way. It also raises
law to general well-being is frequently underestimated. fundamental questions about economic policy. And not
Reforms are only successful if the resulting benefits to forget, competition law is a very international subject.
are clearly illustrated. For example, the introduction During your career, you will come into contact with
of the concept of relative market power into Swiss law, many international issues and meet people from all over
mentioned above, was due to the “Fair Price Initiative,” the world. The number of related networks is impressive.
which held out the prospect of lower prices in Switzerland. As a result, you will rethink your own views all the time.
It is more difficult to push pro-competitive reforms if What could be more enriching? n
Concurrences N° 2-2022 I Interview I Andreas Heinemann: Keeping competition policy up to date 17Concurrences
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