Across Europe competition authorities are increasingly targeting M&A transactions that fall below traditional turnover thresholds. The European Commission (EC) and several National Competition Authorities (NCAs) are expanding their toolkits through call-in powers, post-closing antitrust enforcement and expansive interpretations of existing frameworks to close the gap around below-threshold deals in fear of missing out on so-called killer or roll-up acquisitions. While killer acquisitions mean large established market players buying nascent competitors to eliminate future competition, roll-up acquisitions refer to a company systematically taking over small competitors to achieve consolidation of a fragmented market.

BLOMSTEIN starts the New Year with three celebrations: Elisa Theresa Hauch is promoted to the Antitrust Partnership; Konstantin Kuhle, former Member of the German Bundestag, joins as Special Counsel, and Bruno Galvão is appointed Counsel.

On Wednesday, 3 December 2025, the responsible EU Commissioner Maroš Šefčovič, together with the High Representative for Foreign Affairs and Security Policy Kaja Kallas, presented the Joint Communication on Strengthening Economic Security to the public (JOIN(2025) 977 final). Originally referred to as a “doctrine,” the communication is intended to consolidate previous efforts to promote economic security and, according to Šefčovič, shift them “into a higher gear.” The Communication now outlines various more substantial measures.

The recent “Nexperia crisis” sparked an initiative by the German Automotive Industry Association (VDA) which created a platform enabling carmakers and suppliers to offer and request leftover semiconductor stock. The platform is supposed to mitigate acute chip shortages (notably involving components from Nexperia), which threatens vehicle production in Germany, by effectively connecting players across the industry and efficiently matching supply and demand. The Federal Cartel Office (FCO) gave his blessing with President Andreas Mundt stating that the information exchange implied could improve the allocation of scarce chips and help delay production cuts, ultimately benefiting both the industry and consumers. The VDA semiconductor platform follows a pattern of industry-led digital trading platforms that have sought and received antitrust approval in Germany. This case is interesting as the FCO continues to show its openness for innovative platforms that improve market efficiency, provided certain reliable safeguards are built-in to prevent anti-competitive information exchanges.

On 21 October 2025, the European Commission published a proposal to amend the EU Deforestation Regulation (EUDR). The proposal came as a surprise, particularly in light of speculation that the Commission would seek to suspend the applicability of the EUDR for an additional 12 months. In a letter dated 23 September 2025 from the EU Environment Commissioner Roswall, it was ventilated the idea of postponing the implementation of the EUDR, citing technical challenges with the electronic system responsible for issuing the Due Diligence Statements (DDS) – a precondition for placing in-scope products on the EU market. The Commission acknowledged that the system may not be fully operational by the current deadline of 30 December and noted that it cannot guarantee the platform will be able to handle the expected volume. Instead of moving forward with this first approach, the Commission proposed further amendments to the text while introducing a six-month grace period during which companies would not be subject to checks or potential penalties. The proposal will most likely go to a first vote in the European Parliament either on 12-13 November or during the session of 24-27 November. The final vote, following the conclusion of the trilogue negotiations, is expected to take place during the plenary session of 15-18 December, just days before the EUDR is scheduled to begin applying on 30 December, making it a very tight timeline.

On 23 October 2025, the European Commission adopted another set of sanctions against Russia and Belarus. The new package targets key sectors such as energy and finance, the military industrial base, special economic zones, as well as enablers and profiteers of Russia’s aggression against Ukraine. It is noticeable that the new measures increasingly target third country companies outside of Russia. The EU legislator is trying to further reduce the risk of circumvention of the restrictions by extending the scope of important restrictions.

After the expiry of the 30-day deadline triggered by the snapback mechanism against Iran, the UN and the EU immediately extended their sanctions significantly. This adds a further piece to the mosaic of international sanctions, which is often already perceived as complex by business operators.

BLOMSTEIN is becoming (even) more international: On 1 October 2025, we are expanding our European presence and will open an office in Brussels. With BLOMSTEIN already being strongly connected across Europe and globally, the new Brussels office marks the natural next step in our international footprint and strengthens our proximity to European institutions. 

The European Union (EU) and the United States (US) have recently announced a new transatlantic trade initiative, labelled the United States-European Union framework on an agreement on reciprocal, fair and balanced trade, that aims inter alia to abolish tariffs on US industrial goods. While the agreement is currently only a political declaration without binding legal force, it represents a significant policy signal. Once implemented, it could reshape competition in the EU market not only for US companies, but also for exporters from third countries such as Brazil, India, Japan, South Africa, or South Korea.

BLOMSTEIN advised Opta Group LP, a portfolio company of Speyside Equity Advisors (Speyside), and a leading supplier of performance materials and solutions in the molten metal, infrastructure, and specialty chemical industries, on FDI and merger control aspects relating  the acquisition of the assets of the majority of the business operations of m-tec Group, a company previously operating in Wesel, Germany.