The Hellenic Competition Commission (HCC) carried out unannounced inspections (dawn raids) at the premises of undertakings active in the sector for the import/production, wholesale and retail of pet food (dog and cat food) in the context of its relevant ex officio investigation into possible anti-competitive vertical agreements in breach of Articles 1 of Law 3959/2011, as in force, and 101 of the Treaty on the Functioning of the European Union (TFEU).

According to relevant studies, the population of domestic dogs in Greece for 2021 is estimated at 660,000 while that of cats is estimated at 605,000. Approximately 14% of Greek households have a pet dog and 13% have a pet cat.^[1] Different reports indicate that the cost of purchasing animal feed has significantly increased over the last two years, hence constituting a growing significant cost for households. The increase in the annual Consumer Price Index for pet products in Greece has been consistently higher than the increase in the respective price index in the Eurozone since July 2023, though on a downward trend. In September 2024, inflation in this product category in Greece stood at 1.8%, compared to 0.6% in the Eurozone.

It is noted that unannounced inspections at the premises of undertakings or associations of undertakings are a preliminary step in an investigation into suspected anticompetitive practices.  The fact that the HCC has carried out inspections does not mean that the inspected undertakings have engaged in anti-competitive behavior, nor does it prejudge the outcome of the investigation itself.

Legal Framework

The HCC enforces Greek and EU antitrust rules in the Greek territory (Articles 1, 1A and 2 of Greek Law 3959/2011 and Articles 101 and 102 TFEU).

• Article 1 of Law no. 3959/2011 and Article 101 of the TFEU prohibit anticompetitive agreements and decisions of associations of undertakings that prevent, restrict or distort competition.
• Article 1A of Law no. 3959/2011 prohibits unilateral practices that constitute an invitation to collude or future price announcements to competitors.
• Article 2 of Law no. 3959/2011 and Article 102 of the TFEU prohibit the abuse of a dominant position.

The HCC points out that, within the framework of its responsibilities, it will intervene as an immediate priority where necessary, and will examine any relevant case that comes to its notice, upon submission of a complaint, application for leniency or anonymous information through the secure digital environment (whistleblowing) and will impose severe administrative sanctions on companies that apply anti-competitive practices, pursuant to the provisions of law 3959/2011 and the articles 101/102 TFEU.

^[1] See ICAP, Sectoral Study on “Animal Feed”, July 2023, with further references cited therein.