Case overview
In the context of an ex officio investigation, the Hellenic Competition Commission (‘HCC’) conducted on-site inspections at the premises of several undertakings operating in the markets for the importation, manufacturing, and marketing of school supplies, branded clothing and footwear.
On 3 June 2026, following a Settlement Procedure, the HCC announced that it had imposed a fine of EUR 954,485 on VF HELLAS Ltd (‘VFH’), a subsidiary of the American VF Corporation. VFH imports and distributes school supplies, clothing and footwear under several well-known brands, including VANS, EASTPAK, and THE NORTH FACE.
Infringement
Based on the evidence collected, the Directorate-General for Competition of the HCC concluded that VFH infringed Article 1 of Law 3959/2011 (‘Greek Competition Act’) and Article 101 TFEU.
According to the HCC, VFH imposed contractual restrictions preventing its authorised retailers from using certain online advertising channels. The restrictions covered the full product range of the brands concerned, including clothing and footwear in addition to school supplies. In particular, VFH prohibited the use:
(a) of all price comparison platforms; and
(b) of advertising services on search engines (particularly Google Ads).
By preventing retailers from using key online customer-acquisition channels, the restrictions significantly limited their ability to attract online traffic and compete effectively in e-commerce.
The HCC considered that these restrictions effectively prevented retailers from making effective use of the internet and therefore amounted to a hardcore restriction under Article 4(e) of Regulation (EU) 720/2022.
Commentary
The significance of the decision lies in the HCC’s apparent willingness to treat restrictions on retailers’ online visibility as a hardcore restriction where they effectively deprive retailers of key customer-acquisition tools. The combination of a ban on price comparison services and restrictions on search engine advertising substantially reduced retailers’ ability to generate online traffic and compete for customers.
This approach is broadly consistent with the EU Vertical Guidelines, which treat broad restrictions on online advertising as preventing the effective use of the internet. The decision also aligns with established European Commission practice, most notable Guess (AT.40428, 2018), where restrictions on online search advertising were found to undermine retailers’ “findability” and their ability to compete online. More broadly, it is consistent with the line of EU case law emphasising the importance of effective online distribution channels, including Pierre Fabre (C-439/09), where the Court of Justice confirmed that restrictions capable of significantly limiting internet sales may raise serious competition concerns.
Similar concerns have also arisen in other European enforcement practice. In particular, the German Federal Cartel Office (Bundeskartellamt) in Asics (2015) found that restrictions on the use of price comparison websites, together with limitations affecting online advertising and marketplace sales, impaired retailers’ ability to compete effectively online. A comparable approach can also be seen in the UK Competition and Markets Authority’s Ping decision (2017), which emphasised the importance of online channels in enabling retailers to reach customers and compete effectively. The present case further echoes the HCC’s own approach in Caudalie (2023), where a blanket prohibition on the use of price comparison tools was treated as a hardcore restriction.
More broadly, the decision confirms that the HCC continues to align closely with EU enforcement trends in the digital distribution space and remains particularly attentive to measures that may limit retailers’ digital reach, online discoverability and ability to compete effectively through online channels. Together with Caudalie, the VF Hellas case signals a continued focus by the HCC on restrictions affecting retailers’ online visibility and customer acquisition strategies.
From a procedural perspective, the case is also noteworthy because it forms part of the HCC’s increasing use of settlement procedures in antitrust enforcement. Although settlement has traditionally been associated with cartel enforcement, Law 4886/2022 extended its application to vertical agreements. The decision therefore illustrates the practical operation of this relatively new procedural tool in the vertical restraints context and confirms the HCC's readiness to rely on it when investigating restrictions affecting online sales and distribution.
Further insights may emerge once the full settlement decision becomes available.
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