Compagnie Générale Maritime v. Commission

Competition - antitrust - horizontal cooperation agreements

The Court of Justice of the European Union has not in any way confirmed a restrictive interpretation of the “consumer welfare” standard. On the contrary, the Court has notably opted for a broader approach. In Compagnie Générale Maritime, it held that “regard should naturally be had to the advantages arising from the agreement in question, not only for the relevant market [...] but also, in appropriate cases, for every other market on which the agreement in question might have beneficial effects, and even, in a more general sense, for any service the quality or efficiency of which might be improved by the existence of that agreement […] without requiring a specific link with the relevant market” (§ 343).