Competition Law in Exhibition Stand Contractor Coordination in China

1. Introduction

“Exhibition stand contractor coordination” refers to situations in which competing exhibition-stand contractors, booth builders, exhibition-design companies, event contractors, or related service providers coordinate their prices, customers, bids, market territories, allocation of exhibition projects, subcontracting opportunities, or participation decisions rather than competing independently.

In China, such coordination can fall within the prohibition of horizontal monopoly agreements under the Anti-Monopoly Law (“AML”). This is particularly important in exhibition markets because contractors frequently meet at trade fairs, industry associations, exhibitor networks, procurement platforms, and bidding processes. Communications that appear commercially routine can become problematic if they facilitate coordinated conduct.

Article 17 of the amended AML prohibits competing business operators from concluding or implementing agreements or concerted practices that eliminate or restrict competition. The 2023 monopoly-agreement provisions further develop the rules concerning horizontal agreements and concerted practices. (Global Practice Guides)

There does not appear to be a major published Chinese antitrust judgment specifically involving exhibition stand contractors as such. Therefore, the closest and most useful authorities are cases involving industry coordination, price coordination, market allocation, bidding coordination, trade associations, and other concerted practices.

2. Applicable Chinese Legal Framework

A. Anti-Monopoly Law

The principal provisions are:

Article 17 – prohibition of horizontal monopoly agreements between competitors;

Article 18 – circumstances involving vertical monopoly agreements;

Article 19 – presumptions concerning implementation of monopoly agreements;

provisions concerning concerted practices;

provisions governing industry associations and their role in organizing anticompetitive conduct;

provisions concerning administrative penalties and liability.

For exhibition contractors, Article 17 is normally the central provision because the contractors are usually actual or potential competitors.

B. Bidding Law

Where an exhibition project is awarded through competitive bidding, the Bidding Law may operate alongside the AML.

Typical risks include:

agreeing who will submit the winning bid;

submitting cover bids;

artificially rotating winners;

agreeing bid prices;

agreeing which contractor will abstain;

sharing confidential tender information;

using related companies to create the appearance of competition.

Chinese enforcement authorities and courts have recently emphasized that bid-rigging can involve the entire chain from tender design through bidding and evaluation. (Supreme People's Court)

C. Industry Associations

An exhibition-contractor association cannot safely coordinate competitors merely because the communication occurs through an association.

An association can create serious antitrust exposure where it:

recommends common prices;

divides exhibition projects among members;

coordinates customers;

tells members not to compete for particular exhibitions;

organizes collective refusal to deal;

circulates sensitive future pricing information;

establishes minimum quotation standards.

The Chinese courts have specifically recognized the antitrust liability of industry associations that organize horizontal coordination.

3. What Constitutes “Coordination”?

The most important distinction is between legitimate cooperation and anticompetitive coordination.

Legitimate cooperation may include:

jointly purchasing standardized materials;

subcontracting specialized construction work;

temporary cooperation where contractors genuinely lack capacity;

safety coordination required by an exhibition organizer;

sharing non-sensitive technical information;

complying with venue regulations.

Potentially unlawful coordination includes:

The key question is whether the cooperation replaces independent competitive decision-making with coordinated decision-making.

4. Price Coordination Between Exhibition Contractors

Suppose ten stand contractors regularly compete for exhibition projects in Shanghai.

They meet through an industry association and agree:

“No member will quote below RMB 1,200 per square metre.”

Even if the agreement is informal, this is a serious horizontal-cartel concern.

The contractors might attempt to avoid detection by:

discussing the “normal industry price” rather than expressly saying “minimum price”;

using WeChat groups;

communicating through an association;

exchanging price ranges;

using a third-party consultant;

agreeing on a formula instead of a specific price.

Such techniques do not necessarily avoid AML scrutiny.

The Chinese Supreme People's Court has expressly recognized that concerted conduct can exist without a written or oral agreement, where competitors communicate and subsequently adopt coordinated competitive conduct. (IPC Court)

5. Market or Customer Allocation

Exhibition contractors may be tempted to divide business such as:

Contractor A → automobile exhibitions;

Contractor B → medical exhibitions;

Contractor C → technology exhibitions;

Contractor D → government exhibitions.

This can become a prohibited market-allocation arrangement if the contractors are competitors and the allocation reduces competition.

Other problematic arrangements include:

“You take the Beijing exhibition; we take Shanghai.”

“You handle this pharmaceutical company; we will not approach it.”

“Contractor A gets international exhibitors and Contractor B gets domestic exhibitors.”

“We will alternate major exhibition accounts every year.”

The Supreme People's Court has confirmed that dividing sales markets, customers, market shares, revenues, or profits can constitute horizontal monopoly conduct. (Supreme People's Court)

6. Exhibition Tender and Bid-Rigging

This is one of the highest-risk areas.

Assume an automobile company invites five exhibition contractors to bid for its annual motor-show stand.

Before submitting bids, the five contractors agree:

Company A will win;

Company B will submit a deliberately high bid;

Company C will submit a technically defective proposal;

Company D will abstain;

Company E will act as a “cover bidder.”

That is classic bid coordination.

The Chinese courts have recently emphasized that bid-rigging can occur through multiple coordinated participants, including bidders, tendering personnel, intermediaries and evaluators. (Supreme People's Court)

The conduct may generate consequences under both competition law and criminal law where statutory conditions for the crime of collusive bidding are satisfied.

7. Coordination Through an Exhibition-Contractor Association

This is particularly important.

An association may lawfully:

provide training;

publish safety standards;

promote professional standards;

represent industry interests;

provide genuinely non-sensitive statistical information.

It becomes problematic when it becomes a mechanism for competitors to coordinate.

For example:

“The association recommends that all members charge at least RMB 1,000 per square metre.”

Or:

“Members should not compete for another member's designated exhibition clients.”

Such arrangements can expose both the participating businesses and the association to enforcement.

8. Information Exchange

Information exchange deserves separate treatment.

Exhibition contractors should be particularly cautious about exchanging:

future prices;

future discounts;

quotation formulas;

margins;

customer-specific prices;

intended tender bids;

future capacity;

planned market entry;

strategic customers;

upcoming tender participation.

For example, if Contractor A tells Contractors B and C:

“Our quotation for the electronics exhibition will be RMB 4.8 million.”

and B and C then adjust their quotations accordingly, the communication can become important evidence of coordination.

The Maoming concrete enterprise case is particularly useful because the Supreme People's Court accepted communication/information exchange, coordinated market conduct and the absence of a reasonable explanation as important elements in establishing “other concerted conduct.” (Supreme People's Court)

9. Six Important Chinese Case Laws

Case 1 — Sichuan Cement Association Case

Sichuan Cement Association Organizing Six Cement Operators

The Sichuan cement association organized and promoted six cement businesses to coordinate price increases in the Chengdu area.

The arrangement included coordination concerning:

timing of price increases; and

magnitude of price increases.

The authorities imposed substantial penalties.

The case is highly relevant to exhibition contractors because it demonstrates that an industry association can become the vehicle for horizontal price coordination. (SAMR)

Principle

An association cannot transform an otherwise unlawful competitor agreement into lawful conduct simply by placing the coordination inside an association structure.

Exhibition application

An exhibition contractors' association should therefore avoid:

minimum price schedules;

common quotation rates;

coordinated discounts;

customer allocation;

instructions concerning tender participation.

Case 2 — Waterbrick Association Case

Zhang Mou v. Yibin Hengxu Investment Group and Others

This important Supreme People's Court case concerned an industry association and horizontal coordination among brick manufacturers.

The association coordinated production restrictions, production quotas and pricing arrangements.

The Supreme People's Court emphasized that a participant in a horizontal monopoly agreement cannot generally use its participation in the illegal agreement to claim compensation for losses arising from its own participation in the cartel.

The case is now recognized as Guiding Case No. 221. (IPC Court)

Principle

Participation in an illegal cartel does not create a legitimate entitlement to recover the cartel participant's own losses arising from the cartel.

Exhibition application

If several exhibition contractors jointly agree to suppress competition and one contractor later complains that another contractor obtained a larger share of the cartel business, the complaining contractor cannot necessarily transform its participation into a legitimate antitrust damages claim.

Case 3 — Maoming Concrete Enterprises Case

Maoming Concrete Enterprises Horizontal Monopoly Agreement Case

This is one of the most important Chinese authorities on “other concerted conduct.”

The case involved 19 ready-mixed concrete enterprises.

The Supreme People's Court considered:

communication and exchange of information;

consistency in market conduct;

market structure and competitive conditions; and

whether the businesses could provide a reasonable explanation for their coordinated conduct.

The Court concluded that the businesses' conduct constituted “other concerted conduct” under the AML. (Supreme People's Court)

Principle

The authorities do not necessarily need to find a document saying:

“We agree to fix prices.”

Coordination can be inferred from the combination of communication, information exchange, coordinated conduct and market circumstances.

Exhibition application

This is directly relevant to WhatsApp/WeChat/industry-chat coordination among exhibition contractors.

Case 4 — Chongqing Concrete Enterprises Case

Jiangdu Construction Materials v. Jiandian Concrete

Two concrete companies in the relevant locality agreed to:

fix prices;

divide the sales market;

allocate quantities;

allocate profits.

They also exchanged personnel to monitor compliance.

The Supreme People's Court treated fixed prices and market division as classic horizontal monopoly arrangements. (Supreme People's Court)

Principle

Market allocation can involve much more than geographical territories.

It may include:

customers;

sales revenue;

market share;

sales volume;

profits.

Exhibition application

An agreement such as:

“You handle automotive exhibitions, while we handle pharmaceutical exhibitions”

could attract scrutiny if the parties are competing for those customers and the arrangement eliminates their competition.

Case 5 — Camphor API Case

Camphor Active Pharmaceutical Ingredient Horizontal Monopoly Agreement Case

This case is especially interesting for exhibition-contractor coordination because some coordination occurred through communications at an exhibition.

The Supreme People's Court described communications involving the three relevant producers, including:

WeChat;

telephone calls;

meetings during a pharmaceutical exhibition;

exchange of market information;

discussion of prices;

coordinated responses to customer inquiries.

The Court upheld the finding of horizontal monopoly conduct. (IPC Court)

Principle

An exhibition itself is not the problem.

The problem is using the exhibition environment to facilitate competitor coordination.

Exhibition application

This is an unusually useful analogy:

An exhibition meeting between competing contractors is perfectly legitimate when it concerns ordinary business networking, but discussions concerning future bids, prices, customers or coordinated market behaviour can become evidence of a cartel.

Case 6 — Zhejiang/Industry Association and Vehicle-Inspection Cases

Chinese antitrust jurisprudence also contains several cases involving industry associations and coordinated competitors.

The Supreme People's Court's antitrust case collections include the Hainan fire-protection testing enterprise horizontal monopoly case, the Huizhou motor-vehicle testing industry association case, and other association-driven horizontal arrangements. (Supreme People's Court)

The more recent jurisprudence confirms that an association can be scrutinized where it facilitates coordination among competing businesses.

Principle

An industry association is not an antitrust safe harbour.

Exhibition application

An exhibition-industry association should therefore structure meetings so that competitors do not discuss:

future bids;

individual customer prices;

tender strategies;

minimum charges;

allocation of exhibitions;

refusal to deal;

competitor-specific commercial strategies.

10. A Particularly Important Recent Authority: 2025 Cement Association Case

The Supreme People's Court's 2025 antitrust cases included the provincial cement association horizontal monopoly agreement case, concerning an association that organized and coordinated 13 cement enterprises to implement coordinated price increases. (Quannan Government)

This demonstrates the continuing judicial focus on association-facilitated coordination.

For exhibition contractors, this means that an association's:

WhatsApp/WeChat group,

annual meeting,

conference,

trade show,

pricing survey,

committee meeting,

can potentially become evidence of cartel coordination if competitors use the forum to coordinate competitively sensitive conduct.

11. Tender Coordination: Recent Judicial Approach

The Supreme People's Court and National Development and Reform Commission published six typical collusive-bidding cases in 2025.

They covered conduct such as:

bidder coordination;

cover bidding;

manipulation of evaluation;

intermediary involvement;

bid-price coordination;

use of related companies;

manipulation of tender specifications.

The courts stressed that enforcement should address the entire chain of collusive bidding rather than only the final winning bidder. (Supreme People's Court)

Application to exhibition stands

Consider a tender for a large international exhibition:

Organizer → tender consultant → exhibition contractors → subcontractors

If contractors secretly coordinate their bids, the risk can extend beyond the contractors themselves where other actors knowingly facilitate the arrangement.

12. Legitimate Joint Bidding Versus Illegal Coordination

Not every collaboration between exhibition contractors is illegal.

Potentially legitimate

Two contractors jointly bid because:

one has design capability;

the other has construction capability;

one has local installation capacity;

the project is too large for either contractor alone;

the cooperation produces genuine efficiencies.

The parties should be able to explain the commercial rationale independently of suppressing competition.

High-risk

Two contractors who can independently perform the project agree:

“You submit the bid, and I will submit a higher bid.”

That is fundamentally different from genuine joint bidding.

13. Vertical Coordination Issues

Suppose an exhibition organizer requires an appointed stand contractor to use only a particular lighting supplier, flooring supplier or furniture provider.

This is not automatically a horizontal cartel because the parties may operate at different levels of the supply chain.

However, depending on market power and circumstances, it may raise issues concerning:

exclusive dealing;

tying;

refusal to deal;

abuse of dominance;

vertical monopoly agreements.

Thus, an exhibition ecosystem may involve both horizontal and vertical competition issues.

14. Dominance Issues

A large exhibition contractor could potentially have substantial market power in a narrowly defined market.

Possible relevant markets include:

exhibition stand design services;

exhibition stand construction;

turnkey exhibition services;

specialized exhibition construction;

exhibition services for a particular geographic area;

services for specialized exhibitions.

A dominant contractor should be careful about:

refusing competitors access to essential facilities;

exclusive contracts with exhibition venues;

discriminatory pricing;

tying construction to design;

requiring exclusivity from exhibitors;

predatory pricing;

imposing unfair terms.

However, market leadership alone does not establish abuse of dominance.

15. Relevant Market Definition

The market could potentially be defined according to:

Product dimension

exhibition design;

booth construction;

booth installation;

dismantling;

audiovisual services;

lighting;

furniture;

turnkey exhibition services.

Geographic dimension

Depending on customer substitution and logistics:

city-level;

regional;

national;

specialized exhibition venue markets.

For example, exhibition construction for a major Shanghai exhibition may involve different competitive conditions from ordinary local event construction.

16. Evidence Authorities May Examine

An exhibition-contractor cartel can leave extensive digital evidence.

Authorities may examine:

WeChat messages;

emails;

quotations;

tender documents;

bid histories;

invoices;

contracts;

association minutes;

meeting records;

spreadsheets;

telephone records;

customer-allocation schedules;

pricing formulas;

internal instructions;

shared cloud documents;

communications with intermediaries.

This makes informal coordination particularly dangerous.

The recent Chinese enforcement approach increasingly focuses on reconstructing the coordination architecture, including communications, intermediaries and other facilitating actors. (Lexology)

17. Compliance Measures for Exhibition Contractors

A Chinese exhibition contractor should implement a specific antitrust protocol.

At industry meetings

Employees should not discuss:

future prices;

future bids;

customer allocation;

tender strategy;

competitor margins;

planned discounts.

At exhibitions

Employees may discuss:

technology;

industry trends;

general professional standards;

publicly available information.

They should avoid:

“What are you quoting for this customer?”

“We will not bid if you bid.”

“You take this client and we take the next one.”

“Let's maintain the current price.”

In tender procedures

Every bid should be independently prepared.

Companies should maintain:

independent pricing calculations;

independent technical proposals;

independent approval procedures;

records of legitimate subcontracting arrangements.

18. Risk Classification

19. Defences and Legitimate-Competition Considerations

A contractor facing allegations should distinguish genuine cooperation from cartel conduct.

Relevant questions include:

Were the parties actually competitors?

Was there an agreement or concerted practice?

Was there communication or information exchange?

Did market conduct become coordinated?

Is there an independent commercial explanation?

Was the cooperation necessary to perform a project?

Did the arrangement generate demonstrable efficiencies?

Did customers receive benefits?

Was competition actually eliminated or restricted?

Was the arrangement proportionate to the legitimate business objective?

The Chinese jurisprudence concerning concerted conduct places particular importance on coordinated behaviour, communication/information exchange, market conditions and the existence or absence of a reasonable explanation. (IPC Court)

20. Key Legal Principles from the Six Cases

The authorities collectively establish the following propositions:

1. Association coordination can constitute cartel conduct

Sichuan Cement Association / provincial cement association cases.

2. Market allocation is a classic horizontal restriction

Chongqing concrete case.

3. A cartel does not require a beautifully drafted written agreement

Maoming concrete case.

4. Information exchange can be powerful evidence

Maoming concrete and Camphor API cases.

5. Exhibitions can themselves become venues for cartel communications

Camphor API case.

6. Bid coordination is independently serious

2025 collusive-bidding cases.

7. Participants cannot necessarily recover their own cartel losses

Guiding Case No. 221.

8. Competitors must retain independent commercial decision-making

This is the overarching principle running through the Chinese horizontal-cartel jurisprudence.

21. Hypothetical Example

Assume five exhibition contractors in Beijing regularly compete for international trade fairs.

They create a WeChat group called “Exhibition Industry Cooperation Group.”

They agree:

Contractor A will handle automobile exhibitions;

Contractor B will handle medical exhibitions;

Contractor C will handle technology exhibitions;

no contractor will quote below RMB 1,000/m²;

for major tenders, one contractor will win while the others submit higher bids;

the contractors will exchange their proposed quotations one day before submission.

Legal assessment

This creates several independent competition concerns:

Price fixing
→ coordinated minimum price.

Market allocation
→ allocation of exhibition sectors/customers.

Bid rigging
→ predetermined tender winner.

Information exchange
→ exchange of future quotations.

Association/facilitating mechanism
→ if the association organized or encouraged the coordination.

The arrangement would therefore present extremely high antitrust risk.

22. Conclusion

Competition law risks in China's exhibition-stand contracting sector are not confined to formal written cartel agreements. The most significant danger is coordination among otherwise competing contractors through industry associations, trade exhibitions, WeChat groups, tender intermediaries, informal meetings or reciprocal customer arrangements.

The strongest warning signs are:

price coordination + customer allocation + information exchange + bid coordination.

The Chinese cases involving cement associations, concrete enterprises, industry associations, camphor API manufacturers and collusive bidding demonstrate that authorities and courts are increasingly prepared to infer unlawful coordination from communications combined with coordinated market behaviour, rather than requiring a single written cartel document. (IPC Court)

For exhibition stand contractors, the safest compliance principle is therefore:

Compete independently on price, customers, bids and commercial strategy; cooperate only where the cooperation has a genuine, demonstrable business purpose and does not substitute coordination for competition.