Online marketplaces are multi-sided platforms, with distinct competitive environments on the consumer and seller side. More competition on both sides can be expected to drive better outcomes for consumers, in the form of lower prices, higher quality and greater innovation. On the consumer side, various core general online marketplaces compete closely, providing a “one‑stop-shop” for consumers who value the ability to transact across many retail categories (in terms of product type, quality and price range), compared to other players which focus primarily at the low-cost end of the market or operate with an otherwise different business model. On the seller side, core general online marketplaces which are open to locally based sellers compete closely, with sellers more limited in their alternative options (as compared to consumers). This chapter defines the relevant competitor sets on both the consumer and seller sides of online marketplaces in Poland, Lithuania and Latvia.
Competition Market Study of Online Marketplaces in Poland, Latvia and Lithuania
Abstract
This chapter examines the competitive constraints on online marketplaces operating in Poland, Lithuania and Latvia, identifying the relevant competitor set on both the consumer and seller sides of these multi-sided platforms, and considering their substitutability with other services. This chapter can be considered as similar to a market definition exercise, which would generally be undertaken by a competition authority to determine relevant product markets under competition law frameworks. However, the context of a market study, which does not seek to enforce competition law under a particular legal framework, but rather to analyse more the state of competition in a holistic manner, allows for a more flexible approach. As such, this chapter provides a preliminary assessment of which market players will be included (and to what extent) as part of the assessment of the state of competition between online marketplaces in Chapter 7. Box 6.1 summarises the approaches taken by competition authorities to market definition in market studies in this sector, providing valuable context to inform the approach taken in this report.
In the context of multi-sided platforms (see also Chapter 2 on the multisided nature), market definition can be approached in two ways: either as a single, integrated market that encompasses all user groups, or as distinct but interrelated markets for each group of users participating on each side of the platform. The appropriate approach depends on the specific characteristics of the platform and the nature of competitive interactions. While some assessments treat multi-sided platforms as a unitary market, reflecting their role as intermediaries between interdependent user groups, others examine each side of the market separately, particularly where the competitive constraints differ significantly between user groups.1
For the purpose of this report, and consistent with the approaches taken by competition authorities as described in Box 6.1, the analysis of competitive constraints takes a two‑sided approach and distinguishes between the consumer side and the seller side of online marketplaces. This approach allows for a more granular assessment of competitive dynamics, recognising that the conditions under which competition occurs, and the relevant constraints, are not necessarily symmetrical across sides, while also acknowledging the interdependencies inherent in platform-based ecosystems.
Across jurisdictions, authorities largely converge on defining a seller-side market for intermediation services that is distinct from consumer-facing retail channels, as competitive conditions for attracting business users differ from those for operating a retail channel. Geographic scope is typically national, with demand- and supply-side constraints predominantly country-specific.
Market-share metrics show more variation. A range of measures – sales value/GMV, number of transactions, revenues, and, in some studies, traffic/online reach indicators – can be informative, depending on the question and data availability. In this context, the analysis generally emphasises traffic metrics (visits, unique visitors, pages per visit, bounce rate) to capture user attraction and engagement, while acknowledging that value‑ and volume‑based measures are frequently used by authorities for share calculations.
Market studies
South Africa – Online Intermediation Platforms Market Inquiry (2023)
This inquiry examined competition across major online intermediation categories in South Africa, with a dedicated module on e‑commerce marketplaces.
Product market(s): Seller-side “provision of marketplace services to business users”; consumer-side “online shopping channels” distinct from offline retail.
Geographic market: National (South Africa).
Metrics: Market shares measured as share of overall e‑commerce GMV (gross merchandise value). Other platform types (e.g. online classified ads services and comparison-shopping services) assessed with order volumes, revenue or unique‑user traffic.
Australia – ACCC Digital Platform Services Inquiry (Final Report, 2025)
The final report reflected a multi-year inquiry into digital platforms, including a strand on general online retail marketplaces operating in Australia.
Product market(s): “General online retail marketplaces” defined as two‑sided platforms connecting suppliers and Australian consumers, excluding online classified ads services.
Geographic market: National (Australia).
Metrics: Market presence assessed through (i) online sales values; (ii) platform revenue growth; (iii) consumer survey data on purchasing; and (iv) monthly average users (MAU). Including MAU highlights that traffic-based indicators are part of the accepted measurement toolkit alongside value‑ and revenue‑based measures.
Mexico – COFECE Investigation IEBC‑001‑2022 (Final outcome, 2025; preliminary opinion 2024)
This investigation reviewed competitive conditions in multi-category online marketplaces in Mexico, considering both seller-facing intermediation and consumer-facing channels.
Product market(s): Separate seller-side market for “marketplace intermediation services for vendors”; buyer-side market for “marketplaces and multi-category online stores for consumers.”
Geographic market: National (Mexico).
Metrics: Market shares calculated by both sales value and number of transactions.
Antitrust cases
All listed antitrust cases address seller-side intermediation services only; consumer-side retail market definitions are not adopted.
Italy – AGCM Case A528 (Amazon, 2021)
The AGCM analysed Amazon’s conduct in relation to third-party sellers on its marketplace, focussing on how intermediation services interact with logistics and visibility tools.
Product market(s): Seller-side “intermediation services on online marketplaces” distinct from proprietary websites or offline retail.
Geographic market: National (Italy).
Metrics: Market shares measured by revenue from marketplace sales (sales value) across the overall market for intermediation services on marketplaces; visitor and traffic data used as supplementary indicators.
European Commission – Cases AT.40 462 / AT.40 703 (Amazon commitments, 2022‑2023)
These cases addressed marketplace conduct and data use across several large EU markets, resulting in commitments accepted by the Commission.
Product market(s): “Provision of marketplace services” to third-party sellers.
Geographic market: National (Germany, France, Spain).
Metrics: The Commission did not publish market shares but relied on internal Amazon measures (Gross Merchandise Sales, Order Product Sales, Glance Views), illustrating how platforms track performance.
UK – CMA Amazon Marketplace Case (2022, Case 51 184)
The CMA investigated marketplace practices affecting third-party sellers and consumer choice in the United Kingdom. The case considered the competitive significance of intermediation services and the role of platform-controlled ranking and visibility.
Product market(s): “Supply of e-commerce marketplace services to third-party sellers to reach customers in the UK.”
Geographic market: National (United Kingdom).
Metrics: Share estimated from third-party sales value and online reach.
Source: Competition Commission of South Africa (2023) Online Intermediation Platforms Market Inquiry: Final Report & Decision, https://www.compcom.co.za/wp-content/uploads/2023/07/CC_OIPMI-Final-Report.pdf; Australian Competition and Consumer Commission (2025) Digital Platform Services Inquiry – Final Report, https://www.accc.gov.au/system/files/digital-platform-services-inquiry-final-report-march2025.pdf; COFECE, “Cofece concluye investigación en comercio electrónico minorista” (Press release, September 2025) https://www.cofece.mx/cofece-concluye-investigacion-en-comercio-electronico-minorista/; Diario Oficial de la Federación, Extracto del Dictamen Preliminar del Expediente IEBC‑001‑2022 (February 2024), https://www.cofece.mx/wp-content/uploads/2024/02/DOF-13febrero2024-01.pdf; Autorità Garante della Concorrenza e del Mercato, A528 (2021), https://en.agcm.it/en/media/press-releases/2021/12/A528; EUR-Lex, Summary of Commission Decision of 20 December 2022 (Cases AT.40 462 & AT.40 703) (OJ C 87, March 2023) https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52023AT40462(01); European Commission, Commitments decision materials in AT.40 462 / AT.40 703 (case file document) https://ec.europa.eu/competition/antitrust/cases1/202310/AT_40703_8990760_1533_5.pdf and https://ec.europa.eu/competition/antitrust/cases1/202252/AT_40462_8825091_8265_4.pdf; CMA (2023) Decision to accept binding commitments, https://assets.publishing.service.gov.uk/media/6544cbaed36c91000d935d20/Non-confidential_decision_pdfa_4.pdf.
The analysis begins with an assessment of the consumer side of online marketplaces, first identifying the main features that distinguish the consumer side of online marketplaces from other retail formats, then assessing the extent to which these platforms may be substitutable with alternative purchasing channels, before finally considering the relevant geographic scope of competition.
6.1.1. Scope of online marketplaces on the consumer side
This section identifies the main features that distinguish the scope of the consumer side of online marketplaces. In defining the consumer side of a multi-sided platform, this assessment focusses on demand-side substitutability, namely whether consumers would switch to alternative channels, and supply‑side substitutability, namely the ability of other firms to switch to supplying these services, in response to changes in price, service quality or product availability. In this context, three key features distinguish the consumer side of online marketplaces from other retail formats.
First, online marketplaces allow consumers to access a wide variety of products from within a single, digital environment. In particular, the presence of multiple independent sellers on the marketplace significantly expands choices of products available to consumers. This breadth of choice is coupled with the possibility to complete purchases from different sellers in a single transaction, thereby minimising transaction costs. Consumers do not need to visit or interact with multiple sellers individually, nor do they need to manage separate purchasing processes, as the platform centralises the offer (Burdon, 2021[1]).
Second, online marketplaces enable real-time price and product comparisons across sellers directly within the platform. This level of price transparency exerts strong competitive pressure on sellers and improves consumer outcomes. Sellers adjust their pricing dynamically in response to visible competitive benchmarks, while consumers are empowered to make informed decisions based on easily accessible information regarding price and product attributes. Such price comparisons are generally not available in offline environments and may be more challenging in decentralised online environments.2
Third and as seen in Chapter 4, online marketplaces typically integrate related services such as payment processing, delivery logistics and customer support into a unified transactional framework. These services reduce frictions for consumers and increase the convenience and predictability of the purchasing process. The platform interface automates key aspects of transactions, including pricing, payment terms and delivery conditions, allowing consumers to complete purchases in a standardised, low-effort manner. Platforms may also offer enhanced personalisation resulting from the platform’s collection of data from specific individual consumers as well as consumers more broadly. Such personalisation, in which the platform customises its offering and recommends products in line with consumers’ preferences, can further lower search costs and reduce frictions for consumers.
While consumers do not explicitly pay for access to the platform or for the transaction-enabling services provided by it, they do pay for the goods purchased, which may indirectly reflect the fees charged by online marketplaces to sellers and may pay directly for the delivery of their goods. As highlighted by the European Commission in the context of market definition, the SSNIP test3 may not be suitable for assessing markets where services are offered for free or where competition unfolds along non-price dimensions. In such cases, competition authorities can consider qualitative evidence regarding service quality, user engagement and network effects4 to define the relevant market.5 Taking a similar approach for the purposes of this report, the consumer side of online marketplaces is shaped to some extent by non-price competition. Platforms also compete on the consumer side to attract and retain users through service quality, product variety, platform reach, convenience and user experience (OECD, 2021, p. 32[2]).
6.1.2. Substitutability between different types of online marketplaces
This section draws distinctions between the different types of online marketplaces and assess the extent to which they are substitutes for one another.
Core general online marketplaces vs. other general online marketplaces
As described in Chapters 2 and 4, general online marketplaces are characterised by their broad product offering. More specifically, most of the major general online marketplaces (e.g. Amazon, Allegro, Pigu) sell across nearly all categories of retail consumer goods and represent a “one‑stop-shop” which allows consumers to transact across many retail categories (in terms of product type, quality and price range), from many third-party sellers, in one place. These platforms enable consumers, within the same interface and purchasing journey, to compare alternative offers across multiple price points and quality tiers, benefit from standardised consumer protection and returns policies and rely on predictable delivery conditions. For the purpose of this report, such platforms are referred to as “core general online marketplaces”.
This is in contrast with other general online marketplaces which focus primarily on the low-cost end of the market or operate with an otherwise different business model. While these platforms may offer a large number of products and cover several retail categories, their offering is typically concentrated on specific price and quality segments and is often associated with longer delivery times, cross-border shipping and more limited or less standardised post-purchase guarantees. As a result, they do not provide a genuinely comprehensive product offering across all retail categories, including in terms of quality, within a single purchasing journey, nor do they replicate the full range of services and transaction certainty that consumers expect from core general online marketplace (Blog M2ecloud, 2025[3]). Although such platforms can be considered general in some respects and, may exert aa competitive constraint in relation to specific product types or use cases, they are not generally closely substitutable for core general online marketplaces from the consumer’s perspective, particularly for higher-value, time‑sensitive or repeat purchases where breadth of choice, reliability and integrated services play a central role.
Indeed, there is evidence of substantial differentiation on the consumer side between core general online marketplaces and other alternatives, such as Temu and AliExpress. First, these platforms are used in different ways by consumers. Stakeholder evidence from all three countries indicates that consumers are highly aware of the risks associated with shopping online from Temu and AliExpress, including in relation to delivery times, product quality6 and the availability of return mechanisms. As such, some stakeholders have suggested that, in some part, consumers use these platforms as a form of entertainment, rather than as a complete substitute for the full offering of core general online marketplaces.
This perception is closely linked to the underlying business model of such platforms, which is centred on offering extremely low prices, often at the expense of delivery speed, product consistency and post-sale support and on maximising user engagement through “gamified” features (such as time‑limited offers, reward mechanisms, interactive promotions and in-app incentives). These design elements encourage browsing and impulse purchasing behaviour, reinforcing the platform’s positioning as a low-cost, discovery-driven shopping environment rather than a reliable, comprehensive retail channel. This is particularly the case for low-value, non-urgent or experimental purchases, where longer delivery times and greater uncertainty as to product quality and returns are more readily accepted by consumers (Darji, 2026[4]). In contrast, core general online marketplaces like Allegro and Pigu are distinguished by their faster delivery times and higher levels of customer service, which are highly valued by consumers in the region.7 As a result, they tend to serve as the default channel for a wide range of purchases, which limits the extent to which low-cost platforms such as Temu and AliExpress can be considered close substitutes from the consumer’s perspective.
This differentiation is also reflected in recent enforcement findings in Poland, where in the context of a 2025 decision on Temu’s unfair market practices, UOKiK highlighted concerns relating to product quality and compliance with EU standards.8 In parallel, the European Commission has issued preliminary findings under the Digital Services Act concerning the risk of illegal products being offered on the platform (European Commission, 2025[5]). These developments seem consistent with stakeholder perceptions of lower transaction certainty and product reliability relative to core general online marketplaces.
To complement the features discussed above, the tables below assess consumer cross-browsing behaviour across online marketplaces. While cross-browsing data does not, in itself, establish demand-side substitutability or switching in a transactional sense, it provides useful indicative evidence on the extent to which consumers consider different platforms as potential alternatives within the same purchasing window. In particular, observed patterns of same‑day cross-browsing can shed light on whether low-cost platforms such as Temu and AliExpress are considered alongside core general online marketplaces in consumers’ decision making processes or whether they tend to be used in a more differentiated and complementary manner.
Looking first at Poland, Table 6.1 represents the share of visitors to each of the top 5 online marketplaces (rows) who also visited each other marketplace (columns) on the same day, within the 12‑month period January 2025-December 2025. As shown in the table, 40‑49% of visitors to Temu, AliExpress, Amazon and Empik also browsed Allegro on the same day, compared to around 5‑9% of visitors to Allegro browsing each of these platforms in return. Thus, even where consumers visit these alternative platforms, Allegro is part of their purchasing decision in many circumstances.
Note: Each percentage in the table represents the share of visitors based in Poland to website A (rows) who also visited website B (columns) on the same day at any point during the specific period.
Source: SimilarWeb data.
Looking next at Lithuania, Table 6.2 represents the share of visitors to Pigu and Varle who also visited each other marketplace (columns) on the same day. As shown in the table, around 34% of visitors to Varle also browsed Pigu in the same day, in comparison to just 21% of visitors to Pigu also browsing Varle. Only 4‑13% of Pigu and Varle users considered alternative platforms, including AliExpress, Temu and eBay. This shows the strong consumer preference towards the use of Pigu and suggests that Pigu and Varle compete less closely with other online marketplaces AliExpress, Temu and eBay which, as discussed previously, target different parts of the market or otherwise operate with a different business model.
Note: Each percentage in the table represents the share of visitors to website A (rows) who also visited website B (columns) on the same day. As this metric cannot be limited to users based in Lithuania, the OECD analysed the behaviour of worldwide users visiting websites with a.lt domain (which generally had around 90% of their total traffic originating from Lithuania). As such, is not possible to include aliexpress.com, temu.com and ebay.com in the rows of the table, as only a small percentage of their worldwide users originate from Lithuania.
Source: SimilarWeb data.
Finally, for Latvia, Table 6.3 shows that only around 6‑13% of 220.lv’s visitors also accessed one of the other top 5 online marketplaces on the same day. Again, this indicates that relatively few users of 220.lv’s platform are considering alternative platforms in their purchasing decisions on the same day and suggests that Temu and AliExpress do not compete as closely with 220.lv.
Note: Each percentage in the table represents the share of visitors to website A (rows) who also visited website B (columns) on the same day. As this metric cannot be limited to users based in Latvia, the OECD analysed the behaviour of worldwide users visiting websites with a.lv domain (which generally had around 90% of their total traffic originating from Latvia). As such, is not possible to include aliexpress.com, temu.com, ebay.com and amazon.de in the rows of the table, as only a small percentage of their worldwide users originate from Latvia.
Source: SimilarWeb data.
Furthermore, user data analysed by the OECD suggests fundamental differences in the uses of these platforms by consumers. Figure 6.1 compares the use of Allegro and Temu by consumers in Poland. As shown in the chart on the left, over the time period May 2023 to January 2026, the average Allegro user visits the platform more times within a month as compared to the average Temu user. The chart on the right shows that Temu’s bounce rate, i.e. the percentage of users leaving the website after a single page view, is consistently higher than Allegro’s. Visits per unique visitor reflects frequency of return or depth of usage across a month, while bounce rate reflects the quality of sessions – in combination, they help distinguish platforms with many brief/low-intent touches from those with fewer but more engaged sessions. Allegro’s profile of higher visits per user but low bounce rates, as compared to Temu, suggests that it sustains deeper and more recurrent engagement. This is consistent with the data presented in Figure 6.2, which shows the proportion of users of Allegro and Temu’s apps who continued to use the app over time. User retention rates were substantially higher for Allegro as compared to Temu, suggest more ongoing engagement from consumers. This is consistent with feedback received from stakeholders about Temu’s use by consumers within the three jurisdictions.
Note: Monthly visits captures the total number of visits to the website from users based in Poland, while unique visitors captures the number of distinct individuals from Poland visiting the website at least once during the month. Visits per unique visitor is a measure of frequency of use, indicating how often the average user visits the platform within a month. Bounce rate is the proportion of visits to the website from users based in Poland ending after a single page view, without any further interactions.
Source: OECD calculations based on SimilarWeb data.
Note: SimilarWeb’s retention rate metric tracks the share of new users (based in Poland) that installed the app, who open the app on day N after installation on a monthly basis. Using these monthly figures, the OECD calculated the average retention rate for each day-mark over the period January 2025-December 2025. The data is available only for users on Android, however Android has an approximately 70% of mobile operating systems in Poland.
Source: SimilarWeb.
In response to consumer perceptions and behaviour, such as those outlined above, both Allegro and Pigu have recently taken action to clearly differentiate themselves from platforms such as Temu by removing offers with long shipping times (mostly from Chinese sellers) from their platforms, therefore offering more goods from local sellers, with shorter delivery times and greater quality control (Reuters, 2025[6]; PHH Group, 2025[7]). Another core general online marketplace, Varle, hosts primarily Lithuanian sellers, as well as some sellers Latvia, Estonia or Poland (and no Chinese sellers) to ensure product quality standards.9
This is consistent with more general evidence that consumers are centralising their purchasing journeys in one core general online marketplace. These shifts in consumer behaviour have been widely recognised – for instance, consumers increasingly start their shopping journeys on these platforms, using them as a default search engine for products (Gemius, 2024[8]; Channelengine, 2025[9]; Allegro, 2025[10]). The European Commission found that a significant share of consumers on Amazon purchase multiple items within one composite shopping basket, meaning that they limit their searches for additional items to the alternatives that available directly on Amazon.10 Another driver of this shift in consumer behaviour is the growth in popularity of consumer loyalty programmes like Amazon Prime or Allegro Smart, which add to the incentives for consumers to focus their purchases on one marketplace.11
In light of the above, the assessment of competition in this report will primarily focus on these core general online marketplaces which compete closely, excluding those with a different business model as described. However, where relevant, the competitive constraint from other types of general online marketplaces will be considered.
In light of the above evidence, core general online marketplaces appear to compete most closely with one another, while other general online marketplaces, i.e. platforms operating predominantly at the low-cost end of the market or under materially different business models, exert a more limited and differentiated competitive constraint. Qualitative stakeholder feedback, enforcement findings and user engagement metrics point to differences in consumer perceptions, purchasing patterns and transaction certainty, which are reflected in cross-browsing and retention data across the three jurisdictions. Accordingly, although low-cost or cross-border platforms may constrain core general online marketplaces in specific product segments or use cases, they do not, in aggregate, constitute close demand-side substitutes from the consumer perspective. The competitive assessment in this report therefore centres on rivalry among core general online marketplaces, while taking into account the potential, more targeted constraints exerted by other platforms where relevant.
General online marketplaces vs. specialised online marketplaces
In contrast with general online marketplaces, specialised marketplaces focus only on a particular retail segment. As such, specialised online marketplaces are an alternative for consumers only as relates to that particular narrow segment (this is analysed in detail below in Section 6.1.3 as relates to specialised online retailers, which similarly operate only within a particular retail segment).
Critically, specialised online marketplaces do not provide consumers with the ability to shop across multiple categories via one platform and a centralised purchasing journey, limiting their substitutability with general online marketplaces. This is because consumers will experience substantially greater frictions in order to shop across multiple specialised marketplaces to receive the same service as via one general online marketplace.
This is consistent with findings from other similar studies or cases looking at online marketplaces, which find that there is greater competition between platforms with multiple product categories and that the constraint from specialised platforms is relatively limited (South African Competition Commission, 2022[11]; COFECE, 2024[12]; AGCM, 2021[13]). Moreover, the use of selection parity clauses by general online marketplaces such as Amazon, which prohibit offering a more extensive product lineup on other platforms, supports the notion that platforms recognise consumers’ preference to purchase various types of products in one place.12
On the supply side, specialised marketplaces may be able to expand their offerings to cover a broader range of products, more directly competing with core general online marketplaces, however substantial investments in seller acquisition and/or substantial changes to their business models would be required.
6.1.3. Substitutability with other retail channels
In light of the main features of the consumer side of online marketplaces identified above, this section assesses whether these platforms are substitutable with other retail channels, specifically the degree of substitutability with brick-and-mortar stores, direct online retailers and OCAS platforms.
Brick-and-mortar stores
Brick-and-mortar stores are traditional retailers operating out of physical stores. These retailers may sell products across many retail segments or specialise in a particular retail segment (e.g. electronics or sports). They represent an alternative purchasing channel for consumers, which may be more relevant for particular consumers in specific purchasing scenarios – for instance, depending on the urgency of the purchase or the desirability of physically inspecting the product before purchase.
However, there are several factors which limit their substitutability with online marketplaces. First, brick-and-mortar stores are unlikely to offer the same breadth of choice in one convenient location, as compared to online marketplaces. This means that consumers are not able to easily access a wide variety of products within one purchasing journey or transaction.
Indeed, due to the ability to offer many more products via an online environment as compared to a physical one, where space is constrained by the physical footprint of the store and its shelf space, certain niche products may not be available for purchase in bricks-and-mortar stores and may only be available via online marketplaces or other online retailers.
Additionally, accessing brick-and-mortar retailers requires in-person visits, which consumers may not consider to be a viable alternative to the convenience of purchasing goods online and having these delivered to a chosen location.13 Moreover, price comparisons across multiple physical retailers are constrained by time and geographic limitations (OECD, 2018, p. 55[14]). As such, while relevant in some specific cases, bricks-and-mortar stores are unlikely to be close substitutes to online marketplaces for consumers in most circumstances.
On the supply side, bricks-and-mortar stores are not easily able to expand to offering online marketplaces services and would need to incur substantial upfront costs in order to do so, including establishing an online retail platform, developing the necessary logistics and delivery infrastructure and investing in user acquisition on both sides of the platform. As such, while it is possible that bricks-and-mortar stores could expand in this way, they are unlikely to be considered close substitutes on the supply-side.
Online retailers
Unlike online marketplaces, direct online retailers do not act as intermediaries for third‑party sellers but instead sell their own goods directly to consumers. Similar to bricks-and-mortar stores, online retailers can operate across many retail segments or specialise in a particular, narrow retail segment.14
Most online retailers specialise in a particular retail category, such as fashion or electronics. Consumers shopping in these categories may shop only from retailers within those categories or in some cases may consider general online marketplaces as alternatives.
To illustrate this, Table 6.4 represents the share of visitors to each website (rows) who also visited each other website (columns) on the same day, looking specifically at several of the top general online marketplaces and specialised fashion retailers in Poland. Table 6.4 below shows that, in general, a greater percentage of users visiting fashion retailers visit other fashion retailers (bottom right quadrant of the table) as compared to general online marketplaces (bottom left) on the same day (with the exception of the leading platform Allegro). The reverse is also true – a greater percentage of users visiting general online marketplaces visit other general online marketplaces (top left) as compared to fashion retailers (top right).
Note: Each percentage in the table represents the share of visitors based in Poland to website A (rows) who also visited website B (columns) on the same day at any point during the specific period.
Source: SimilarWeb data.
Table 6.5 below considers the same exercise for electronics retailers as compared to general online marketplaces. It shows that, on average, a greater percentage of users visiting electronics retailers visit other electronics retailers (bottom left quadrant) as compared to general online marketplaces (bottom right) and vice versa (again, with the exception of Allegro).
However, users of general online marketplaces are more likely to visit electronics retailers than fashion retailers and users of electronics retailers are more likely than fashion retailers to visit general online marketplaces (including Allegro) in turn. This can suggest that electronics retailers may be considered a closer alternative to general online marketplaces as compared to fashion retailers, that being for the narrow product category. However, it is also important to note the different level of product homogeneity between the fashion and electronics categories, which can impact this cross-browsing behaviour. For completeness, the available data shows relatively low levels of cross-browsing behaviour between fashion retailers and electronics retailers themselves.
Note: Each percentage in the table represents the share of visitors based in Poland to website A (rows) who also visited website B (columns) on the same day at any point during the specific period.
Source: SimilarWeb data.
As such, while consumers browsing within a particular category are likely to focus on substitutes within same retail category, consumers may also consider specialised online retailers and general online marketplaces to be substitutable under certain circumstances – namely, when they are shopping for products in this narrow product segment.
However, their narrower product assortment reduces substitutability for consumers seeking one primary purchasing channel which offers a broad variety of products (a so-called “one‑stop-shop”), as discussed above. Consumers will experience substantially more friction and higher search costs in order to access multiple specialised online retailers, as compared to receiving the same service from one online marketplace.
Certain large online retailers, which may more closely match the range of products and the integrated service offering of online marketplaces, are likely to present a closer alternative for consumers. However, due to the lack of third-party sellers present on the platform, they may not offer the same wide reach and breadth of choice as online marketplaces, impacting their substitutability.
On the supply side, online retailers are better placed than bricks-and-mortar stores to expand to offering online marketplaces services due to already having an online retail presence. However, there are still likely to be significant technical adjustments and ongoing transaction costs required to facilitate integration with a multitude of third-party sellers, as well the significant upfront investments required in seller acquisition to match the breadth of sellers available via online marketplaces, limiting their substitutability on the supply side.
OCAS platforms
OCAS platforms primarily function as consumer-to-consumer (C2C) platforms, whereby consumers offer second-hand or other local goods for sale directly to other consumers. Professional third-party sellers are generally absent, and product listings often concern unique, used or low-value items, rather than new, standardised goods.
As a result, OCAS platforms cater to a different consumer demand than online marketplaces. Consumers typically use these platforms to search for bargains, second-hand goods or locally available items, often driven by price sensitivity, environmental considerations or the desire for informal, local exchanges. In contrast, demand on online marketplaces is characterised by a preference for convenience, reliability and a broad assortment of new products, supported by professional sellers, consumer protection, and platform-facilitated payment and delivery options.
Moreover, OCAS platforms generally operate as listing services rather than transactional intermediaries: the platform itself does not facilitate the sale but merely enables contact between users. Consumers must therefore independently negotiate, pay and arrange delivery, leading to a more fragmented and less predictable purchasing experience.
However, some OCAS platforms have progressively integrated marketplace‑like functionalities, such as embedded payment solutions, centralised logistics, and, in certain cases, access for professional sellers. Should this evolution continue, the demand-side gap between OCAS and online marketplaces may narrow, particularly if consumers begin to perceive OCAS platforms as offering comparable levels of convenience and transactional security. Nonetheless, achieving such substitutability would likely require significant investment in infrastructure, trust mechanisms and professionalisation of the platform environment.
6.1.4. Geographic scope of competition
This section turns to the geographic scope of competition on the consumer side of online marketplaces, assessing the extent to which marketplaces outside of a particular jurisdiction constrain those within it and as such, whether they form part of the relevant competitor set. As such, it builds on the previous discussion of the key local characteristics relevant to online marketplaces and related e‑commerce segments in Chapter 5, which considered how the need to provide services in local languages, accommodate consumer price sensitivity, establish effective logistics networks and support domestic payment methods influences the competitive dynamics observed in Poland, Lithuania and Latvia. These factors, both individually and collectively, shape the way platforms interact with users and respond to competitive pressures.
For the purpose of this report, the relevant geographic dimension for the consumer side of online marketplaces is national (consistent with precedent in other studies and cases, see also Box 6.1). Consumer behaviour and platform usage patterns indicate that, in practice, these platforms operate predominantly in a country specific environment. The key driver of this national focus is the way in which online marketplaces cater to localised consumer preferences, infrastructure requirements and regulatory environments.
As already seen in Chapter 5, consumers generally exhibit a preference for online marketplaces that are tailored to their national context. These preferences are shaped by factors such as language, payment options, delivery methods and customer service. Locally tailored platforms not only provide consumers with a more seamless shopping experience but also enhance trust through region-specific features like familiar payment systems (e.g. cash-on-delivery), local customer service and product assortments that reflect domestic preferences. These factors reduce the appeal of cross-border substitution, as consumers are less likely to switch to international platforms that lack such local adaptations due to the substantial frictions involved. Consumer preferences for local platforms will also be affected by the higher shipping costs, speed of delivery and potential duty fees incurred by shopping from outside the jurisdiction.
For avoidance of doubt, this does not require that the platforms originate from within the jurisdiction in order to compete at the national level, but that they sufficiently target their service offering towards consumers in the jurisdiction. However, whether such platforms enter these jurisdictions will depend on their ability to achieve sufficient scale to make it worthwhile to incur the upfront investments and ongoing costs involved in tailoring their service offerings, including to offer support in local languages and establish local logistics networks. As identified in Chapter 5, the size of the local market may be a relevant factor in assessing the likelihood of this occurring.
As such, from the consumer side, the focus of this report is on the provision of online marketplace services to consumers based in Poland, Lithuania and Latvia.
6.1.5. Conclusions
For the consumer side of online marketplaces, the relevant competitor set includes core general online marketplaces operating nationally in each of the three jurisdictions. As relevant, the OECD will also consider the competitive constraint provided by other general online marketplaces, including those with different business models or targeted at the low-cost end of the market.
In some narrow cases, consideration will be given to the extent of competition with alternatives such as specialised online marketplaces or retailers or other large online retailers, as well as the evolving positioning of OCAS platforms. However, the assessment of the state of competition in online marketplaces (set out in Chapter 7) will focus primarily on the case of core general online marketplaces and in some cases, other general online marketplaces.
The seller side of online marketplaces refers to the group of business users, ranging from individual entrepreneurs to large enterprises, who use the platform to reach consumers and complete sales (online marketplaces compete on the seller side to offer their platform and services to sellers; this is distinct from competition between sellers within the confines of the online marketplace). Before analysing competition on the seller side of online marketplaces, it is worth noting explicitly why competition on the seller side of the market matters for consumers downstream. In short, a competitive environment on the seller side can not only be expected to lead to a better offering for sellers, which in turn might translate into lower prices for consumers, but also to create the conditions in which more sellers are likely to enter or expand their retail offerings, leading to greater choice for consumers.
Conversely, ineffective competition on the seller side will also have an impact on consumers. To understand these impacts, it is helpful to understand the relationship between online marketplaces and sellers in terms of bargaining power. Bargaining power, all else equal, can shift the distribution of surplus between these two groups (OECD, 2022[15]).
OECD (2022[15]) identifies a number of ways in which bargaining power can cause potentially harmful effects in downstream markets, beyond transferring surplus from suppliers to buyers which can be applied to the situation of online marketplaces. First, to the extent that online marketplaces have the ability to impose many of the terms of trade (see also Chapter 8), this can alter market outcomes. For example, if online marketplaces can impose vertical restraints, such as MFNs, this can lead to input foreclosure for the marketplaces’ rivals.
More generally however, bargaining power can cause downstream harms by affecting dynamic efficiency and sellers’ ability and incentives to innovate. For instance, if online marketplaces increase sellers’ costs of doing business, in turn eroding their profitability, this can result in sellers exiting or reducing their pace of innovation (see also, (ACCC, 2022[16])). Moreover, such costs might be passed on to consumers.
Further, online marketplaces with bargaining power may use their position to transfer risks onto sellers or otherwise to make the terms of trade unpredictable. Where this results in an inefficient allocation of risk, it can also lead to an overall increase in costs and a reduction in economic efficiency. Increased uncertainty for sellers also contributes to reducing their ability and incentive to innovate, by reducing their ability to predict the likely return from their investments. For consumers, this has direct impacts on their access to innovative products, as well as diversity of choice.
These considerations are especially important in the context of hybrid marketplaces, where online marketplaces compete with their sellers in downstream markets. (European Commission, 2022[17]) notes, in the case of Amazon, that, if Amazon can increase the risks and costs for sellers, this will have the effect of depriving them of scale and marginalising them, reducing competitive pressure on Amazon’s retail business. (South African Competition Commission, 2022[11]) frames this as a raising-rival’s-costs arguments, in which a hybrid platform may have the ability and incentive to raise costs for its rivals on the platform, as it will be easier for its retail business to compete with less efficient firms. Hybrid marketplaces could also use their bargaining power to extract data from sellers that could then help them compete more effectively in downstream markets.
As such, while online marketplaces could use their bargaining power to drive lower prices in the short term, an imbalance of bargaining power can directly cause consumer harms by distorting the competitive process for online marketplaces and in downstream retail markets.
With this context in mind and following the same approach as for the consumer side, this section assesses the seller side of online marketplaces. It first describes the main features that distinguish the seller side of online marketplaces, then considers in turn the extent to which alternative channels may be substitutable, before finally considering the relevant geographic scope of competition.
6.2.1. Scope of online marketplaces on the seller side
This section identifies the main features that distinguish the scope of the seller side of online marketplaces. As with the consumer side, the assessment focusses on demand-side substitutability namely whether sellers would shift their “demand” for online marketplace services to other channels and supply substitutability, namely whether other firms would switch to supplying these services, if the commercial terms of access to online marketplaces changed.
First, one of the main distinguishing features of the seller side of online marketplaces is the immediate access to a broad and diverse consumer base through a single, integrated platform. Unlike independent online retailers or offline sellers, who must individually invest in customer acquisition and visibility, sellers on marketplaces benefit from built-in traffic and exposure to consumers who browse multiple sellers and products within a single session. This aggregation effect intensifies intra-platform competition but also provides sellers with increased opportunities to reach a wider audience than they could independently. Within the platform, sellers on online marketplaces can enhance their visibility and competitiveness through platform-specific features such as advertising placements, product ranking algorithms, discounting tools and promotional offers, limiting the need for sellers to build and optimise their own conversion funnels.15
Second, online marketplaces typically operate under a standardised contractual and transactional framework. Sellers are subject to uniform terms covering pricing, payment processing, delivery logistics and dispute resolution. This reduces the operational costs compared to independent sales channels, where sellers must build their own infrastructure or negotiate terms on a per-transaction basis. Moreover, and as discussed in Chapter 4, marketplaces offer integrated services, such as logistics (e.g. Fulfillment by Amazon), customer service and advertising tools that support sellers and reduce entry barriers for smaller operators.16 In exchange for access to these benefits, sellers pay a variety of fees, including sales commissions, fixed subscription fees and optional charges for value‑added services which are generally linked to the volume or value of transactions.
6.2.2. Substitutability between types of online marketplaces
Similar to the consumer side, this section assesses the substitutability of different types of online marketplaces on the seller side. Notwithstanding the differentiation between core general online marketplaces and all other general online marketplaces detailed above for the consumer side, this section describes a number of additional factors that solidify such differentiation also on the seller side of the market.
First, some general online marketplaces operate with a different business model focussing primarily on intermediation services, without providing other integrated services to sellers. This means sellers are generally responsible for managing all other aspects of their transactions and deliveries. Depending on the needs and characteristics of the seller, the degree of substitutability between these platforms and those with more integrated product offerings will vary.
Within the category of general online marketplaces, this is a substantial first element of differentiation between core general online marketplaces and the broader category of marketplaces operating under different business models, as it is the case for low-cost platforms such as Temu and AliExpress. Core general online marketplaces provide access to a broad and heterogeneous consumer base, encompassing multiple price points, quality tiers and purchasing use cases. By contrast, as described in Section 6.1.2, low-cost platforms differ significantly in terms of the type of consumer audience that sellers are able to reach. These platforms typically attract a more price‑sensitive audience, with purchasing behaviour concentrated on low-value, standardised products, limiting their attractiveness for sellers seeking to offer higher-quality, branded or higher-margin goods.
Second, these differences are also linked to the underlying business model and the range of services offered to sellers. As already mentioned, platforms such as Temu operate with a highly centralised and tightly controlled model, characterised by aggressive price positioning, platform-driven discounting strategies, and limited seller discretion over pricing, branding and presentation.17 Sellers are expected to align with platform-imposed pricing and promotional strategies, which prioritise volume and low prices over margin optimisation, regardless of the nature of the product proposed. This contrasts with core general online marketplaces, where sellers typically retain greater autonomy over pricing, assortment, branding and customer positioning, and can combine organic visibility with paid tools to target different consumer segments.
In addition, the product categories most commonly traded on low-cost platforms tend to be those associated with thin margins, low shipping costs and low average basket values. As a result, these platforms are less suitable for sellers operating across multiple retail categories, offering higher quality or branded products or relying on repeat purchases and customer relationships. The specific brand image and consumer expectations associated with low-cost platforms may further limit their substitutability for sellers concerned with quality perception and brand positioning.
Third, the services offered to sellers also differ in ways that affect switching. Core general online marketplaces typically provide integrated fulfilment and delivery solutions, including warehousing, last-mile delivery partnerships and returns handling. Many sellers rely on these services to ensure fast and predictable delivery. By contrast, other types of marketplaces, such as low-cost platforms, generally require sellers to organise logistics themselves or operate within a different shipping structure. Moving from a platform with integrated local fulfilment to one without it may therefore require sellers to arrange and manage these functions independently, involving additional costs and operational adjustments (Hannig, 2025[18]). This seem to reduce the practical substitutability between these types of marketplaces.
Finally, specialised online marketplaces might present an alternative to general online marketplaces only for sellers which operate in that particular retail segment. These sellers can consider the use of either channel to reach consumers. However, sellers may consider these channels to be complementary (e.g. see (AGCM, 2021[13])), due to the need to reach consumers who prioritise the convenience of accessing a wide range of products via one centralised interface, as described in Section 6.1. Moreover, specialised online marketplaces operating in a particular retail segment (e.g. electronics, fashion) will not present a viable alternative for sellers who do not sell any products from that retail category or for sellers operating across multiple segments. These sellers may prefer general online marketplaces which allow them to present their entire product offering via one channel. As such, these platforms are not close substitutes on the seller side.
6.2.3. Substitutability with other retail channels
Looking at substitutability, the extent to which sellers can realistically shift to other sales channels varies significantly depending on the alternative. For the purposes of this analysis, this section will assess the alternative sales channels already identified in the context of the consumer side, namely brick-and-mortar stores, direct online retail and OCAS platforms.
Brick-and-mortar stores
First, this section considers brick-and-mortar stores. For sellers considering this as an alternative sales channel, multiple different business models are available, including operating a vertically integrated business, i.e. opening their own brick-and-mortar store or supplying goods to brick-and-mortar stores as a wholesaler (instead of as a third-party seller) under particular terms and conditions.
There are high barriers to entry for online marketplace sellers considering operating brick-and-mortar stores. Directly running brick-and-mortar operations involves substantial upfront and operational costs, such as leasing premises, hiring staff and establishing supply chains, and requires time‑consuming investments in customer acquisition, including advertising, brand-building and establishing consumer trust. In contrast, online marketplaces offer instant access to consumers with less need for physical infrastructure. Given these high costs and differences in operational requirements, brick-and-mortar stores do not represent a feasible alternative for most online marketplace sellers.18
Furthermore, sellers are unlikely to consider supplying goods to brick-and-mortar stores as a wholesaler to be easily substitutable to selling directly to consumers via online marketplaces. This would require a substantial shift of business model in order to supply products in bulk to brick-and-mortar retailers in line with their specific demands and constraints, foregoing the flexibility of selling directly to consumers via the online marketplace, including controlling stock and price levels.
Online retailers
Second, this section considers direct online retailers. In the same way as for brick-and-mortar stores, sellers can consider operating their own online store or supplying goods as a wholesaler to other online retailers.
When considering directly running their own online store, sellers are responsible for their own digital marketing, logistics and customer support. Moreover, website design, hosting (including domain registration and server capacity) and ongoing maintenance or technical support also entail significant costs. Most critically, sellers operating their own online stores need to incur substantial costs in order to independently build their own consumer traffic, rather than acquiring this directly from the online marketplace. This includes the complexity and costs involved in setting up their own advertising and customer acquisition funnels, without benefitting from the same scale and network effects as compared to online marketplaces.
Moreover, sellers establishing their own online stores are unable to benefit from the shared infrastructure, including website, payments and logistics infrastructure, offered by online marketplaces. While sellers may be able to separately acquire these services from different vendors, the convenient and integrated service offering provided by online marketplaces (including the addition of add-on fulfilment services) substantially lowers frictions for sellers. Particularly for smaller sellers that do not benefit from the same economics of scale, the scalable infrastructure of marketplaces is likely to offer a more viable commercial route than setting up standalone operations. These differences in operational requirements and the need for substantial upfront investment further limits the substitutability between online marketplaces and other online sales channels for sellers. As such, while such a move may be feasible for relatively big sellers, this is likely to be substantially difficult for the vast majority of sellers using these services.
As flagged above for both brick-and-mortar stores, sellers also have the option of supplying goods to other online retailers via a wholesale relationship. In the same way as for brick-and-mortar stores, this is not closely substitutable for the option of selling directly to consumers via online marketplace platforms, due to the substantial shift of business model required.
OCAS platforms
Third, this section assesses OCAS platforms. The nature of these platforms, which primarily function as C2C platforms for second-hand goods, means that they are not available sales channels for professional sellers with broader distribution needs. This means they are not substitutable alternatives for most sellers on online marketplaces.
Moreover, to the extent that sellers are even able to access these platforms, they are characterised by minimal intermediation, offering basic listing functionality without integrated transaction or logistics services. Sellers shifting to these platforms would lose access to critical marketplace features, such as secure payments, fulfilment infrastructure and consumer trust mechanisms and would need to incur substantial costs to manage these aspects themselves. As discussed above, OCAS platforms may evolve over time to incorporate more similar features to online marketplaces or opening up to professional sellers, rather than only focussing on C2C transactions. However, this would require significant investments in comprehensive integrated services and infrastructure on the part of the OCAS platforms in question.
6.2.4. Geographic scope of competition
Next, this section assesses the geographic scope of competition on the seller side of online marketplaces, building on the similar analysis of the consumer side in Section 6.1.3.
Sellers looking to reach consumers in one specific jurisdiction are inclined to use platforms that specifically target consumers in those jurisdictions. As described above, such platforms will be tailored to the local context, including offering support for local languages and payment methods and local delivery infrastructure. This is the case for sellers that are based within the jurisdiction (including multi-national sellers with a local presence) and sellers from outside the jurisdiction.19
However, there may be marketplaces which target consumers in a particular jurisdiction, but which are not open to sellers based within the same jurisdiction. This means that these platforms are not available as substitutes for sellers based in a particular jurisdiction looking to reach consumers within that same jurisdiction. This was considered, for example, by the Polish Competition Authority (UOKiK) in its assessment of Allegro’s acquisition of Mall Group in 2022. UOKiK found that not all online marketplaces platforms available to Polish consumers were open to Polish sellers at the time and therefore, it considered that those did not operate in the domestic market of intermediation services in online sales between sellers and consumers (i.e. online marketplace services).20
As such, and for the purposes of this report, the geographic scope of competition on the seller side is also considered to be national (consistent with the approaches taken by other jurisdictions as highlighted in Box 6.1), covering online marketplace services targeted at consumers based in Poland, Lithuania and Latvia. However, online marketplaces which are closed to locally based sellers cannot be considered substitutable alternatives for sellers based in Poland, Lithuania and Latvia. Therefore, this report considers the state of competition between online marketplaces which meet both of these criteria.
6.2.5. Conclusions
For the purposes of the analysis in this report, the relevant competitor set includes core general online marketplaces operating nationally in each of the three jurisdictions and which are open to locally based sellers. As relevant, the OECD will also consider the competitive constraint provided by other general online marketplaces, including those with different business models or targeted at the low-cost end of the market, which might provide an alternative for certain categories of sellers in specific circumstances.
While some sellers may operate across multiple complementary channels, the services offered by general online marketplaces are not readily substitutable with the alternative channels considered. For sellers that operate in specific retail segments, such as fashion or electronics, specialised online marketplaces may be considered substitutable in some cases, however sellers are more likely to consider these channels to be complementary to the extent that they need to reach consumers who use general online marketplaces as their primary purchasing channel.
Online marketplaces are multi-sided platforms, with distinct user groups and competitor sets on each side of the platform.
On the consumer side, the relevant competitor set includes core general online marketplaces operating nationally in each of the three jurisdictions – namely, those general online marketplaces which provide a “one‑stop-shop” for consumers who value the ability to transact across many retail categories (in terms of product type, quality and price range). Other general online marketplaces which focus primarily at the low-cost end of the market or operate with an otherwise different business model also provide some degree of competitive constraint, despite competing less closely.
On the seller side, the relevant competitor set includes core general online marketplaces platforms, which offer a specific set of services to a broad range of sellers as well as a degree of autonomy in terms of pricing and branding, open to locally based sellers. Sellers are more limited in their alternative options (as compared to consumers). All other general online marketplaces operating under different business models might offer an alternative to specific categories of sellers in some circumstances but cannot be considered as closely substitutable to core marketplaces. Where sellers operate across multiple channels, these may be considered as complementary for sellers that still need to reach consumers who use general online marketplaces as their primary purchasing channel.
More competition between online marketplaces on the seller side can not only be expected to lead to a better offering for sellers, which in turn might translate into lower prices for consumers, but also to create the conditions in which more sellers are likely to enter or expand their retail offerings, leading to greater choice for consumers. Conversely, ineffective competition on the seller side can affect sellers’ ability and incentives to innovate or result in an inefficient allocation of risk, which can lead to an overall increase in costs and a reduction in economic efficiency.
References
[16] ACCC (2022), Digital platform services inquiry interim report No. 4 – General online retail marketplaces, https://www.accc.gov.au/system/files/DPB%20-%20DPSI%20-%20March%202022%20-%20Full%20interim%20report%20-%2031%20March%202022.pdf.
[13] AGCM (2021), Case A528 — Amazon Logistics, Decision of 30 November 2021.
[10] Allegro (2025), Trading platforms are increasingly becoming the starting point for online shopping – Allegro is at the forefront [translated], https://media.allegro.pl/430803-platformy-handlowe-coraz-czesciej-punktem-startowym-zakupow-online-allegro-na-czele.
[3] Blog M2ecloud (2025), Selling on Temu: What Makes This Marketplace Different from the Rest?, https://blog.m2ecloud.com/selling-on-temu-what-makes-this-marketplace-different-from-the-rest/.
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[12] COFECE (2024), File IEBC-001-2022, Preliminary Opinion issued on February 6, 2024.
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[5] European Commission (2025), Commission preliminarily finds Temu in breach of the Digital Services Act in relation to illegal products on its platform, https://ec.europa.eu/commission/presscorner/detail/en/ip_25_1913.
[17] European Commission (2022), Commission Decision - Cases AT.40462 (Amazon Marketplace) and AT.40703 (Amazon Buy Box).
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[19] OECD (2023), Algorithmic competition – Note by Italy, OECD Competition Committee. OECD Unclassified document, https://one.oecd.org/document/DAF/COMP/WD(2023)10/en/pdf.
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← 1. See European Commission, Notice on the definition of the relevant market for the purposes of Union competition law, (2023/C 399/01), para. 95; and also this Note by Italy to the OECD Algorithmic competition roundtable (OECD, 2023[19]) on the Amazon FBA case (‘In defining relevant markets, the AGCM adopted a multi-market approach by defining as many relevant markets as the sides of a platform: in this case, it defined a market for e‑commerce intermediation services via “horizontal” (i.e. generalist) marketplaces on the sellers’ side only (e.g. all the intermediation services for sellers to reach out consumers), although the Authority indirectly considered the services provided by marketplaces to consumers (e.g. search and ranking, product reviews, refund policies).’).
← 2. In some cases, comparison shopping services (CSS) can also support real-time price and product comparisons across multiple online marketplaces or retailers.
← 3. The Small but Significant and Non-transitory Increase in Price (SSNIP) test is a conceptual tool used in competition law to define relevant markets. It assesses whether a hypothetical monopolist could profitably impose a small but significant (typically 5‑10%) and non-transitory increase in price. If consumers would switch to alternative products or suppliers in response to such a price increase, those alternatives are considered part of the relevant market.
← 4. European Commission, Notice on the Definition of the Relevant Market for the Purposes of Union Competition Law, 2024, para. 31.
← 5. European Commission, Notice on the definition of the relevant market for the purposes of Union competition law, (2023/C 399/01), para. 97.
← 6. This is also supported by the recent Decision No. DOZIK‑9/2025 by UOKiK (addressed also below), where serious doubts about the quality and nature of the products offered on Temu were explicitly expressed.
← 7. E.g. see Gemius, E-commerce study in the Baltics – 2024, https://gemius.com/blog/e-commerce-study-in-the-baltics-2024/, 2 May 2024; Reuters, Amazon leans into video in emerging Europe's online marketplace fight, 9 April 2024, https://www.reuters.com/business/retail-consumer/action-amazon-leans-into-video-emerging-europes-online-marketplace-fight-2024-04-09/.
← 8. Decision No. DOZIK‑9/2025, see also https://uokik.gov.pl/en/is-the-discount-obvious-to-everyone-not-necessarily-lowest-price-in-the-30-days-before-the-discount-penalties-for-zalando-and-temu.
← 9. https://kaup24.ee/ru/a/%E2%80%9CPigu.lt%E2%80%9D%20Drastically%20Reduces%20Number%20of%20Chinese%20Sellers%E2%80%99%20Products.
← 10. European Commission, Case AT.40 703 – Amazon Buy Box.
← 11. Ibid.
← 12. For example, in a case handled by the JFTC, the authority raised concerns also about clauses requiring equivalence in product assortment, which were subsequently eliminated, https://www.jftc.go.jp/en/pressreleases/yearly-2017/June/170601.html.
← 13. And vice versa, in some situations consumers will choose physical stores allowing them to get to know the product physically before purchasing it, an element which further differentiates the sales channels.
← 14. The French Competition Authority’s in-depth study explains how online sales do not always substitute physical store sales: for some goods, the immediacy of need, the value of touching/seeing the product, or large / bulky items make online less attractive, https://www.autoritedelaconcurrence.fr/sites/default/files/9782111572874_Commerce-en-ligne_final.pdf.
← 15. In this context, the European Commission stated in paragraph 173 of its decision in Case AT.40 703 – Amazon Buy Box that “sales through the Buy Box represent the vast majority of all transactions on each of Amazon’s e‑commerce platforms” underscoring the central role of such tools in shaping competition between sellers on the platform.
← 17. In this context, the Bundeskartellamt has even opened an investigation into whether Temu improperly influences merchant pricing, reflecting concerns about platform-imposed pricing constraints on sellers, https://www.bundeskartellamt.de/SharedDocs/Meldung/EN/Pressemitteilungen/2025/10_08_2025_Temu.html.
← 18. This is in line with the European Commission’s approach, which states that selling through e‑commerce platforms differs fundamentally from operating brick-and-mortar stores, particularly in terms of initial investment requirements, operating cost structures, and the timeframe for achieving profitability. The Commission also highlights that, as recognised in previous decisions at both EU and national level, online and offline channels exhibit markedly different geographic scopes. Moreover, the market investigation in the case revealed that retailers themselves tend to view the two channels as distinct and complementary. See European Commission, Case AT.40 703 – Amazon Buy Box Decision of 20 December 2022, para. 73.
← 19. The location of third-party sellers using a marketplace is not necessarily determinative of the geographic scope of the marketplace’s operations. While sellers based in other countries may access the marketplace, they typically do so to reach consumers located within the marketplace’s target country. In practice, sellers that wish to access consumers in a specific national market must choose platforms that are tailored to that market, offering local language interfaces, relevant payment and delivery options, and visibility among domestic users. As such, the geographic focus of a marketplace is shaped primarily by the consumer base it serves, rather than the origin of the sellers operating on it. As noted by the European Commission, a seller wishing to target consumers in Germany, for instance, would need to choose a marketplace tailored to the German market; the same holds true for sellers aiming to reach French or Spanish consumers. The geographic focus of a marketplace is thus shaped primarily by the consumer base it serves. See European Commission, Case AT.40 703 – Amazon Buy Box, Decision of 20 December 2022, para. 76.
← 20. UOKiK decision, Allegro/Mall Group.