Rev Ind Organ (2010) 36:305–331
Comparing Merger Policies in the European Union
and the United States
Mats A. Bergman · Malcolm B. Coate ·
Maria Jakobsson · Shawn W. Ulrick
Published online: 23 July 2010
© US Government 2010
Abstract We collect a sample of EU and US merger investigations, estimate
models of the regulatory decisions, and use the models to compare merger policies.
Our approach allows us to decompose observed differences into policy effects and
case-mix effects. Focusing on dominance mergers, we ﬁnd that the EU is tougher
than the US on average, in particular for mergers resulting in moderate market shares.
However, the US appears to be more aggressive for coordinated interaction and non-
dominance unilateraleffects cases. Overall, our analysis detects substantial differences
in policies, but it does not classify one regime as being more aggressive than the other.
Keywords Antitrust · Comparative regulatory policy · Merger policy · Oaxaca
JEL Classiﬁcation L44 · K21
M. A. Bergman
Södertörn University of South Stockholm, 141 89 Huddinge, Sweden,
M. B. Coate (
) · S. W. Ulrick
Federal Trade Commission, 600 Pennsylvania Ave. NW, Washington, DC 20580, USA
S. W. Ulrick
Pﬁzer AB, Vetenskapsvägen 10, 191 90 Sollentuna, Sweden