Statement of Objections Notification

Statement of Objections Notification

Notification of Statement of Objections to addressees

An SO is addressed and notified individually to each party by the Secretariat General (“SG”) together with the cover letter explaining the rights of the addressees (see further here below Section 6).

More about Statement of Objections Notification

The SG sends the SO only to the undertakings, not to their lawyers. Therefore, if regarded as useful, a courtesy copy to the lawyers can be sent by the Head of Unit responsible. 1

More about the Subject

While the subject of the competition rules is an “undertaking”, each legal entity that may be liable for the infringement within the undertakings must individually receive, as an addressee, an SO, specifying which elements of the infringement it is held responsible for and whether a fine is liable to be imposed on it. 2 It is therefore important to make sure that the SO is addressed to all possible legal entities (parent companies and subsidiaries) that may be held jointly and severally liable for the infringement, indicating clearly why the Commission considers each of them to be liable for the infringement. The final decision cannot be addressed to legal entities which, although they may be considered to be responsible for the infringements, were not an addressee of the SO.

Other Considerations

As regards associations of undertakings, it is normally sufficient to send a single SO to the association rather than addressing individually its members, 3 unless its members are also held liable for the infringement.


In case a language waiver has been agreed by the parties modifying the basic language rules contained in Regulation No 1 (see above section 3 Language regime), this must be submitted to the SG to ensure that the SG is prepared to send out an SO or a decision to an undertaking in a language other than the language of the Member State in which that undertaking is based.


See Also


  • Information about Statement of Objections Notification in the Antitrust Manual of Procedures for the application of Articles 101 and 102 TFEU (Internal DG Competition)


[Note 1]
Article 10(1) of Regulation 773/2004.
[Note 2]
Joined Cases C-395/96 P and C-396/96 P, Compagnie maritime belge, [2000] ECR I-1365, paragraphs 142 to 147
[Note 3]
Joined Cases T-39/92 and T-40/92 Carte Bleu v Commission [1994] ECR II-49, paragraph 139.

Further Reading

  • Information about Statement of Objections Notification in “An Introduction to EU Competition Law”, Moritz Lorenz (Cambridge University Press)

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