Competition Law and Smart Logistics Platform Market Power

1. Introduction

A smart logistics platform is a digitally integrated system that connects shippers, manufacturers, sellers, warehouses, transport operators, courier companies, drivers, consumers and other logistics participants through software, data, algorithms, cloud infrastructure, GPS/IoT systems, automated warehouses and digital payment systems.

Examples include platforms performing functions such as:

• freight matching;
• route optimisation;
• warehouse allocation;
• courier and delivery aggregation;
• smart parcel lockers;
• last-mile delivery coordination;
• real-time shipment tracking;
• algorithmic pricing;
• fleet management;
• supply-chain financing;
• logistics-data analytics; and
• integration of e-commerce with transportation and warehousing.

The competition-law problem arises when a platform becomes sufficiently important that logistics operators, merchants or customers cannot effectively operate without access to it. Network effects, accumulated logistics data, switching costs and vertical integration can then create substantial market power.

China's Platform Economy Antitrust Guidelines specifically recognise factors such as market share, network effects, control over related markets, barriers to entry, technology, innovation and the ability to control prices, traffic or other transaction conditions when assessing platform dominance.

2. Meaning of Market Power in Smart Logistics

Market power is the ability of an undertaking to behave to an appreciable extent independently of competitors, customers or suppliers.

For a smart logistics platform, market power may arise from several sources.

A. Network effects

A logistics platform becomes more valuable as more participants join it.

For example:

More merchants → more shipments → more logistics providers → better network density → more merchants.

This creates a self-reinforcing competitive advantage.

B. Data advantage

A platform may accumulate:

• shipment histories;
• customer addresses;
• delivery times;
• route information;
• freight prices;
• warehouse utilisation;
• driver performance;
• demand forecasts; and
• consumer purchasing patterns.

The data can improve algorithms and make competing platforms less attractive.

C. Switching costs

A merchant may have invested in:

• APIs;
• warehouse software;
• inventory systems;
• delivery integrations;
• customer tracking systems; and
• platform-specific contracts.

Moving to another platform can therefore be costly.

D. Vertical integration

A platform may simultaneously operate:

E-commerce + warehouse + freight marketplace + courier network + payment system + parcel lockers.

This creates the possibility of leveraging power from one market into another.

E. Algorithmic control

A smart logistics platform can automatically determine:

• which courier receives an order;
• delivery priority;
• freight rates;
• visibility in search results;
• access to customers;
• incentives;
• commissions; and
• penalties.

Consequently, an apparently neutral algorithm can become an important competition-law instrument.

3. Relevant Market

Market definition is particularly important because a smart logistics platform can participate in several interconnected markets.

Possible relevant markets include:

1. Logistics-platform services market

Services enabling merchants and logistics providers to match transportation demand and supply.

2. Express-delivery market

Collection, transportation and delivery of parcels.

3. Freight-matching market

Digital matching between shippers and transportation providers.

4. Warehouse-management services

Digital and physical infrastructure for storage and distribution.

5. Last-mile delivery market

The final transportation stage from distribution centre to consumer.

6. Smart parcel-locker market

Automated collection and delivery infrastructure.

7. Logistics-data services

Provision and processing of transportation and shipment information.

The same company can possess power in one market and use that power to affect another.

4. Indicators of Dominance

China's platform-antitrust framework permits authorities to consider not merely traditional market share but also:

• transaction value;
• transaction volume;
• active users;
• clicks;
• usage time;
• duration of market share;
• network effects;
• economies of scale;
• technological advantages;
• financial strength;
• switching costs;
• barriers to entry;
• control over upstream and downstream markets; and
• ability to influence prices, traffic and transaction conditions. 

This is particularly important for smart logistics because market share alone may underestimate platform power.

5. Major Competition Concerns

A. Exclusive dealing

A dominant logistics platform may require merchants or logistics providers to use its services exclusively.

Example:

"If you use our warehouse or e-commerce platform, you cannot simultaneously use a competing logistics platform."

Such conduct can foreclose rivals.

The concern is especially serious when the platform controls an essential source of customers or logistics data.

B. Self-preferencing

A vertically integrated platform may favour its own logistics subsidiary.

For example:

Platform A operates both a logistics marketplace and its own courier company.

It may give its own courier:

• preferential search ranking;
• faster order allocation;
• better delivery information;
• lower platform fees;
• earlier access to customers; or
• preferential algorithmic treatment.

This can disadvantage independent logistics companies.

6. Data Access and Interoperability

Data can be one of the most important competitive assets.

A platform may possess real-time information concerning:

• parcel locations;
• delivery routes;
• customer demand;
• freight rates;
• warehouse capacity;
• delivery performance.

If it refuses reasonable access to indispensable information, competition concerns may arise.

The 2017 Cainiao–SF Express dispute is particularly relevant. Cainiao, Alibaba's logistics-data platform, and SF Express became involved in a dispute concerning logistics information and data sharing. Cainiao disconnected SF Express's data interface, while SF Express-related entities had concerns concerning the sharing of logistics data. The State Post Bureau intervened and the parties resumed cooperation. The dispute did not result in a conventional antitrust judgment, but it illustrates the competition importance of interoperability and control over logistics data.

7. Refusal to Deal

A dominant platform may refuse access to:

• API interfaces;
• warehouse infrastructure;
• parcel lockers;
• routing systems;
• delivery networks;
• customer information;
• digital identification systems; or
• interoperability mechanisms.

A refusal becomes particularly problematic where competitors cannot realistically reproduce the relevant infrastructure.

However, competition law does not automatically require a dominant firm to share every asset or piece of data. Authorities normally have to examine indispensability, feasibility of duplication, competitive foreclosure and legitimate business justifications.

8. Predatory or Discriminatory Pricing

Smart logistics platforms can use algorithmic pricing to:

• charge different commissions;
• offer targeted discounts;
• subsidise selected merchants;
• charge competing logistics companies higher fees; or
• temporarily price below cost to eliminate competitors.

A platform could theoretically use its financial resources to sustain losses until smaller logistics platforms exit.

The 2026 Chinese Internet Platform Antitrust Compliance Guidelines specifically identify concerns involving unfairly high selling prices or unfairly low purchasing prices, including excessive platform fees and low payments to platform businesses under comparable market conditions.

9. Algorithmic Discrimination

Algorithms may create discriminatory conditions between logistics providers.

For example:

The difficulty is that discriminatory treatment may be hidden within complex algorithms.

10. Tying and Bundling

A smart logistics platform might require customers purchasing one service to purchase another.

Example:

Warehouse-management software + compulsory use of the platform's delivery service.

Or:

E-commerce platform access + mandatory use of affiliated logistics services.

The competition-law question is whether the tying arrangement forecloses competing logistics providers and exploits power from the tying market.

11. Mergers and Acquisitions

Competition concerns can also arise when large logistics platforms acquire:

• courier networks;
• warehouse operators;
• parcel-locker companies;
• freight marketplaces;
• route-optimisation companies;
• logistics-data companies; or
• competing platforms.

A transaction may eliminate an emerging competitor before it becomes a serious rival.

Fengchao Network–China Post Smart Delivery case

In 2020, Fengchao Network, associated with SF Express, acquired 100% of China Post Smart Delivery, which operated the "Express Easy" smart parcel-locker business. SAMR treated the transaction as a concentration requiring notification because the relevant turnover thresholds were met. SAMR ultimately found no evidence that the transaction produced effects eliminating or restricting competition, but the case demonstrates that smart parcel-locker consolidation is capable of attracting merger scrutiny.

12. Six Important Case Laws / Cases

Case 1 — SAMR v Alibaba, 2021

This is one of the most important Chinese platform-dominance decisions.

SAMR found Alibaba dominant in China's online retail-platform services market and concluded that Alibaba had required merchants to choose between Alibaba's platform and competing platforms.

The conduct involved:

• exclusivity;
• platform rules;
• data;
• algorithms;
• rewards and penalties.

SAMR imposed a RMB 18.228 billion fine, equivalent to 4% of Alibaba's 2019 domestic sales.

Relevance to smart logistics

A logistics platform may similarly use:

market power + data + algorithms + platform rules + economic incentives

to restrict multi-homing.

Therefore, a smart logistics operator cannot assume that technologically sophisticated exclusivity is outside traditional abuse-of-dominance rules.

Case 2 — SAMR v Meituan, 2021

SAMR found Meituan had abused its dominant position in China's online food-delivery platform services market.

The conduct included:

• differential fees;
• delaying merchant onboarding;
• exclusive cooperation;
• deposits;
• data;
• algorithms; and
• punitive measures.

SAMR characterised the conduct as forcing merchants into "choose one of two" arrangements and imposed a RMB 3.442 billion fine, together with corrective measures.

Logistics relevance

Although the case concerned food delivery rather than conventional freight, it is highly relevant to smart logistics because both involve:

platform → merchants/service providers → algorithmic allocation → network effects → delivery infrastructure.

A dominant logistics platform could face similar concerns if it uses algorithmic penalties or differential treatment to force exclusive use.

Case 3 — Qihoo 360 v Tencent

The Qihoo 360 v Tencent litigation is important for understanding the threshold for establishing dominance in China's platform economy.

The Supreme People's Court considered whether Tencent possessed a dominant position despite its substantial market share.

The case demonstrates that high market share alone does not necessarily establish dominance; market structure, competitive constraints and other economic factors must also be examined.

This is especially significant for smart logistics platforms because a platform may have a very large user base but still face substantial competitive constraints.

The Alibaba analysis itself contrasted Alibaba's dominance assessment with the Supreme People's Court's treatment of market share in Qihoo 360 v Tencent.

Principle

Market share is evidence of market power, not an automatic substitute for a complete dominance analysis.

Case 4 — Cainiao v SF Express Data Dispute, 2017

Cainiao and SF Express were two major participants in China's logistics ecosystem.

The dispute concerned access to and sharing of logistics-tracking data. Cainiao temporarily disconnected SF Express's data interface and SF Express was removed from certain logistics options on Taobao. Regulatory intervention resulted in restoration of cooperation.

Competition significance

This dispute illustrates the importance of:

• data interoperability;
• access to APIs;
• network effects;
• logistics information;
• platform neutrality; and
• potential foreclosure through technical exclusion.

Important qualification

This was not a final antitrust judgment establishing liability. It is better understood as an important regulatory and competition-law illustration.

Case 5 — Fengchao Network–China Post Smart Delivery, 2020

Fengchao Network acquired China Post Smart Delivery's smart parcel-locker business.

The transaction involved competing operators in the smart parcel-locker/last-mile delivery infrastructure field.

SAMR examined the transaction as an unnotified concentration and assessed whether the acquisition could eliminate or restrict competition. It concluded that the transaction did not have such effects, while imposing a penalty for failure to notify before implementation.

Significance

The case demonstrates that:

Control over last-mile infrastructure can itself become a competition-law issue.

For smart logistics, parcel lockers may become strategic bottlenecks because they connect:

e-commerce → courier → consumer.

Case 6 — Tan v Agricultural Products Company, 2026

A particularly relevant Chinese Supreme People's Court case was published in September 2026.

The operator of a logistics/wholesale market serving approximately 90% of the local vegetable supply imposed restrictive contractual conditions on a merchant. The merchant was effectively forced to choose between operating in that market and a competing market, with the transaction service fee increased to three times the ordinary level as a punitive measure.

The Supreme People's Court held that the combination of the exclusivity requirement and punitive fee constituted prohibited exclusive dealing / restricted transaction conduct where the operator possessed market dominance.

Relevance to smart logistics

This is especially useful for logistics-platform analysis because the defendant operated a market infrastructure with strong dependence by users.

The case illustrates how courts can examine:

• market coverage;
• dependence of users;
• contractual restrictions;
• switching possibilities;
• punitive pricing; and
• foreclosure of competing infrastructure.

It is a useful modern illustration of how physical logistics infrastructure can produce platform-like market power.

13. Comparative Case — Amazon Marketplace Antitrust Proceedings

Amazon provides an important comparative example of the problems created when a platform simultaneously operates as:

1. platform intermediary;
2. retailer;
3. logistics operator; and
4. infrastructure provider.

The U.S. Federal Trade Commission and state authorities have alleged that Amazon used interconnected practices to maintain monopoly power, including conduct affecting sellers and competing channels. Separately, in 2026, New Jersey filed an antitrust case concerning alleged monopsony power over Amazon delivery-service partners. These are allegations/proceedings, not final findings of liability.

Logistics significance

The case illustrates that market power can exist not only on the selling side but also on the purchasing side.

Thus, a smart logistics platform could theoretically possess:

• monopoly power over merchants seeking logistics services; and/or
• monopsony power over delivery operators seeking access to the platform.

14. Two-Sided Market Problem

Smart logistics platforms generally operate two or more sides simultaneously.

For example:

Side 1: Merchants
↓
Platform
↓
Side 2: Couriers/logistics providers

The platform may also interact with:

Consumers + warehouses + drivers + advertisers + financial institutions.

Competition authorities therefore cannot examine only one side.

A platform may subsidise one side while charging the other side higher fees.

Consequently, analysis should consider:

• cross-side network effects;
• multi-homing;
• platform switching;
• transaction volumes;
• data feedback loops;
• platform neutrality; and
• competitive constraints.

15. Smart Logistics and Essential-Facility Concerns

An extremely powerful logistics platform may control infrastructure that competitors cannot reasonably duplicate.

Possible examples include:

• nationwide parcel-locker networks;
• unique logistics data;
• critical API infrastructure;
• indispensable routing systems;
• strategically located automated warehouses;
• dominant freight-exchange infrastructure.

The essential-facilities concept, however, should be applied cautiously.

A competitor normally must demonstrate more than mere inconvenience. Questions include:

1. Is the facility genuinely indispensable?
2. Can it reasonably be duplicated?
3. Is access technically feasible?
4. Is refusal capable of eliminating effective competition?
5. Is there a legitimate business justification?
6. Can access be provided without compromising security or privacy?

16. Competition Problems Created by Data

Smart logistics platforms create a particularly strong data-feedback loop:

More shipments
↓
More data
↓
Better algorithms
↓
Better delivery efficiency
↓
More customers
↓
More shipments

This can create an entrenched competitive advantage.

Competition authorities therefore need to distinguish between:

Legitimate efficiency

Using proprietary data to improve delivery efficiency.

and

Potential exclusion

Using data to:

• prevent competitors from competing;
• discriminate against rival logistics operators;
• deny interoperability;
• restrict multi-homing;
• identify and punish customers using competitors; or
• favour an affiliated logistics business.

17. Algorithmic Collusion

Smart logistics platforms can also create risks involving competitors.

Suppose several independent freight companies use a common algorithm to determine prices.

If the algorithm enables competitors to:

• coordinate prices;
• monitor rivals;
• punish deviations; or
• reduce competitive uncertainty,

competition authorities may investigate whether the conduct amounts to a prohibited agreement or concerted practice.

China's Platform Economy Antitrust Guidelines specifically recognise that platform markets require attention to platform market conditions, market power, barriers to entry and effects on innovation when evaluating potentially anticompetitive coordination.

18. Refusal of API Access

For a smart logistics ecosystem, APIs can be strategically important.

For example:

Independent courier → requests API access → dominant platform refuses → courier cannot provide real-time tracking to merchants → merchants migrate to platform-affiliated courier.

The competition question is whether the refusal merely protects legitimate technology or instead forecloses a viable competitor.

Relevant considerations include:

• technical indispensability;
• availability of alternatives;
• interoperability costs;
• cybersecurity;
• privacy;
• investment incentives;
• competitive foreclosure; and
• legitimate operational reasons.

19. Discriminatory Treatment

A dominant platform may treat comparable logistics operators differently.

Examples include:

• different commissions;
• different access to data;
• different API speeds;
• different search rankings;
• different delivery allocations;
• different warehouse access;
• different advertising costs.

China's current platform-compliance framework specifically recognises differential treatment and the use of data, algorithms, technology, capital and platform rules as potential instruments of prohibited monopolistic conduct.

20. Competition-Law Assessment Framework

A smart logistics platform should therefore be analysed through the following sequence:

Step 1 — Define the market

Identify:

• logistics platform;
• freight;
• express delivery;
• warehouse;
• parcel locker;
• last-mile delivery; or
• logistics-data market.

Step 2 — Identify market participants

Examine:

• merchants;
• couriers;
• freight operators;
• warehouses;
• consumers;
• competing platforms.

Step 3 — Measure market power

Consider:

• market share;
• transaction volume;
• users;
• data;
• network effects;
• switching costs;
• financial resources;
• technology;
• entry barriers.

Step 4 — Examine conduct

Ask whether the platform:

• excludes competitors;
• imposes exclusivity;
• ties services;
• self-preferences;
• refuses access;
• discriminates;
• predates;
• manipulates algorithms;
• restricts data;
• engages in anticompetitive acquisitions.

Step 5 — Consider efficiencies

Potential justifications may include:

• cybersecurity;
• privacy;
• fraud prevention;
• delivery quality;
• network reliability;
• investment incentives;
• operational efficiency.

Step 6 — Examine competitive effects

Determine whether conduct:

• forecloses rivals;
• raises entry barriers;
• increases switching costs;
• reduces innovation;
• increases prices/fees;
• reduces quality; or
• restricts consumer choice.

21. Remedies

Competition authorities may employ several remedies.

Structural remedies

• divestiture;
• separation of business units;
• restrictions on acquisitions.

Behavioural remedies

• prohibition of exclusivity;
• non-discrimination obligations;
• API access;
• interoperability;
• transparent ranking;
• restrictions on self-preferencing.

Data-related remedies

• data portability;
• controlled data access;
• interoperability;
• restrictions on combining data from different markets.

Compliance remedies

• algorithmic auditing;
• internal antitrust compliance;
• monitoring;
• periodic reporting;
• independent review mechanisms.

China's enforcement approach increasingly emphasises platform compliance alongside enforcement, including obligations concerning dominant platforms' pricing, trading restrictions, tying, refusal to deal and differential treatment.

22. Key Legal Principles from the Cases

23. Conclusion

Smart logistics platform market power represents a modern form of competition-law power created by the combination of infrastructure, data, algorithms, network effects and vertical integration.

The central competition-law concern is not simply that a platform is large. A large platform can produce substantial efficiencies. The critical issue is whether its accumulated market power is used to exclude competitors, restrict access, impose unjustified exclusivity, discriminate between comparable logistics operators, exploit data advantages, or extend dominance from one market into another.