Chapter Columbia

Columbia Company, which manufactures machine tools, had the following transactions related to plant assets in 2014. Asset A: On June 2, 2014, Columbia purchased a stamping machine at a retail price of $12,000. Columbia paid 6% sales tax on this purchase. Columbia paid a contractor $2,800 for a specially wired platform for the machine, to ensure noninterrupted power to the machine. Columbia estimates the machine will have a 4-year useful life, with a salvage value of $2,000 at the end of 4 years. The machine was put into use on July 1, 2014.Asset B: On January 1, 2014, Columbia, Inc. igned a fixed-price contract for construction of a warehouse facility at a cost of $1,000,000. It was estimated that the project will be completed by December 31, 2014. On March 1, 2014, to finance the construction cost, Columbia borrowed $1,000,000 payable April 1, 2015, plus interest at the rate of 10%. During 2014, Columbia made deposit and progress payments totaling $750,000 under the contract; the we ighted-average amount of accumulated expenditures was $400,000 for the year.The excess-borrowed funds were invested in short-term securities, from which Columbia realized investment revenue of $13,000. The warehouse was ompleted on December 1, 2014, at which time Columbia made the final payment to the contractor. Columbia estimates the warehouse will have a 25-year useful life, with a salvage value of $20,000. Columbia uses straight-line depreciation and employs the â€Å"half-year† convention in accounting for partial-year depreciation. Columbia's fiscal year ends on December 31 . Instructions (a) At what amount should Columbia record the acquisition cost of the machine? b) What amount of capitalized interest should Columbia include in the cost of the warehouse? (c) On July 1, 2016, Columbia decides to outsource its stamping operation to Medek, Inc. As part of this plan, Columbia sells the machine (and the platform) to Medek, Inc. for $7,000. What is the impact of this dispo sal on Columbia's 2016 income before taxes? Solution (a) Historical cost is measured by the cash or cash equivalent price of obtaining the asset and bringing it to the location and condition for its intended use.For Columbia, this is: Price $12,000 Tax 720 Platform 2,800 Total $15,520 Since Columbia has outstanding debt incurred specifically for the construction project, in an amount greater than the weighted-average accumulated expenditures of $400,000, the interest rate of 10% is used for capitalization purposes. Capitalization stops upon completion of the project at December 31, 2014. Therefore, the avoidable interest is $40,000, which is less than the actual interest.The investment revenue ot is irrelevant to the question addressed in this problem because such interest earned on the unexpended portion of the loan is not to be offset against the amount eligible for capitalization. (c) The income effect is a gain or loss, determined by comparing the book value of the asset to the disposal value: Cost $1 5,520 Less: Accumulated depreciation 6,760* Book value of machine and platform 8,760 Less: Cash received for machine and platform 7,000 Loss before income taxes $ 1,760 hyear $1,690 2014. full year 3,380 2015. 2016. ? h year 1,690

Patriots resist British laws and policies Essay

After the Seven Years War, Britain’s hold on the colonies was established. The Crown then began to impose laws on the colonies to offset the losses it incurred in securing Britain’s hold. Among these laws were the Sugar Act, which hiked the non-British goods import duties, and the Currency Act, which prohibited printing of currency, were met with resistance in America. Other laws and policies governing taxation and trade were also imposed on the colonies. However, many people in the colonies did not favor the British laws. Three strategies they used to foil British control are: organized demonstrations, non-importation of British goods, and terrorizing tax collectors. The Sons of Liberty was established as a secret organization with the purpose of terrorizing those who were tasked as tax collectors under the Stamp Act. The ploy was successful since the tax collectors all quitted even before the Stamp Act was implemented. Without collectors and with protests, the colonists were successful in getting the Act repealed. The non-importation was the most successful strategy for the patriots. It worked very well for a few years. It made Britain reconsider its laws and repeal the Stamp Act. The Crown had a lot to lose with the colonies’ imports. However, it soon declared that the colonies can only trade with Great Britain and no other country. The organized protests were also successful at times but led to a disastrous event when people were killed in Boston after a skirmish with British soldier. But the event was used by radicals as a propaganda against the British colonizers. The radicals incited protests and recruited men to their cause. The public protests helped to mask the formation of an armed movement that would oppose Britain’s right to the colonies.

The Life of Edgar Allan Poe Essay Example | Topics and Well Written Essays - 750 words

The Life of Edgar Allan Poe - Essay Example His father's name was David Poe (1784-1810) while his mother's was Elizabeth Arnold Hopkins (1787-1811) (Quinn 1997). He was born on January 19, 1809. A year after his birth, his father died, then a year later, her mother followed. Left as an orphan, Edgar was taken in by Frances and John Allan, a wealthy merchant in Richmond, Virginia. In 1815, Poe went with the Allans to England where he studied in Chelsea. Five years later, he went back to study at the University of Virginia. In this school he considered Latin and poetry. In addition, Edgar was an active and athletic student, joining activities such as swimming and acting. A few years later, Edgar and John had a falling out due to Edgar's debts and lack of responsibility. Unable to support his self, he enlisted in the U.S. army where he served for two years. In 1827, Edgar Poe published his first book, Tamerlane and Other Poems. When Edgar's foster mother died in 1827, he had a brief reconciliation with Allan and later entered West Point Military Academy but was dismissed after one year. In 1831, the same year his Poems were published, Edgar lived in with his aunt Maria Clemm in Baltimore. Eventually, he married Maria Clemm's daughter, Virginia Eliza, in 1836, who was just a girl of thirteen. The only completed novel of Poe, The Narrative of Arthur Gordon Pym was published in 1838. The story is about a Nantucket stowaway looking for adventure but the novel soon turns to a chilly story of murder and cannibalism. (Merriman 2007) It was the years succeeding his marriage that the financial strains started to set in. The Panic of 1837 marking the "close of one epoch in our industrial history, and the beginning of a new era. It engulfed all classes and all phases of economic toils; and for seven long years the people of the land struggled to free themselves from its oppression," (McGrane). Aside from professional and personal struggles, Poe was also almost always in economic distress; frequently loaning and making literary hack works (Whalen 1999). It was these problems that made him understand the "sad poverty and the thousand consequent contumelies and other ills which the condition of the mere Magazinist entails upon him in America - where more than in any other region upon the face of the globe to be poor is to be despised." After their marriage came the string of years of writing. It was in 1841 that the first detective story was ever written. The title was The Murders in the Rue Morgue. Their last residence was a cottage in the Fordham section of the Bronx. In 1847, Virginia died, Edgar Allan Poe was deeply saddened by the loss of his wife. Due to this, he frequently directed his attention to alcohol and was reportedly becoming more erratic. A year after Virginia's death, he rekindled his affair with his childhood sweetheart in Richmond, Elmira Royster. In able to raise funds to start his own magazine (to be called Stylus) in 1849, Poe went on a poetry and lecture reading tour. But his hopes of starting his own magazine was never realized because of his sudden mysterious death on the 7th of October of that same year. (Merriman 2007) There are several different theories that have been proposed concerning his death. Others say he died of alcoholism while others suggest different diseases. Still, others imply that Poe did not suffer a natural death but instead was murdered. For the past decades and until now, what really happened to Edgar Allan

Compare and Contrast Research Methods Essay Example | Topics and Well Written Essays - 1500 words - 2

Compare and Contrast Research Methods - Essay Example Similarity of data sets used in meta-analysis is in terms of the studies addressing the same research question. Meta-analysis method uses the characteristics of data to make conclusions rather than making general conclusions about data. The method applies when a research deals with quantitative data. Use of secondary data poses the risk of unreliability of meta-analysis. Therefore, researchers need to test the accuracy of secondary data before using it to make conclusions in a research (LaValley, 2005). Other methods of research Questionnaire-Based survey is another research method used in statistics. The method involves isolating samples from a population, obtaining data from the samples and making conclusions about the population based on the sample. Questionnaire method uses questions to obtain data from the field. The method translates research objectives into questions. Focus group is another qualitative research method that goes beyond explaining the quantitative aspects of dat a. Focus group refers to all participants who take part in discussions about a research. This method applies for open-ended research studies that cover a wide range of objectives (Jowett & O’Toole, 2006). Historical research method involves studying what happened in the past and identifying the push factors for these past events. Historians use this method to explain past events by applying scientific skills, conscience and other tools of analysis (Methods Network, 2011). Observation method involves humans using their senses to determine the events taking place and their effects. Observation method can be direct or indirect. Direct observation involves active actions of the researcher to collect data while indirect observation involves collecting data from recorded information, for example, from movies (Management Study Guide, 2012). Action research method involves participation of a group of people who suffer from a similar problem. Attempts to solve their problem reveal the best ways of solving such problems. Applications of research methods in the business sector Historical research is the research method that most business organizations use in their operations. This is because the method involves reviewing past data in the history of an organization. Scholars will be interested in determining the impacts of past events on their performance. The businesses must use past data to identify different variables that affect their performance. Researchers can also use questionnaire method to assess the impact of various strategies on employees and other members of the organizations. Employees answer the questions that the management asks through the questionnaires. The answers help the management in determining whether certain policies are successful in the research. Researchers use focus group method to explain their financial statements. This research method explains quantitative data to give it extra meaning. Businesses explain their financial statements by giving reasons that lead to a loss or profit. Businesses use observation method in observing trends in a population including consumption of goods and services. Action research method is the result of participation of members who suffer from the same problems. Most researchers use action research method to determine the impacts of change among members of the organizations. Change affects all members of the organization and their attempts to deal with the effects reveal the best w

DISASTER PREPARATION Research Paper Example | Topics and Well Written Essays - 750 words

DISASTER PREPARATION - Research Paper Example If there are risk factors that could result into their own illness, that of their family members as well as those that they come into contact with. In the event of violence, they are encouraged to think about the available security services that are available at the scene of the disaster and this ensures their own safety and that of their patients. RNs have the responsibility to act ethically if the victims that they are helping out are members of their family or friends (American Nurses Association, 2010). However, RNs are advised to put their patients’ needs first at all times and this ensures that they act ethically at all times. Nurses have the duty to act according to the code of conduct governing the practice and this facilitates efficiency while handling disasters. Volunteering in a community wide disaster can be challenging for RNs in various ways. This is caused by various aspects that are present in a community-wide setting. First, volunteers are called upon to ensure the safety of their patients first. This means that they are forced to put their lives at risk. In relation to this point, volunteers put their lives at risk, those of their family members and those that they touch or talk to. This is owing to the fact that they might get an infection while volunteering and are in a position where they can transmit it to other members of the society. Secondly, ethical issues arise when helping out in community-wide disasters because these volunteers are likely to come into contact with friends and family (American Nurses Association, 2010). They may be tempted to help out their family first and this goes against the code of conduct governing their practice. This explains the reason as to why volunteers should be highly cautious in this situati on. The other challenge that I will be likely to face in community-wide disasters is the likelihood to face legal problems. This is because some of the members of the community recognize me and therefore

Business research method and skills Essay Example | Topics and Well Written Essays - 2500 words

Business research method and skills - Essay Example In present scenario there are wide array of retailers who gives more importance to their retail store environment. This is because maintaining appropriate ambient conditions enable a firm to attract maximum customers and initiate high revenue margins. At times this form of approach is also regarded as a tool utilized for market differentiation. In this study different journal articles shall be included and reviewed like Journal of International Business and Management, Journal of Services Marketing, Journal of Business Ethics and Association for Consumer Research. There has been various research studies conducted on effect of store atmospherics on consumer behaviour. However limited analysis is performed on mixture on retail store environmental conditions. This would be the key area of focus in this research study. It is a highly relevant study since retail industry is growing at a rapid pace and marketers invest lump sum amount on store environment conditions. The major aim of this research study is to – â€Å"analyze the impact of ambient conditions of a retail store on consumer purchasing decision†. Objectives of the study are- This study would be feasible since sales volume at retail stores is largely dependent on purchasing behaviour of customers. On the other hand, impact of ambient conditions can be effectively measured through customer satisfaction level and increase in revenue margins. Researcher Hosseini and Jayashree, (2014) have outlined in their study that the decoration and the ambience of the store is regarded as an important element in the overall outlook of the stores that is designed for enhancing the satisfaction of the customers. The atmospheric design of the environment of the retail store includes the lighting, music, communications that stimulates the emotional responses and the perception of the consumers that mainly affect the purchasing behaviour of the customers.

Family and Consumer Personal Finance Essay Example | Topics and Well Written Essays - 250 words

Family and Consumer Personal Finance - Essay Example It looks for social factors, governmental, and economical factors that have contributed to such changes within the previous generation. Social economic mobility in United States does refer to movement of the Americans from a social class or level of economy to another may be through job changing or even marriage. Vertical mobility could be socio economic status changes between children and parents (â€Å"intergenerational†) or even over a life time course (â€Å"intra-generational†). Typically it refers to relative mobility, which is a chance that income status of Americans will fall or raise in comparison to the others or rather another income/status group. It also can be absolute, which means whether as well as by how much American living standards have increase. In the recent past years studies have discovered that vertical intergenerational mobility has been lower. Less higher in the United States than in other countries. Studies do differ in whether social as well as economic mobility in the recent years has gotten lower. In 2013, income inequality was getting to be more permanent reducing social mobility sharply. In 2014 income mobility had changed appreciably at least in the previous 20 years. Economic issue or financial crisis had wide ranging as well as long term economic implications in United States and the world, and it was much media attention focus over years. The crisis also did have a significant effect on many United States citizens personal finance. Some effects felt by U.S citizens in the previous generation were the direct consequences for financial crises which did produce the crisis for instance sub-prime mortgages provision to individuals who did struggle to pay back their debts. As a result, most people lost their homes they had bought within the years leading to the crisis. Other part in the U.S experienced incredibly for closure high rates. Governmental factors have contributed critically to changes in family and personal finances

Drug and GPA Assignment Example | Topics and Well Written Essays - 1000 words

Drug and GPA - Assignment Example Introduction The study on the effect of drug on individual GPA is very useful and critical. This is owing to the fact that, in developed countries, one among four young people between the age of 12 and 20 are involved in drug abuse and excessive alcohol consumption. Several studies in United States learning institutions have also confirmed that drug abuse at young age significantly affects students’ academic performance. Drug abuse also results in increased conflict in schools and school dropouts. The threatening impacts of drugs and alcohol abuse on students GPA have therefore raised the need for intensive research to understand the manner in which drugs affect Grade Point Average at all academic levels (Hommer, 2003). The study will also be critical in helping the policy makers in coming up with an effective intervention measures to address the problem. Research question Does drug effect students’ GPA? Literature review Williams, Powell &Wechsler, (2003, undertook int ensive researches to understand the impact of drugs on GPA. Howver, among there researches, there is no study that has presented a convincing answer. The available research findings in the journal have however confirmed that drug abuse has a critical students GPA. Drusg also dertemines whether a student will remain in school or will terminate their education for other social purposes. Most of their studies that were conducted in the United States of America in 2003 and they linked drug abuse to various social challenges in higher learning institutions including school drop outs, hangovers, alcohol poisoning, Neuro-cognitive defects, and brain dysfunction (Williams, Powell &Wechsler, 2003).. ... Based on this research finding, it is also clear and accurate to observe that male GPA are largely affected by drug consumption more than their female counterparts. On their part, Zimmerman, Caldwell & Bernat, (2006), obrserved that male students who engage in excessive consumptions of alcohol and drugs have a poor GPA compared to female who are involved in the same social vice. Their study further indicated that the rate of drug abuse both in high schools and in other higher learning institutions is increasing at an alarming rate. Therefore, by considering the impact of drugs on students’ performance, (Zimmerman, Caldwell & Bernat, 2006) recognised the importance of intensive research to intensively understand the manner in which drugs affects male and female students Grade Point Average (GPA) at all academic levels. The understanding of impact of drug abuse on male and female student GPA is also vital as it will help in searching for the most appropriate intervention measure s to address the vice (Zimmerman, Caldwell & Bernat, 2006) Method The study used random method to identify the sample. Data was obtained from a sample from CSUN students in June, 2009 (N=541). This sample composed of 35.6% males and 64.4% females. Respondents age was between 18-54 with mean age: 25.4 (s=5.619). The sample was also from different ethical background, 20.6% Asian-Pacific Islander, 25.6% Latino/Hispanic 8.1, 39.1% Caucasian, African American, and 5.6% other. The available information also indicates that among the 36,208 students registered at CSUN43% are men and 57% are women. Ethnically, the population is composed of Asian-Pacific

The Abyssinian crisis led to the failure of the League of Nations Essay

The Abyssinian crisis led to the failure of the League of Nations - Essay Example This organization is commonly known as the League of Nations, which is the predecessor of the United Nations. The League of Nations was categorical that members must maintain peace among themselves and with other countries in the world. However, in 1935, one League member, Italy, attacked another member, Abyssinia. There were clear signs that Italy would attack Abyssinia but nothing was done by the League of Nations to prevent the attack. It seemed like the League was biased towards countries which led to that attack and several others that eventually led to the fall of the League of Nations. The Failure of the League of Nations to solve the Italy and Abyssinian crisis discredited the League significantly and is probably one of the reasons the League of Nations failed in the subsequent years. The League of Nations When the World War One finally came to an end in November 1918, many people in the world did not want to experience or have their future generations experience the horrors of war ever again. Leaders from Europe, United States and other world countries met in France in 1919 to come up with an organization that would safeguard the world from wars. The main working principles of the League of Nations were disarmament of the countries and provide security to the League members like an alliance. Under these terms and conditions, no League member would attack another League member. In the case of disputes among the members of the League, democratic process would be used to solve the dispute amicably under the oversight of the other members of the League of Nations. Events Leading to Italy-Abyssinia Crisis of1935 Italy was one of the most powerful countries immediately after the World War One. Benito Mussolini, the Italian Prime Minister of the time envisioned a large Italian empire that would be ruled by him. In this case, he was looking for regions to expand the Italian invasion to. The large empire would provide the much required material for the Italian industries and Military as well as provide regions for expanding population to settle in. A large empire would also play an important role in instilling national pride and prestige. In fact, Winston Churchill had lamented that countries that were dependent on many war commodities like Italy would consider getting unhampered imports (Florian 7). Italy also felt left behind by its European peers in the scramble for Africa in especially the Easy African region. The country has possessions in East Africa were not resourceful as its peers and wanted to expand. It is also claimed that the Battle of Adowa, in which Italian troops were defeated by Abyssinian troops was of great shame and Mussolini wanted to revenge the attack. In fact, it is thought that he was looking for reasons to regain glory by defeating Abyssinia (Mendum and Waugh 19). A German official was quoted saying that Mussolini was not moving his troops in Africa back to Italy without glory. There were Italian troops in Somali a and Libya at the time (Kelly and Lacey 78). An opportunity for Benito Mussolini to do exactly what he was waiting for arose in December 1934 during the Wal Wal dispute. It is claimed that on 22nd November 1934, Ethiopian troops arrived at the Wal Wal fort and demanded that the Somali-Italian troops there to withdraw from the fort as it was in Ethiopia. The head of the fort refused but the Ethiopian troops persisted for the following days. Tensions were high and between 5th and 7th December 1934, there were collisions between Ethiopians and Italians and Somalis. None of the two parties involved in the incident claimed responsibility. The Italian government demanded that the

Chinese Philosophy and Poetry Essay Example for Free

Chinese Philosophy and Poetry Essay Chinese Philosophy and Poetry One of the most prevalent beliefs of the Chinese philosophies is that men are born good. People are naturally good unless they fail to develop their feelings and senses. Confucianism teaches that a lack of knowledge can be the cause to evil. In Poem 238, a woman named Chiang Yuan gave birth to the human race by sacrificing and praying to God. She bore her child easily because she sought after blessings from God. Confucianism teaches that good things will come to those who are good and do good. A. N. Whiteheads quotation of a Cambridge vicar says, For well-conducted people, life presents no problems. The mother in the poem seemed to be well-conducted and therefore she was blessed with a painless, easy childbirth. It says that God gave her ease and blessed her because he was pleased with the sacrifice and prayer. The poem paints a picture of how even the animals protected the baby. This might be because of their view of being born flawless and without evil. This baby was protected by the animals because there was no evil in him. Hou Chi, the baby boy, grew up to be a wise man and continued to be blessed and prospered through his crops and farming. He would be considered to be the superior man because of his moral wisdom and his ability to tell right from wrong. Because he lived by his mothers example and gave sacrifices to God, good things came to him. The power of moral example is strongly shown here. His mother first taught him the importance of sacrifice and prayer and through that, he learned to do the same and show respect and fear God. Another philosophy is the importance of filial piety and reverence. Parents are revered because they give life to their children and sacrifice much for them. The child brought honor to his mother by keeping her religious traditions. God was pleased by his actions and blessed him his entire life. This is a very ideal form of what a man can be like, but it is very unrealistic. If man were actually born good, then evil would not have such a major influence and affect everyday lives.

Economic Globalisation and Competition

Economic Globalisation and Competition 1. Introduction Competition is a vital mechanism of the market economy and is an efficient means of guaranteeing consumers a level of quality in terms of the value and price of products and services. Economic globalization has increased volatile growth within international trade and as a result in subject of competition law. Article 81(1) of the EC Treaty ‘prohibits agreements between undertakings; decisions by associations of undertakings and concerted practices which may affect trade between Member States and which prevent restrict or distort competition’. These agreements shall be void according to 81(2). However, the agreements which satisfy the conditions set out in article 81(3) EC shall not be prohibited, no prior decision to that effect being required. 1.1. Anti-Competitive Agreements Article 81 of the EC Treaty, prohibiting anti-competitive agreements, must be considered in relation to all commercial agreements with a probable EU cross-border impact. The Horizontal and the Vertical agreements are the agreements, which are relevant for the purposes of the application of the competition rules. Horizontal agreements are those between undertakings operating at the same level of production or marketing, while vertical agreements are those completed between undertakings operating at different economic levels. Under EC Competition Law, restrains included in vertical agreements are regarded as not as much damaging than those included in horizontal agreements. In Consten and Grundig v Commission the European Court of Justice considered that Article 81(1) EC applies not only to horizontal agreements but also to vertical agreements. The later decisional practice of the Commission on the treatment of vertical arrangements under Art 81(1) and 81(3) EC, and the case law of the Community Courts, have been one of the most controversial and severely criticized aspects of Community competition policy. These agreements are very important for the functioning of the economy. Commercial agreements may be exempted from the application of article 81(1) under article 81(3). 1.2. The Vertical Block Exemption Regulation However, there is a ‘safe harbour’ for undertakings: the Vertical Block Exemption Regulation 2790/1999. Safe harbours exist for certain agreements including restrictions providing conditions are met so that agreements falling within the terms of the Regulation are exempt from the application of Article 81(1) EC guaranteeing the enforceability of the agreement and granting protection from antitrust prosecution. Thus, if undertakings wish to be certain that their vertical agreements are in line with EC competition law, they should agree on clauses within the scope of the Regulation. Outside this safe harbour, the European Commission’s Notice Guidelines on Vertical Restraints are a helpful guide for the assessment under Art 81(3) EC and are explaining the application of Regulation 2790/1999 and the Commission’s approach to vertical restraints. The Guidelines on Vertical Restraints sets out the principles for the assessment of vertical agreements under Article 81, including the application of the Regulation to vertical agreements. Article 2(1) of the Vertical Block Exemption Regulation gives the definition of vertical agreements and states that Article 81(1) shall not apply to ‘agreements or concerted practices entered into between two or more undertakings each of which operates, for the purposes of the agreement, at a different level of the production or distribution chain, and relating to the conditions under which the parties may purchase, sell or resell certain goods or services’. The Commission adopted the Vertical Block Exemption Regulation on 1999 and the new Block Exemption Regulation is expected in 2010. Modifications might remain quite limited and might concern, especially, the presentation of more certain rules on e-commerce, on internet sales and the treatment of resale price maintenance. 1.3. Scope of Application of the Vertical Block Exemption Regulation The objective of the Vertical Block Exemption Regulation is to exempt certain categories of vertical agreements that, under certain conditions, may improve economic efficiency within a production or distribution chain and is directed at vertical agreements for the purchase or sale of goods or services. The Regulation covers various vertical agreements and applies to any type of agreement entered into companies, which do not operate at the same level of the production or distribution chain. Agreements are covered by the Vertical Block Exemption Regulation on franchising, selective distribution, exclusive dealing, exclusive purchasing, exclusive supply, and non-genuine agency agreements within the scope of Article 81. An agency agreement falls outside article 81(1) where the agent bears no or only insignificant risks in relation to either of these matters. Article 81(1) does not apply to certain agreements or concerted practices entered into between two or more undertakings. The concept of an undertaking was discussed in Hofner and Elser v Matrocton. It was stated that: â€Å"The concept of an undertaking encompasses every entity engaged in economic activity regardless of the legal status of the entity and the way it is financed†. The definition of competing undertakings in Article 1(b) includes actual or potential suppliers in the same product market. The exclusion may be quite wide and uncertain in application. In Tetra Pack I it was considered that a contract within the terms of the Vertical Block Exemption Regulation enjoys exemption from Article 81(1), but not from article 82 unless the Commission withdraws the exemption for the future, with a decision. The Regulation does not apply, however, to vertical agreements to rent and lease agreements, as no sale takes place and to agreements which have as their primary object the licensing of intellectual property rights, nor automobile distribution agreements, nor agreements between competitors, except if they are ancillary to a vertical agreement and facilitate the purchase, sale or resale of the contract goods or services by the buyer and vertical agreements whose subject matter falls within the scope of another block exemption regulation. Also, the Vertical Block Exemption Regulation does not cover any restrictions or obligations that do not relate to the conditions of purchase, sale and resale. The Regulation does not apply to vertical agreements with a subject matter that falls within the scope of any other Block Exemption Regulation. The application of the Regulation, in certain circumstances, can be withdrawn by a decision of the European Commission, or the national competition authorities. Also, the European Commission can enact a regulation declaring the Regulation usually inapplicable to certain agreements including specific restraints. 1.4. Agreements between Competitors The Vertical Block Exemption Regulation does not cover vertical agreements that are concluded on a reciprocal basis between competitors. This exclusion may be very broad because it includes both actual and potential competitors, with the latter being defined as companies that would be able and likely to enter the market within one year. Vertical agreements between competitors are covered by the Vertical Block Exemption Regulation if the agreement is non-reciprocal and the buyer has a turnover not exceeding â‚ ¬100 million or the buyer is not a manufacturer of competing goods but only a competitor of the supplier at the distribution level. Also, are covered and where the supplier is a provider of services operating at several levels of trade, while the buyer does not provide competing services at the level of trade where it purchases the contract services. 1.5. Summary Article 81(1) EC prohibits agreements which have anti-competitive effects. By enacting the Vertical Block Exemption Regulation, the Commission has establish ‘safe harbors’ for undertakings, that outline conditions regarding when vertical agreements and concerted practices that have an anti-competitive purpose or results and would be prohibited under article 81(1) might be acceptable because they satisfy the criteria of article 81(3). When an agreement fulfills the conditions set out in the Regulation, the agreement is valid and enforceable. The Vertical Block Exemption Regulation is a measure under European Union law that grants an exemption from the application of Article 81. Agreements that meet the conditions set out in the Regulation are considered either not to adversely affect competition on the relevant European market(s) or only to affect competition to a limited degree. It is now time to examine if the Vertical Block Exemption Regulation has worked and whether the Regulation and the vertical Guidelines are need any modification, and, if so, what have to be done. PART I Requirements of the Application of the Vertical Block Exemption Regulation The Vertical Block Exemption Regulation contains certain requirements that have to be satisfied before, for the vertical agreement is able to benefit from the Regulation. The market share of the supplier must not exceed 30% (Article 3). Also the agreement must not contain any of the hard-core restrictions (Article 4). Finally, the Regulation contains conditions relating to three certain restrictions (Article 5). 2. The Market Share Cap The Market Share threshold is probably one of the most important provisions of the Vertical Block Exemption Regulation. In Article 3(1) is stated that ‘the market share held by the supplier does not exceed 30% of the relevant market on which it sells the contract goods or services’. Also, Article 3(2) states that ‘in the case of vertical agreements containing exclusive supply obligations, the exemption provided for in Article 2 shall apply on condition that the market share held by the buyer does not exceed 30% of the relevant market on which it purchases the contract goods or services’. In Telenor/Canal+/Canal Digital the 30% rule prevented the application of the Vertical Block Exemption Regulation. The market share threshold is aimed to reduce regulatory burdens from those businesses that, according to Bishop and Ridyard, ‘could not behave anti-competitively even if they tried’. The introducing of a market share cap was one the most hotly contested aspects of the Vertical Block Exemption Regulation. Businesses and its lawyers argued that such a rule would be unworkable, since it is so difficult to establish market shares with any degree of precision, particularly in rapidly developing markets. However, the Commission insisted that there was no better means of ensuring that the benefit of the Block Exemption, did not go to firms with too much market power, and the market share cap stayed, albeit in the form of a single threshold of 30%, rather that two of 20% and of 40% which had been proposed in an earlier draft. If the market share of the parties exceeds the 10% threshold described in the De Minimis Notice, Article 81(1) EC will normally not apply to the agreement if the product is new or if the existing product is sold for the first time on a different geographic market. One factor which may have assisted the Commission in prevailing was the fact that while discussions on the Vertical Block Exemption Regulation were going on, it published its white paper on procedural modernization in the application of articles 81 and 82 EC, which proposed the abolition of the notification system altogether. This may have led some to feel less strongly about the content of the Regulation. 2.1. Calculating the Market Share In order to calculate the market share there must be identified the manufactured goods and geographic markets. Regarding market definition, the general rules apply. On the relevant market, the supplier calculates its market share by comparing its turnover achieved on that market with the total value of sales on that market. However, the benefit of the Vertical Block Exemption Regulation will, subject to certain conditions, not always be lost if the market share exceeds the 30% threshold. In Rewe/Meinl the European Commission considered that a supplier is in a situation of â€Å"economic dependence† when the buyer accounts for over a 22% market share and thus buyer power might distort competition. John De Gregorio, European counsel for consumer goods manufacturer Kimberly-Clark Corporation, has stated: ‘With the introduction of market share thresholds to the block exemption analysis, it’s more important than ever for in-house counsel to know how the Commission and European courts may define the â€Å"relevant market† for the goods that your company manufactures and sells, and to be comfortable with the definition your company adopts’. 2.2. The De Minimis Doctrine and Agreements of Minor Importance In addition to the Vertical Block Exemption Regulation and the Guidelines the Commission has issued a series of notices, called ‘Notices on agreements of minor importance’ which give guidance on the agreements which will escape Article 81(1), because the market share of each or both of the parties to the agreement is too small. The European Commission’s de minimis Notice states that no Article 81 subjects are raised by an agreement between undertakings where in vertical agreements the market share of each party to the agreement does not exceed 15% of the relevant market, or 5% for vertical agreements where access to the relevant market is foreclosed by the increasing effect of parallel networks of vertical agreements by several companies. The ‘de minimis’ notice sets the relevant threshold at 5% for horizontal agreements. Commercial agreements between parties where market shares exceed these thresholds might however not have a considerable effect on competition or might benefit from exemption. Nevertheless, the presumption in the de minimis Notice will not apply if the commercial agreement contains hardcore restrictions. In Franz Volk v Establissments Vervaecke SPRL the 0.6% of market share in washing machines considered insignificant. In general, agreements taken between Small and Medium size Enterprisers are ‘de minimis’. Paragraph 3 of the Notice recognizes that agreements between small and medium-sized undertakings are rarely capable of appreciably affecting trade between Member States. Finally, Article 8 provides that the Commission can withdraw the benefit of Block Exemption where ‘50 % of a relevant market, contain specific restraints relating to that market. This Regulation shall not become applicable earlier than six months following its adoption’. 2.3. Market Power The Vertical Block Exemption Regulation states that, with some certain exceptions, all vertical restrains are acceptable unless they are coupled to significant market power. Market share thresholds are criticized to be uncertain because they need a definition of the market which is the reason why the idea of market share thresholds has been discarded in most systems. Also, the amount of market power can be considered by reference to market share. Scherer and Ross state that economic analysis shows that in most cases the welfare-reducing effects of vertical restrains depend on the degree of market power the involved firms have. If market shares are in general indicative of potential market power, they can never be considered without considering some other factors to achieve a reasonable assessment of market power for instance the barriers to entry and prospective competition and the characteristics of the oligopolistic dealings between businesses. The Commission in some of its judgments show that market shares do not equal market power. For example, in Alcatel-Telectra the Commission cleared a merger which gave the parties market shares of 83%. Also, in Rhone-Poulenc/SNIA the high degree of concentration was ought to weighed by the existence of rapid technology development. The most obvious issue, according to Professor Denis Waelbroeck, is to consider whether the system should not allow all vertical agreements which do not include hardcore restrictions, separately of the market share of the parties involved, and only apply a control under Article 82 EC in cases of dominance. That would remove the burden above the threshold for businesses to achieve a complex evaluation of their agreements under Article 81(1) and Article 81(3) EC and it will provide more legal certainty in this subject. In addition, the economic assessment required by the Guidelines on Vertical Restrains and the Guidelines on the application of Article 81(3) of the Treaty is challenging, and it is doubtful that many judges and parties will have the income or abilities to undertake it sufficiently, thus raising the danger of extensive, expensive and uncertain litigation. 2.4. Arguments about the Threshold The use of market shares as a key element of the Regulation’s treatment has been criticised as being possible to lead to uncertainty and unpredictability given the difficulties in defining the relevant market and market share. It may be argued that the threshold is too low or that it is improperly cast. Those who argue that the threshold is too low point out that the anti-competitive risks can arise only when there is a dominant firm. A non-dominant firm cannot increase rivals costs and cannot make damage to the consumers as they still benefit from inter-brand competition. Those who argue that the threshold is improperly cast would agree with the above criticism but bear in mind that anti-competitive effects can manifest themselves when there is the risk of oligopolistic interdependence. Bishop. and Ridyard state that an assessment of the market’s concentration would be more useful than the assessment of one players market share. Some argue that given the uncertainties over market definition, a market share threshold is not a substitute for a detailed analysis of whether the consumers suffer consequently of a particular practice but this might damage the effectiveness of the existing system which creates a safe harbour so that analytical incomes are allocated to those cases where anticompetitive effects are most possible to occur. The Vertical Block Exemption Regulation creation of a market share threshold which the Regulation does not apply, limits manufacturing businesses that manufacture extremely innovative goods and want to sell them before other businesses have the chance to promote competitive goods into the market. In this situation, the manufacturing businesses with the extremely innovative goods might have a very high market share in a particular industry within a specific geographic area as no competing goods exist. However, as its market share is more than 30%, the manufacturing business is unable to take benefit from the Regulation and would be banned from effectively distributing and selling its manufactured goods in the market. 2.5. Removing the Threshold The Vertical Block Exemption Regulation is unduly restrictive by setting the threshold at 30%. Many agreements thus escape the safe harbour though they are completely harmless from a competition law perspective. By removing the thresholds the sellers using private resellers may be penalised not as much as vertically integrate businesses. Also, abolishing the threshold would give more stability to the system because not all restrictions of competition under 81 are an abuse under 82. On the other hand, if the system is seen as too essential one may think a less radical change to the Regulation consisting of a differentiated approach identifying those clauses which can be problematic above 30% although the parties are not dominant. Those clauses which are always straightforward, even in cases of dominance and which thus essentially deserve an exemption and should not to be matter to any market share threshold and also those clauses which should never advantage from a group exemption even they are below 30%. 2.6. Summary The Vertical Block Exemption Regulation can simplify issues but also can cause difficulties. It makes issues simple as it offers the parties more flexibility in establishing their agreements and if a business’s market share is less than the related market share threshold the agreement will fall outside the scope of the competition rules or be qualified for exemption provided that it does not include hardcore restrictions. The Regulation can also cause difficulties as the parties’ market share must be verified in every case and this can be very hard in situations, for instance as those concerning new markets. Where the market share threshold is exceeded, issues become more difficult as the Regulation requires a complete evaluation of the agreement to define whether it would restrict competition under Article 81(1) and, if so, whether it would meet the requirements for an exemption under Article 81(3). This requires the parties to verify the economic effect of certain restrictions by considering how they would operate in the specific product market involved. The Vertical Block Exemption Regulation principally proposes that businesses with small market shares are given more choice to establish their agreements and will not require undertaking an antitrust review of their dealings. Businesses with large market shares might need to spend time and resources to assessing their agreements from an antitrust perspective. 3. The Hard-Core Restrictions The Vertical Block Exemption Regulation does not apply to vertical agreements that have certain anti-competitive objects. The Regulation lists a number of hard-core restrictions that, if included in the agreement, prevent the safe harbour from applying and cause the exclusion of the whole agreement from the benefit of the Block Exemption even if the market share of the supplier or buyer is below 30%. There are hard-core restrictions which apply to agreements between competitors, and agreements between non competitors. If one hard-core restriction is present in the agreement, the agreement will lose the benefit of the block exemption so Article 81(1) EC may apply. This can result in the unenforceability of the entire agreement and may even lead to fines and it is important that a severability or invalidity clause is included in the agreement where appropriate. Hard-core restrictions are considered to be so serious that they are almost always prohibited. In Javico International and Javico AG v Yves Saint Laurent Parfumes SA it was considered that hard-core restrictions do not infringe Article 81(1) except if they might have considerable effect on trade between Member States. There are five hard-core restrictions which, if there are contained in a vertical agreement, they have the consequence of taking the whole agreement outside the scope of the Regulation. 3.1. Resale Price Maintenance The first hard-core restriction concerns resale price maintenance. Article 4(a) states that the benefit of the Vertical Block Exemption Regulation does not apply to vertical agreements that fix prices and have the object of restricting a buyer’s ability to determine its sale price. A supplier is not allowed to fix or minimum the sale price at which distributors can resell his products. The restriction on the buyer’s power to establish his sale price is a hard-core restriction. The Commission in Yamaha considered that an obligation of a purchaser to resell at a particular price is ‘an obvious restriction of competition that is prohibited by Article 81(1)’. However, Paragraph 47 of the Guidelines states that ‘the provision of a list of price recommendations by the supplier to the buyer is not considered in itself as leading to resale price maintenance’ if they do not amount to a fixed or a minimum sale price. In Pronuptia de Paris v Pronuptia de Paris Irmgard Schillgalis, the Court held that the recommendation of prices would not infringe Article 81(1). In genuine agency agreements, where the principal bears all or almost all the financial and commercial risks related to the transactions concluded on his account by the agent, Article 81(1) would generally not be applicable. In Vlaamse Reisbureaus an agreement between travel agents and tour operators indented to oblige the travel agents to examine the prices and tariffs set by the Tour operators and the agents were banned from sharing commissions with or granting refunds to their customers. The Court held that the Belgium system infringed Article 81(1). From an economic point of view, it can be said that there is no certain analysis nowadays as to how to treat with resale price maintenance. Resale price maintenance can be pro-competitive or anti-competitive. Nevertheless, even when applying an effect based approach, it is obvious that in many cases competition will be delayed and that cases when resale price maintenance is efficient are actually quite rare. 3.1.2. Anti-Competitive and Pro-Competitive Effects in Resale Price Maintenance Resale price maintenance is a complex issue and may be harmful in some circumstances. There are two major anti-competitive effects in relation to resale price maintenance. These are the elimination of intra-brand price competition which has as a direct effect the price increase, and the resulting risk of a reduction in inter-brand competition which gains from increased price transparency, thus make easiest price collusion between manufacturers or distributors at a horizontal level. Other anti-competitive effects of the resale price maintenance, according to Luc Peeperkorn, are the loss of pressure on the seller’s scope and the loss of dynamism and innovation from in particular discounters. However, the doubts about the efficiency of and the likelihood that resale price maintenance leads to positive aspects. Economic theory has shown that this practice might have a number of efficiency benefits. For instance, price fixing may prevent ‘free riding’ by retail price discounters on the pre-sales services and/or reputation of full price dealers while it is obvious that intra-brand price competition will be reduced by imposing a fixed or minimum price. This can be reasonable, for example, where a distribution outlet offers first-class services on which customers then rely to buy at a cheaper discounter which does not provide these services and thus is able to charge lower prices. Free riding arises when one business benefits from the performance of another with no paying for it. A minimum price would remove the pricing advantage from the discounter and change intra-brand price competition with competition on services. Minimum resale price maintenance can thus occasionally be economically and commercially reasonable if certain conditions are fulfilled. One could argue that the ‘free riding’ problem could be solved by using other block exempted restrains achieving the same result. Some inefficiencies and externalities caused by the ‘free riding’ problem might be solved by exclusivity clauses, or selective distribution but this restraint may not be an ideal substitute in all conditions for resale price maintenance and it is then questionable that resale price maintenance should be per se prohibited in all cases. Also, resale price fixing can be useful to entrant manufacturers as it might assist them to position their products and thus retailers would have the incentives to invest in making the entrant’s products better known to consumers. Resale price maintenance has created worries in Commission because is being stand on national limits with different costs in different member states. According to Professor Boscheck, taking into account that the economic conditions to consider such restrains ‘are still either too crude or too costly to apply to allow for efficient rules and structured rule of reason’, it is difficult to argue that fixed or minimum prices should not be part of the hard-core list. On the other hand, it appears that such clauses are not considered as if an exemption were inconceivable in any case. There are reasonable arguments that such restrains, considered under an effects-based approach, can rarely be deemed as pro-competitive. It is still uncertain whether free riding by resale price maintenance to rationalize the exclusion of price competition between dealers or retailers. There are methods, for instance promotional allowances or service requirements, which can avoid ‘free riding’ without the anticompetitive side effect of reducing price competition between dealers and retailers. 3.2. Territorial and Customer Restrictions Article 4(b) states that restricting sales by the buyer into specified territories or to specified customers is a hard-core restriction. Distributors must remain free to decide where and to whom they sell. Paragraph 49 of the Guidelines recognizes two restrictions on buyers that would not be considered as hard-core under 4(b): a prohibition on resale except to certain and users for which there is an ‘objective justification related to the product’, and an obligation on the reseller relating to the display of the supplier’s brand names. There are exceptions to 4(b), such as restriction ‘of active sales into the exclusive territory or to an exclusive customer group reserved by the supplier or allocated by the supplier to another buyer’. The Commission in Souris-Topps held that Topps’s distribution agreements for its Pokemon Stickers and Cards failed to benefit from the Block exemption as they violated Article 4(b). The Paragraph 51 of the Guidelines deals with the Internet. It states that ‘A restriction on the use of the Internet by distributors could only be compatible with the Block Exemption Regulation to the extent that promotion on the Internet or sales over the Internet would lead to active selling into other distributors’ exclusive territories or customer groups’. The Commission in Yves Saint Laurent case held that a prohibition on internet publicity and sale usually constitutes a hard-core restriction. The Commission is awry of deterring the growth of e-commerce, and has confirmed that the use of the internet is not considered a form of active sales as it is a reasonable way of reaching customers. Provisions that restrict the territory into which, or the customers to whom, the buyer might sell the contract goods or services are illegal. There are four exceptions to that rule: (1) The restriction of active sales into the exclusive territory or to an exclusive customer group reserved to the supplier or allocated by the supplier to another buyer, where such a restriction does not limit sales by the customers of the buyer, (2) Restrictions of sales to end-users by a buyer operating at the wholesale level of trade, unless it relates to a selective distribution system. This Principle was established by the Commission in Villeroy Boch, (3) the restriction of sales to unauthorised distributors by the members of a selective distribution system, and (4) the restriction of the buyers ability to sell components, supplied for the purposes of incorporation, to customers who would use them to manufacture the same type of goods as those produced by the supplier. A restriction on active sales might not restrict sales by the consumers of the buyer. Thus, a seller can not prohibit his consumers to sell his goods or services on-line without an objective reason and he also can not reserve such sales to himself and/or advertising over the internet. The Vertical Guidelines contain definitions of the terms ‘active sales’ and ‘passive sales’. ‘Active sales’ are defined in paragraph 50 of the Guidelines and it means actively approaching individual customers inside another distributor’s exclusive territory or exclusive consumer group while ‘passive sales’ means responding to unsolicit Economic Globalisation and Competition Economic Globalisation and Competition 1. Introduction Competition is a vital mechanism of the market economy and is an efficient means of guaranteeing consumers a level of quality in terms of the value and price of products and services. Economic globalization has increased volatile growth within international trade and as a result in subject of competition law. Article 81(1) of the EC Treaty ‘prohibits agreements between undertakings; decisions by associations of undertakings and concerted practices which may affect trade between Member States and which prevent restrict or distort competition’. These agreements shall be void according to 81(2). However, the agreements which satisfy the conditions set out in article 81(3) EC shall not be prohibited, no prior decision to that effect being required. 1.1. Anti-Competitive Agreements Article 81 of the EC Treaty, prohibiting anti-competitive agreements, must be considered in relation to all commercial agreements with a probable EU cross-border impact. The Horizontal and the Vertical agreements are the agreements, which are relevant for the purposes of the application of the competition rules. Horizontal agreements are those between undertakings operating at the same level of production or marketing, while vertical agreements are those completed between undertakings operating at different economic levels. Under EC Competition Law, restrains included in vertical agreements are regarded as not as much damaging than those included in horizontal agreements. In Consten and Grundig v Commission the European Court of Justice considered that Article 81(1) EC applies not only to horizontal agreements but also to vertical agreements. The later decisional practice of the Commission on the treatment of vertical arrangements under Art 81(1) and 81(3) EC, and the case law of the Community Courts, have been one of the most controversial and severely criticized aspects of Community competition policy. These agreements are very important for the functioning of the economy. Commercial agreements may be exempted from the application of article 81(1) under article 81(3). 1.2. The Vertical Block Exemption Regulation However, there is a ‘safe harbour’ for undertakings: the Vertical Block Exemption Regulation 2790/1999. Safe harbours exist for certain agreements including restrictions providing conditions are met so that agreements falling within the terms of the Regulation are exempt from the application of Article 81(1) EC guaranteeing the enforceability of the agreement and granting protection from antitrust prosecution. Thus, if undertakings wish to be certain that their vertical agreements are in line with EC competition law, they should agree on clauses within the scope of the Regulation. Outside this safe harbour, the European Commission’s Notice Guidelines on Vertical Restraints are a helpful guide for the assessment under Art 81(3) EC and are explaining the application of Regulation 2790/1999 and the Commission’s approach to vertical restraints. The Guidelines on Vertical Restraints sets out the principles for the assessment of vertical agreements under Article 81, including the application of the Regulation to vertical agreements. Article 2(1) of the Vertical Block Exemption Regulation gives the definition of vertical agreements and states that Article 81(1) shall not apply to ‘agreements or concerted practices entered into between two or more undertakings each of which operates, for the purposes of the agreement, at a different level of the production or distribution chain, and relating to the conditions under which the parties may purchase, sell or resell certain goods or services’. The Commission adopted the Vertical Block Exemption Regulation on 1999 and the new Block Exemption Regulation is expected in 2010. Modifications might remain quite limited and might concern, especially, the presentation of more certain rules on e-commerce, on internet sales and the treatment of resale price maintenance. 1.3. Scope of Application of the Vertical Block Exemption Regulation The objective of the Vertical Block Exemption Regulation is to exempt certain categories of vertical agreements that, under certain conditions, may improve economic efficiency within a production or distribution chain and is directed at vertical agreements for the purchase or sale of goods or services. The Regulation covers various vertical agreements and applies to any type of agreement entered into companies, which do not operate at the same level of the production or distribution chain. Agreements are covered by the Vertical Block Exemption Regulation on franchising, selective distribution, exclusive dealing, exclusive purchasing, exclusive supply, and non-genuine agency agreements within the scope of Article 81. An agency agreement falls outside article 81(1) where the agent bears no or only insignificant risks in relation to either of these matters. Article 81(1) does not apply to certain agreements or concerted practices entered into between two or more undertakings. The concept of an undertaking was discussed in Hofner and Elser v Matrocton. It was stated that: â€Å"The concept of an undertaking encompasses every entity engaged in economic activity regardless of the legal status of the entity and the way it is financed†. The definition of competing undertakings in Article 1(b) includes actual or potential suppliers in the same product market. The exclusion may be quite wide and uncertain in application. In Tetra Pack I it was considered that a contract within the terms of the Vertical Block Exemption Regulation enjoys exemption from Article 81(1), but not from article 82 unless the Commission withdraws the exemption for the future, with a decision. The Regulation does not apply, however, to vertical agreements to rent and lease agreements, as no sale takes place and to agreements which have as their primary object the licensing of intellectual property rights, nor automobile distribution agreements, nor agreements between competitors, except if they are ancillary to a vertical agreement and facilitate the purchase, sale or resale of the contract goods or services by the buyer and vertical agreements whose subject matter falls within the scope of another block exemption regulation. Also, the Vertical Block Exemption Regulation does not cover any restrictions or obligations that do not relate to the conditions of purchase, sale and resale. The Regulation does not apply to vertical agreements with a subject matter that falls within the scope of any other Block Exemption Regulation. The application of the Regulation, in certain circumstances, can be withdrawn by a decision of the European Commission, or the national competition authorities. Also, the European Commission can enact a regulation declaring the Regulation usually inapplicable to certain agreements including specific restraints. 1.4. Agreements between Competitors The Vertical Block Exemption Regulation does not cover vertical agreements that are concluded on a reciprocal basis between competitors. This exclusion may be very broad because it includes both actual and potential competitors, with the latter being defined as companies that would be able and likely to enter the market within one year. Vertical agreements between competitors are covered by the Vertical Block Exemption Regulation if the agreement is non-reciprocal and the buyer has a turnover not exceeding â‚ ¬100 million or the buyer is not a manufacturer of competing goods but only a competitor of the supplier at the distribution level. Also, are covered and where the supplier is a provider of services operating at several levels of trade, while the buyer does not provide competing services at the level of trade where it purchases the contract services. 1.5. Summary Article 81(1) EC prohibits agreements which have anti-competitive effects. By enacting the Vertical Block Exemption Regulation, the Commission has establish ‘safe harbors’ for undertakings, that outline conditions regarding when vertical agreements and concerted practices that have an anti-competitive purpose or results and would be prohibited under article 81(1) might be acceptable because they satisfy the criteria of article 81(3). When an agreement fulfills the conditions set out in the Regulation, the agreement is valid and enforceable. The Vertical Block Exemption Regulation is a measure under European Union law that grants an exemption from the application of Article 81. Agreements that meet the conditions set out in the Regulation are considered either not to adversely affect competition on the relevant European market(s) or only to affect competition to a limited degree. It is now time to examine if the Vertical Block Exemption Regulation has worked and whether the Regulation and the vertical Guidelines are need any modification, and, if so, what have to be done. PART I Requirements of the Application of the Vertical Block Exemption Regulation The Vertical Block Exemption Regulation contains certain requirements that have to be satisfied before, for the vertical agreement is able to benefit from the Regulation. The market share of the supplier must not exceed 30% (Article 3). Also the agreement must not contain any of the hard-core restrictions (Article 4). Finally, the Regulation contains conditions relating to three certain restrictions (Article 5). 2. The Market Share Cap The Market Share threshold is probably one of the most important provisions of the Vertical Block Exemption Regulation. In Article 3(1) is stated that ‘the market share held by the supplier does not exceed 30% of the relevant market on which it sells the contract goods or services’. Also, Article 3(2) states that ‘in the case of vertical agreements containing exclusive supply obligations, the exemption provided for in Article 2 shall apply on condition that the market share held by the buyer does not exceed 30% of the relevant market on which it purchases the contract goods or services’. In Telenor/Canal+/Canal Digital the 30% rule prevented the application of the Vertical Block Exemption Regulation. The market share threshold is aimed to reduce regulatory burdens from those businesses that, according to Bishop and Ridyard, ‘could not behave anti-competitively even if they tried’. The introducing of a market share cap was one the most hotly contested aspects of the Vertical Block Exemption Regulation. Businesses and its lawyers argued that such a rule would be unworkable, since it is so difficult to establish market shares with any degree of precision, particularly in rapidly developing markets. However, the Commission insisted that there was no better means of ensuring that the benefit of the Block Exemption, did not go to firms with too much market power, and the market share cap stayed, albeit in the form of a single threshold of 30%, rather that two of 20% and of 40% which had been proposed in an earlier draft. If the market share of the parties exceeds the 10% threshold described in the De Minimis Notice, Article 81(1) EC will normally not apply to the agreement if the product is new or if the existing product is sold for the first time on a different geographic market. One factor which may have assisted the Commission in prevailing was the fact that while discussions on the Vertical Block Exemption Regulation were going on, it published its white paper on procedural modernization in the application of articles 81 and 82 EC, which proposed the abolition of the notification system altogether. This may have led some to feel less strongly about the content of the Regulation. 2.1. Calculating the Market Share In order to calculate the market share there must be identified the manufactured goods and geographic markets. Regarding market definition, the general rules apply. On the relevant market, the supplier calculates its market share by comparing its turnover achieved on that market with the total value of sales on that market. However, the benefit of the Vertical Block Exemption Regulation will, subject to certain conditions, not always be lost if the market share exceeds the 30% threshold. In Rewe/Meinl the European Commission considered that a supplier is in a situation of â€Å"economic dependence† when the buyer accounts for over a 22% market share and thus buyer power might distort competition. John De Gregorio, European counsel for consumer goods manufacturer Kimberly-Clark Corporation, has stated: ‘With the introduction of market share thresholds to the block exemption analysis, it’s more important than ever for in-house counsel to know how the Commission and European courts may define the â€Å"relevant market† for the goods that your company manufactures and sells, and to be comfortable with the definition your company adopts’. 2.2. The De Minimis Doctrine and Agreements of Minor Importance In addition to the Vertical Block Exemption Regulation and the Guidelines the Commission has issued a series of notices, called ‘Notices on agreements of minor importance’ which give guidance on the agreements which will escape Article 81(1), because the market share of each or both of the parties to the agreement is too small. The European Commission’s de minimis Notice states that no Article 81 subjects are raised by an agreement between undertakings where in vertical agreements the market share of each party to the agreement does not exceed 15% of the relevant market, or 5% for vertical agreements where access to the relevant market is foreclosed by the increasing effect of parallel networks of vertical agreements by several companies. The ‘de minimis’ notice sets the relevant threshold at 5% for horizontal agreements. Commercial agreements between parties where market shares exceed these thresholds might however not have a considerable effect on competition or might benefit from exemption. Nevertheless, the presumption in the de minimis Notice will not apply if the commercial agreement contains hardcore restrictions. In Franz Volk v Establissments Vervaecke SPRL the 0.6% of market share in washing machines considered insignificant. In general, agreements taken between Small and Medium size Enterprisers are ‘de minimis’. Paragraph 3 of the Notice recognizes that agreements between small and medium-sized undertakings are rarely capable of appreciably affecting trade between Member States. Finally, Article 8 provides that the Commission can withdraw the benefit of Block Exemption where ‘50 % of a relevant market, contain specific restraints relating to that market. This Regulation shall not become applicable earlier than six months following its adoption’. 2.3. Market Power The Vertical Block Exemption Regulation states that, with some certain exceptions, all vertical restrains are acceptable unless they are coupled to significant market power. Market share thresholds are criticized to be uncertain because they need a definition of the market which is the reason why the idea of market share thresholds has been discarded in most systems. Also, the amount of market power can be considered by reference to market share. Scherer and Ross state that economic analysis shows that in most cases the welfare-reducing effects of vertical restrains depend on the degree of market power the involved firms have. If market shares are in general indicative of potential market power, they can never be considered without considering some other factors to achieve a reasonable assessment of market power for instance the barriers to entry and prospective competition and the characteristics of the oligopolistic dealings between businesses. The Commission in some of its judgments show that market shares do not equal market power. For example, in Alcatel-Telectra the Commission cleared a merger which gave the parties market shares of 83%. Also, in Rhone-Poulenc/SNIA the high degree of concentration was ought to weighed by the existence of rapid technology development. The most obvious issue, according to Professor Denis Waelbroeck, is to consider whether the system should not allow all vertical agreements which do not include hardcore restrictions, separately of the market share of the parties involved, and only apply a control under Article 82 EC in cases of dominance. That would remove the burden above the threshold for businesses to achieve a complex evaluation of their agreements under Article 81(1) and Article 81(3) EC and it will provide more legal certainty in this subject. In addition, the economic assessment required by the Guidelines on Vertical Restrains and the Guidelines on the application of Article 81(3) of the Treaty is challenging, and it is doubtful that many judges and parties will have the income or abilities to undertake it sufficiently, thus raising the danger of extensive, expensive and uncertain litigation. 2.4. Arguments about the Threshold The use of market shares as a key element of the Regulation’s treatment has been criticised as being possible to lead to uncertainty and unpredictability given the difficulties in defining the relevant market and market share. It may be argued that the threshold is too low or that it is improperly cast. Those who argue that the threshold is too low point out that the anti-competitive risks can arise only when there is a dominant firm. A non-dominant firm cannot increase rivals costs and cannot make damage to the consumers as they still benefit from inter-brand competition. Those who argue that the threshold is improperly cast would agree with the above criticism but bear in mind that anti-competitive effects can manifest themselves when there is the risk of oligopolistic interdependence. Bishop. and Ridyard state that an assessment of the market’s concentration would be more useful than the assessment of one players market share. Some argue that given the uncertainties over market definition, a market share threshold is not a substitute for a detailed analysis of whether the consumers suffer consequently of a particular practice but this might damage the effectiveness of the existing system which creates a safe harbour so that analytical incomes are allocated to those cases where anticompetitive effects are most possible to occur. The Vertical Block Exemption Regulation creation of a market share threshold which the Regulation does not apply, limits manufacturing businesses that manufacture extremely innovative goods and want to sell them before other businesses have the chance to promote competitive goods into the market. In this situation, the manufacturing businesses with the extremely innovative goods might have a very high market share in a particular industry within a specific geographic area as no competing goods exist. However, as its market share is more than 30%, the manufacturing business is unable to take benefit from the Regulation and would be banned from effectively distributing and selling its manufactured goods in the market. 2.5. Removing the Threshold The Vertical Block Exemption Regulation is unduly restrictive by setting the threshold at 30%. Many agreements thus escape the safe harbour though they are completely harmless from a competition law perspective. By removing the thresholds the sellers using private resellers may be penalised not as much as vertically integrate businesses. Also, abolishing the threshold would give more stability to the system because not all restrictions of competition under 81 are an abuse under 82. On the other hand, if the system is seen as too essential one may think a less radical change to the Regulation consisting of a differentiated approach identifying those clauses which can be problematic above 30% although the parties are not dominant. Those clauses which are always straightforward, even in cases of dominance and which thus essentially deserve an exemption and should not to be matter to any market share threshold and also those clauses which should never advantage from a group exemption even they are below 30%. 2.6. Summary The Vertical Block Exemption Regulation can simplify issues but also can cause difficulties. It makes issues simple as it offers the parties more flexibility in establishing their agreements and if a business’s market share is less than the related market share threshold the agreement will fall outside the scope of the competition rules or be qualified for exemption provided that it does not include hardcore restrictions. The Regulation can also cause difficulties as the parties’ market share must be verified in every case and this can be very hard in situations, for instance as those concerning new markets. Where the market share threshold is exceeded, issues become more difficult as the Regulation requires a complete evaluation of the agreement to define whether it would restrict competition under Article 81(1) and, if so, whether it would meet the requirements for an exemption under Article 81(3). This requires the parties to verify the economic effect of certain restrictions by considering how they would operate in the specific product market involved. The Vertical Block Exemption Regulation principally proposes that businesses with small market shares are given more choice to establish their agreements and will not require undertaking an antitrust review of their dealings. Businesses with large market shares might need to spend time and resources to assessing their agreements from an antitrust perspective. 3. The Hard-Core Restrictions The Vertical Block Exemption Regulation does not apply to vertical agreements that have certain anti-competitive objects. The Regulation lists a number of hard-core restrictions that, if included in the agreement, prevent the safe harbour from applying and cause the exclusion of the whole agreement from the benefit of the Block Exemption even if the market share of the supplier or buyer is below 30%. There are hard-core restrictions which apply to agreements between competitors, and agreements between non competitors. If one hard-core restriction is present in the agreement, the agreement will lose the benefit of the block exemption so Article 81(1) EC may apply. This can result in the unenforceability of the entire agreement and may even lead to fines and it is important that a severability or invalidity clause is included in the agreement where appropriate. Hard-core restrictions are considered to be so serious that they are almost always prohibited. In Javico International and Javico AG v Yves Saint Laurent Parfumes SA it was considered that hard-core restrictions do not infringe Article 81(1) except if they might have considerable effect on trade between Member States. There are five hard-core restrictions which, if there are contained in a vertical agreement, they have the consequence of taking the whole agreement outside the scope of the Regulation. 3.1. Resale Price Maintenance The first hard-core restriction concerns resale price maintenance. Article 4(a) states that the benefit of the Vertical Block Exemption Regulation does not apply to vertical agreements that fix prices and have the object of restricting a buyer’s ability to determine its sale price. A supplier is not allowed to fix or minimum the sale price at which distributors can resell his products. The restriction on the buyer’s power to establish his sale price is a hard-core restriction. The Commission in Yamaha considered that an obligation of a purchaser to resell at a particular price is ‘an obvious restriction of competition that is prohibited by Article 81(1)’. However, Paragraph 47 of the Guidelines states that ‘the provision of a list of price recommendations by the supplier to the buyer is not considered in itself as leading to resale price maintenance’ if they do not amount to a fixed or a minimum sale price. In Pronuptia de Paris v Pronuptia de Paris Irmgard Schillgalis, the Court held that the recommendation of prices would not infringe Article 81(1). In genuine agency agreements, where the principal bears all or almost all the financial and commercial risks related to the transactions concluded on his account by the agent, Article 81(1) would generally not be applicable. In Vlaamse Reisbureaus an agreement between travel agents and tour operators indented to oblige the travel agents to examine the prices and tariffs set by the Tour operators and the agents were banned from sharing commissions with or granting refunds to their customers. The Court held that the Belgium system infringed Article 81(1). From an economic point of view, it can be said that there is no certain analysis nowadays as to how to treat with resale price maintenance. Resale price maintenance can be pro-competitive or anti-competitive. Nevertheless, even when applying an effect based approach, it is obvious that in many cases competition will be delayed and that cases when resale price maintenance is efficient are actually quite rare. 3.1.2. Anti-Competitive and Pro-Competitive Effects in Resale Price Maintenance Resale price maintenance is a complex issue and may be harmful in some circumstances. There are two major anti-competitive effects in relation to resale price maintenance. These are the elimination of intra-brand price competition which has as a direct effect the price increase, and the resulting risk of a reduction in inter-brand competition which gains from increased price transparency, thus make easiest price collusion between manufacturers or distributors at a horizontal level. Other anti-competitive effects of the resale price maintenance, according to Luc Peeperkorn, are the loss of pressure on the seller’s scope and the loss of dynamism and innovation from in particular discounters. However, the doubts about the efficiency of and the likelihood that resale price maintenance leads to positive aspects. Economic theory has shown that this practice might have a number of efficiency benefits. For instance, price fixing may prevent ‘free riding’ by retail price discounters on the pre-sales services and/or reputation of full price dealers while it is obvious that intra-brand price competition will be reduced by imposing a fixed or minimum price. This can be reasonable, for example, where a distribution outlet offers first-class services on which customers then rely to buy at a cheaper discounter which does not provide these services and thus is able to charge lower prices. Free riding arises when one business benefits from the performance of another with no paying for it. A minimum price would remove the pricing advantage from the discounter and change intra-brand price competition with competition on services. Minimum resale price maintenance can thus occasionally be economically and commercially reasonable if certain conditions are fulfilled. One could argue that the ‘free riding’ problem could be solved by using other block exempted restrains achieving the same result. Some inefficiencies and externalities caused by the ‘free riding’ problem might be solved by exclusivity clauses, or selective distribution but this restraint may not be an ideal substitute in all conditions for resale price maintenance and it is then questionable that resale price maintenance should be per se prohibited in all cases. Also, resale price fixing can be useful to entrant manufacturers as it might assist them to position their products and thus retailers would have the incentives to invest in making the entrant’s products better known to consumers. Resale price maintenance has created worries in Commission because is being stand on national limits with different costs in different member states. According to Professor Boscheck, taking into account that the economic conditions to consider such restrains ‘are still either too crude or too costly to apply to allow for efficient rules and structured rule of reason’, it is difficult to argue that fixed or minimum prices should not be part of the hard-core list. On the other hand, it appears that such clauses are not considered as if an exemption were inconceivable in any case. There are reasonable arguments that such restrains, considered under an effects-based approach, can rarely be deemed as pro-competitive. It is still uncertain whether free riding by resale price maintenance to rationalize the exclusion of price competition between dealers or retailers. There are methods, for instance promotional allowances or service requirements, which can avoid ‘free riding’ without the anticompetitive side effect of reducing price competition between dealers and retailers. 3.2. Territorial and Customer Restrictions Article 4(b) states that restricting sales by the buyer into specified territories or to specified customers is a hard-core restriction. Distributors must remain free to decide where and to whom they sell. Paragraph 49 of the Guidelines recognizes two restrictions on buyers that would not be considered as hard-core under 4(b): a prohibition on resale except to certain and users for which there is an ‘objective justification related to the product’, and an obligation on the reseller relating to the display of the supplier’s brand names. There are exceptions to 4(b), such as restriction ‘of active sales into the exclusive territory or to an exclusive customer group reserved by the supplier or allocated by the supplier to another buyer’. The Commission in Souris-Topps held that Topps’s distribution agreements for its Pokemon Stickers and Cards failed to benefit from the Block exemption as they violated Article 4(b). The Paragraph 51 of the Guidelines deals with the Internet. It states that ‘A restriction on the use of the Internet by distributors could only be compatible with the Block Exemption Regulation to the extent that promotion on the Internet or sales over the Internet would lead to active selling into other distributors’ exclusive territories or customer groups’. The Commission in Yves Saint Laurent case held that a prohibition on internet publicity and sale usually constitutes a hard-core restriction. The Commission is awry of deterring the growth of e-commerce, and has confirmed that the use of the internet is not considered a form of active sales as it is a reasonable way of reaching customers. Provisions that restrict the territory into which, or the customers to whom, the buyer might sell the contract goods or services are illegal. There are four exceptions to that rule: (1) The restriction of active sales into the exclusive territory or to an exclusive customer group reserved to the supplier or allocated by the supplier to another buyer, where such a restriction does not limit sales by the customers of the buyer, (2) Restrictions of sales to end-users by a buyer operating at the wholesale level of trade, unless it relates to a selective distribution system. This Principle was established by the Commission in Villeroy Boch, (3) the restriction of sales to unauthorised distributors by the members of a selective distribution system, and (4) the restriction of the buyers ability to sell components, supplied for the purposes of incorporation, to customers who would use them to manufacture the same type of goods as those produced by the supplier. A restriction on active sales might not restrict sales by the consumers of the buyer. Thus, a seller can not prohibit his consumers to sell his goods or services on-line without an objective reason and he also can not reserve such sales to himself and/or advertising over the internet. The Vertical Guidelines contain definitions of the terms ‘active sales’ and ‘passive sales’. ‘Active sales’ are defined in paragraph 50 of the Guidelines and it means actively approaching individual customers inside another distributor’s exclusive territory or exclusive consumer group while ‘passive sales’ means responding to unsolicit

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