To quote this paper: E. JULIEN, “The systemic evolution of the market for veterinary medicines and products: an analysis of competitive concerns under competition law”, Competition Forum, 2025, n°0078 https://competition-forum.com. 

The turnover of the veterinary sector has increased significantly over recent years, rising from 3.5 billion euros (excluding taxes) in 2016[1] to nearly 5 billion euros in 2022[2].

The request for an opinion arises in a context of significant developments in the modalities of practising the veterinary profession in France. These structural transformations give rise to concerns regarding the development of practices likely to limit the free exercise of competition by veterinary professional companies, to affect access to care for animal owners, and to restrict the available therapeutic arsenal.

On 18 June 2024, the Minister for the Economy, Finance and Industrial and Digital Sovereignty referred to the Competition Authority, based on Article L. 462-1, paragraph 2 of the Commercial Code, a request for an opinion concerning the competitive functioning of the markets for veterinary medicinal products and veterinary care in France. This referral was registered under number 24/0054 A.

It is worth noting that veterinarians may carry out their medical and surgical activities on animals individually or jointly within sociétés civiles professionnelles, sociétés d’exercice libéral (SEL) or any other type of company, except those granting partners the status of trader, if these comply with the conditions laid down in Article L. 241-17 II of the Rural and Maritime Fisheries Code.

The Competition Authority is required here to examine the distribution chain of veterinary medicinal products. The market for the distribution of these products is analysed at three distinct levels.

First, there is the upstream market. This refers to the manufacturing level of veterinary medicinal products by pharmaceutical laboratories. “Article R. 5142-1 of the Public Health Code defines the manufacturer as ‘the company comprising one or more veterinary pharmaceutical establishments involved, with a view to wholesale distribution, free provision or use in clinical trials on animals, in the manufacture of veterinary medicinal products other than medicated feed’”[3]. The scope of this level covers six major categories of veterinary medicinal products: anti-infectives (representing more than 16% of sales), antiparasitics (more than 22%), reagents, vaccines (more than 19%), biotechnological products and other pharmaceutical products.

There is also the intermediate market. This concerns intermediaries in veterinary medicinal products, including wholesalers, depositaries, purchasing groups, groupings of pharmacists or veterinarians, and professionals authorised to sell medicinal products at retail. These authorised professionals (ayants droit) include pharmacists, veterinarians and farmers’ groups. According to the Association Interprofessionnelle pour l’étude du médicament vétérinaire (AIEMV), the wholesale distribution market amounted in 2022 to more than 1.57 billion euros[4].

Finally, there is the downstream retail market. This involves the sale of these medicinal products by the aforementioned “ayants droit” to end-users such as livestock farmers and pet owners. Veterinarians play a predominant role in this downstream market, since they dispense approximately 80% of veterinary medicinal products to end-users, the remainder being dispensed by producers’ groups (13.3%), pharmacists (5.8%), and very rarely by departmental laboratories and the Directorate of Veterinary Services (0.6%)[5].

There is a price-setting mechanism throughout the chain, which the Competition Authority had to examine.

In principle, the price of veterinary medicinal products is freely determined, unlike human medicines, which are subject to a regulated pricing regime. This freedom exists in a context where there is no reimbursement mechanism, no third-party payer and no form of price regulation for veterinary medicines; it is a completely free market in Europe. Moreover, the veterinary medicinal products market represents only 4% of the human medicinal products market, which partly explains the lower prices of veterinary medicines[6]. However, Act No. 2014-1170 of 13 October 2014 on the future of agriculture, food and forestry introduced a notable exception to the principle of free pricing: for veterinary medicinal products containing one or more antibiotic substances, discounts, rebates, refunds, differentiated general or specific terms of sale within the meaning of Article L. 441-1 I of the Commercial Code, and the granting of free units, are prohibited.

As regards price setting on the upstream market, this involves negotiation between manufacturers and wholesalers. These negotiations are distinct from those between manufacturers and purchasing groups, which determine year-end rebates (“RFA”). However, if a mandate links the laboratory to the wholesaler, the latter may administer the payment of rebates owed to veterinarians under “tripartite” agreements negotiated by the purchasing groups.

In contrast, on the downstream market between the wholesalers and the “ayants droit” negotiation is not truly involved. Most of the time, wholesalers apply to the ayants droit the agent price plus their commercial margin. If veterinarians can optimise their orders, wholesalers may offer logistical discounts or better purchasing conditions.

However, negotiations between manufacturers and purchasing groups — first developed through economic interest groupings such as Isovet — have profoundly transformed veterinary supply by allowing purchasing volumes to be pooled and by obtaining significant discounts, sometimes ranging from 30% to 50%, thus strengthening veterinarians’ competitiveness compared with pharmacies and producers. This model, which emerged in the 1990s and became structured from 2005 onwards, aims to provide all members with homogeneous purchasing conditions despite different individual volumes.

At the same time, another emerging practice has been developed: negotiations conducted by veterinary clinic networks, particularly “corporate” networks, which bring together establishments partly financed by investors. These networks may negotiate directly with laboratories—through their parent company, an internal purchasing group or an independent purchasing group—which gives them consolidated purchasing power and often more advantageous commercial conditions. However, laboratories and wholesalers report strained commercial relations, marked by difficult negotiations, threats of delisting, possible influence on prescribing freedom, and demands for discounts deemed excessive or disconnected from the real value of the products.

From this analytical approach, the members of the Competition Authority were asked to answer the following question: how do these transformations affect the competitive functioning of the veterinary care and medicinal products market in France, and what risks or opportunities do they entail for professional independence, access to care, and diversity of medicinal products?

To address this issue, a first section will analyse the transformations affecting the markets for veterinary medicinal products and care due to the rise of corporate networks (I), and a second section will examine the possible restructuring of the market resulting from the influence of purchasing groups and the ethical framework applicable to veterinarians, which may lead to restrictions on competition (II).

I. The transformation of the structure of veterinary medicinal products and care market

In a first subsection, it will be necessary to explain what a corporate network is and how it operates (A), and then, in a second subsection, to analyse the effects of its proliferation on the market for veterinary medicines and veterinary care (B).

A. The rise of corporate networks

For several years now, the veterinary sector has been characterised by a trend towards the consolidation of veterinary establishments within networks. These networks are known as “corporate networks”. They are veterinary practice companies in which external non-veterinarian investors (often associated with investment funds) hold shares in the company[7].

These networks emerged in France in the 2010s with the creation of groups such as MonVeto, Univet, Vetone or Argos Vétérinaires. The turnover of these networks is mainly composed of the revenue generated by the professional practice sites, including the invoicing of veterinary acts, the sale of medicinal products and associated goods, as well as animal feed. The income of the holding companies comes from the dividends received from the veterinary practice companies and from the invoices issued for service agreements performed by veterinarians.

In 2019, these networks represented only 2% of veterinarians, whereas by the end of 2022 they accounted for around 19%, and nearly 28% in 2025. The seven largest corporate networks now represent more than 960 veterinary clinics and hospital centres, as well as more than 8,000 professionals, 17% of practising veterinarians and 60% of veterinary hospital centres in France[8]. According to one study, more than 20% of the veterinary practice companies existing in 2018 disappeared because of the corporate expansion. Despite this, in 2024, 74% of veterinarians still practise in non-corporate structures (individual practices or small companies)

Moreover, these networks constitute a very significant local concentration. Between 2023 and 2025, every region of mainland France had at least one corporate group. The highest concentrations are most often found in Île-de-France (with 42% of the region’s veterinarians), but also in Auvergne–Rhône-Alpes (19.6%), and in the PACA region (28.4%)[9]. Some of these networks adopt specific strategies, such as Argos, which creates “clusters” of clinics in major cities.

These networks have continued to grow over the years to the point of reaching a new scale. Indeed, in 2025, the 12 identified corporate groups have on average more than 300 veterinarians each. Moreover, 10 networks exceed 100 veterinarians, four of which exceed 500. Above all, the five largest corporates alone account for 69% of affiliated veterinarians. The largest is IVC Evidensia (943 veterinarians in 2025), followed by MonVéto (932) and Sevetys (702)[10].

Veterinary clinic networks attract professionals by facilitating access to essential investments (modernisation, costly equipment, training) and by providing support services that reduce administrative burdens. They also simplify the transfer of clinics for veterinarians wishing to end their activity and offer a more structured and collective mode of practice, better aligned with the expectations of new generations[11].

The growth of these networks may therefore have a significant impact on competition, as the Competition Authority has rightly pointed out.

B. The market effects of a surge in these networks

The rapid expansion of corporate veterinary networks is reshaping the competitive structure of the market, particularly through local concentration and the standardisation of economic practices. The Competition Authority therefore examines these developments considering merger control rules and the prohibition of anticompetitive agreements.

1. Acquisitions of clinics under merger control law

This modification of the market structure may have effects on competition. Indeed, as we have just seen, there may be a high concentration of corporate networks at certain levels. In this opinion, the Competition Authority explains that the integration of a clinic into a network may, in some cases, constitute a concentration within the meaning of Article L. 430-1 of the Commercial Code[12], even if veterinarians remain the majority shareholders: a minority shareholding by a non-veterinarian investor may be sufficient insofar as it enables them to exercise decisive influence over strategic decisions.

To assess whether these concentrations can influence competitive dynamics, the Competition Authority applies the Herfindahl–Hirschman Index, which measures market concentration on the basis of market shares held by operators. The use of this index has shown that, although concentration levels remain generally low at the regional scale, they are already significant in certain departements and very high in numerous municipalities, including those where many veterinarians practice. The Competition Authority attributes this to the multiplication of acquisitions of small clinics, which therefore escape ex ante merger control thresholds.

As a result, in its opinion the Authority indicates that it will pay particular attention to developments in these local markets and recalls that, even when notification thresholds are not met, acquisitions may be subject to ex post control if they strengthen a dominant position to the point of significantly hindering competition, in accordance with the Towercast and Continental Can case law[13].

2. The internal mechanisms of the networks and the risk of price-fixing agreements

At the same time, the Authority analyses the internal mechanisms implemented by certain corporate networks from the standpoint of collusive practices. 

In fact, the Authority notes that the cost of veterinary care has increased in recent years, with a sometimes-sharper rise within corporate networks, where pressure to achieve return on investment may be strong. The dissemination of common pricing grids, the setting of turnover and performance targets, as well as the use of management software that automatically adjusts prices, may in practice significantly limit veterinarians’ ability to set their fees freely.

These networks may indeed require formal confirmation of price updates, reflecting a desire to exercise close control over veterinarians’ pricing policy. In some cases, compliance with these increases is made conditional on access to future investments or recruitment, creating increased economic pressure on practitioners. The Authority also notes that pricing grids are often directly integrated into management software, making the pre-programmed prices difficult to modify manually[14]. This configuration de facto limits veterinarians’ pricing autonomy, as they must alter prices act by act to deviate from the recommended rates, which discourages any adaptation to local market realities[15].

In parallel, the transfer agreements concluded with certain corporate groups include earn-out clauses, which allow the transferring veterinarian to receive part of the sale price only if the clinic reaches specific targets in terms of turnover, margin, or cost control. These mechanisms create a direct incentive to increase billable activity or prices to meet the financial criteria set. When these individual incentives are combined with an already high level of local concentration and with common pricing recommendations within the network, they may align the economic behaviour of affiliated veterinarians[16]. 

3. The potential impact on the economic independence of veterinarians and on local competition

The Competition Authority therefore reaches the following conclusion: the combination of the strong local concentration observed in certain municipalities and the mechanisms implemented by the corporate networks may, if veterinarians are considered autonomous vis-à-vis the network, be analysed as a price-fixing agreement within the meaning of Competition Law.

This could therefore lead to a potential infringement of the commercial and strategic independence of veterinarians who are members of these networks.

Having examined how the Competition Authority analysed the developments in the markets for veterinary medicines and care resulting from the expansion of corporate networks, it is therefore necessary to consider the possible changes proposed by the Competition Authority in this opinion.

II. The potential need for a reorganization of the veterinary medicine and healthcare sector

In this second part, it will be necessary to analyse the effects of purchasing groups on the market and their pro-competitive and anti-competitive impacts (A), and then to examine the issues addressed by the veterinary Code of Ethics that may restrict competition (B).

A. Trading centers: their significant market presence instinctively raises questions about the effects of their actions

The central role played by purchasing groups in the distribution of veterinary medicinal products raises concerns about their impact on competitive balance. The Competition Authority thus assesses whether their negotiating power may distort competition.

1. The concentration of purchasing power and the question of a possible competitive imbalance

Purchasing groups are responsible for negotiating with manufacturers the conditions under which medicinal products are purchased, particularly discounts, the rates of which may vary depending on the animal species treated and the product ranges concerned[17]. Today, they occupy a central position in the distribution of veterinary medicinal products. Their rise in importance results from a trend towards the pooling of purchases initiated by veterinarians seeking to obtain better commercial conditions on strategic product ranges. This dynamic has led to a strong concentration of the market, with five purchasing groups now accounting for more than 70% of veterinary medicinal product purchases in France[18], thereby granting them significant bargaining power vis-à-vis manufacturers.

Manufacturers describe their relations with purchasing groups and clinic networks as very difficult[19]. They denounce demands for very high discounts, threats of delisting, mandatory budgets to remain listed, as well as pressure to limit price increases. They also claim that they can no longer communicate directly with veterinarians, with some purchasing groups even sanctioning laboratories that attempt to circumvent centralised negotiation. According to them, these practices reduce their margins, hinder innovation, and could ultimately reduce the diversity of available medicinal products.

In contrast to the criticisms made by manufacturers, purchasing groups and corporate networks offer a completely different interpretation of their role in the market. According to them, the consolidation of veterinarians into purchasing groups or integrated chains is a logical and necessary development in the face of the commercial power of large international laboratories that, for years, imposed their conditions on a fragmented profession. They point out that the volume-based discount system was created by the laboratories themselves, and that the purchasing groups merely take advantage of it to rebalance the negotiating power in favour of practitioners. As for catalogues, listing tools or colour codes, they argue that these are simple instruments to improve economic readability and assist purchasing decisions, and not mechanisms intended to restrict prescribing freedom: veterinarians, they maintain, remain fully free and legally responsible for prescribing the medicinal product they consider most appropriate. Even products classified as “red” would not be prohibited but merely not discounted or recommended only as a last resort where equivalent alternatives exist. Thus, purchasing groups and corporates claim that their practices are not aimed at constraining prescriptions, but at optimising the organisation of purchases and improving economic conditions in a market that has become more competitive[20].

2. The absence of characterization of a state of economic dependence

The Competition Authority ultimately settled the matter by stating that laboratories are not economically dependent on purchasing groups. Even though these groups now aggregate a large share of veterinary purchases, laboratories belong to large international groups that are very little dependent on the French market and possess substantial investment capacities. Moreover, no purchasing group accounts for more than 20% of a laboratory’s sales, a level far too low to characterise a true situation of dependence. Delistings remain rare, budgets paid to purchasing groups are low and dispersed, and increases in discount levels have been offset by price adjustments. In short, the balance of power does not appear to be distorted, and there is no indication that purchasing groups threaten laboratories’ ability to innovate or to compete effectively.

Therefore, the commercial conditions fall within the normal functioning of competition and do not reveal any concerning imbalance.

B. The revision of the ethical framework to restore competition and transparency

Certain provisions of the Veterinary Code of Ethics may hinder the free play of competition. The Competition Authority accordingly evaluates their necessity and proportionality in light of the ethical objectives pursued.

1. Ethical restrictions affecting the veterinarians’ freedom to set their own fees

Veterinarians are subject to ethical rules set out in Articles R. 242-32 to R. 242-84 of the Rural and Maritime Fisheries Code (CRPM).

The Competition Authority considers that several rules contained in the Veterinary Code of Ethics today create unjustified obstacles to competition and to consumer information, due to the breadth of the provisions, the legal uncertainty they generate, and, in some cases, the restrictions they may entail. Indeed, the Competition Authority had already stated, in an opinion on regulated professions, that competition rules apply fully to the health professions and that any ethical restriction must be strictly necessary and proportionate to ethical objectives; it also emphasised the need for a clear and readable code of ethics to avoid any unjustified impediment to the proper functioning of the market[21].

Firstly, there are the provisions relating to customer diversion. In this regard, Article R. 242-47 of the Rural Code prohibits customer diversion and “any act of unfair competition”. However, the Authority questions the relevance of this second prohibition, since the Code of Ethics itself specifies that only a civil judge has jurisdiction to characterise an act of unfair competition[22]. In practice, this means that disciplinary bodies should not sanction a veterinarian on this basis unless a judicial decision has established the existence of such an act.

Secondly, there are the provisions relating to remuneration and fees. Here, the Competition Authority considers that several provisions of Article R. 242-49 of the CRPM relating to the remuneration of veterinarians lack clarity and are not justified by ethical imperatives[23].

It first notes that the prohibition on setting fees according to criteria likely to compromise independence or the quality of care is redundant with the obligations already provided for in Article R. 242-33, and that, due to its vagueness, it creates unnecessary legal uncertainty[24].

It then observes that the reference to fees set “with tact and measure” constitutes an indeterminate notion, contrary to the clarity requirements of a code of ethics and likely to unduly restrict pricing freedom.

Lastly, the prohibition of practices aimed at lowering remuneration “for competitive purposes” appears both vague, redundant, and contrary to the principle of free price setting.

Consequently, the Authority recommends the deletion or substantial revision of these provisions, which it considers disproportionate and unnecessary for ensuring the quality of care.

2. Limitations on communication and consumer information

Lastly, the Competition Authority identifies issues relating to professional communication. It considers the reference to the “dignity of the profession” in Article R. 242-76 of the CRPM to be too vague, generating legal uncertainty and excessive restrictions[25]. It also recommends abolishing the prohibition on sending pricing or promotional information regarding medicinal products, as this rule is not provided for by European law and unjustifiably restricts competition[26].

The Authority further highlights a lack of price transparency: veterinarians are not required to display their fees on their websites, unlike other health professions[27]. It therefore recommends establishing such an obligation to enable animal owners to compare prices. Finally, it recommends that clinics belonging to a network clearly display this affiliation to guarantee truthful information to clients.

In conclusion, the Competition Authority adopted in this opinion a case-by-case analytical approach. It began with a market analysis to determine whether the elements constituted an infringement of competition law. Following the publication of this opinion, the President of the National Council of the Veterinary Order, Jacques Guérin, stated his intention to consider the recommendations of the Competition Authority, particularly those relating to ethical rules, by incorporating them into the ongoing consultation on the 2027 revisions of the Code of Ethics[28].

Eva JULIEN

[1] See : French Competition Authority, October 13^th, 2025, Opinion No. 25-A-12, 18

[2] See: French Competition Authority, October 13^th, 2025, Opinion No. 25-A-12, 18

[3] See: French Competition Authority, July 26^th, 2018, Decision No. 18-D-15.

[4] See: Interprofessional Association for the Study of Veterinary Medicines, “Marché 2022 France – Chiffres clés”, Annual Report, 2022, available online: https://www.lefil.vet/_contenus_dyn/articles/2274/src/aiemv-marche-2022-france.pdf

[5] Ibid.

[6] See the statistics of the Syndicat de l’Industrie et du Médicament et diagnostic Vétérinaires:

https://www.simv.org/generalites.

^[7] See: French Competition Authority, October 13^th, 2025, Opinion No. 25-A-12, 122.

^[8] See the study by SYNGEV : https://syngev.fr/qui-sommes-nous

[9] See the Veterinarian Database and CNOV DPE Census Database. Processing by the instruction services

[10] See the Veterinarian Database and CNOV DPE Census Database. Processing by the instruction services.

[11] See: French Competition Authority, October 13^th, 2025, Opinion No. 25-A-12, 144.

[12] The classification of a merger could be applied if non-veterinary shareholders, although holding a minority stake in the practice company, control the healthcare facility, meaning they have the ability to exert decisive influence over it, particularly if they are able to block its strategic decisions. In addition to holding voting rights or equity participation, “other factors, such as contractual or financial relationships, combined with the rights conferred upon a minority shareholder, can establish de facto control” (see the French Competition Authority’s Guidelines on Merger Control, paragraphs 30 et seq.).

[13] Judgment of the Paris Court of Appeal, 27 June 2024, Towercast, No. RG 20/04300, paragraph 63. And the judgment of the ECJ, 21 February 1973, Europemballage Corporation and Continental Can Company Inc. v Commission, Case 6-72, paragraph 26.

[14] See: French Competition Authority, October 13^th, 2025, Opinion No. 25-A-12, 190.

[15] See: French Competition Authority, October 13^th, 2025, Opinion No. 25-A-12, 179 and seq. of notice.

[16] See: French Competition Authority, October 13^th, 2025, Opinion No. 25-A-12, 188 and seq. of notice.

[17] See: French Competition Authority, October 13^th, 2025, Opinion No. 25-A-12, 100.

[18] See: French Competition Authority, July 26^th, 2018, Decision No. 18-D-15.

[19] See: French Competition Authority, October 13^th, 2025, Opinion No. 25-A-12, 217.

[20] See: French Competition Authority, October 13^th, 2025, Opinion No. 25-A-12, 221.

[21] See: French Competition Authority, December 31^st, 2019, Opinion No. 19-A-18. See also: French Competition Authority, June 2^nd, 2025, Opinion No. 25-A-08.

[22] See:  French Veterinary Code of Conduct, Article R. 242-47.

[23] See: French Competition Authority, October 13^th, 2025, Opinion No. 25-A-12, 156.

[24] See: French Competition Authority, October 13^th, 2025, Opinion No. 25-A-12, 157.

[25] See: French Competition Authority, December 31^st, 2019, Opinion No. 19-A-18.

[26] See:  French Rural and Maritime Fisheries Code, Article R. 242-76 ; French Public Health Code, Article R. 5141-83 ; Regulation No. 2019/6, article 120.

[27] See: French Rural and Maritime Fisheries Code, Article R. 242-49 which provides that the veterinarian “shall provide the price of the service, when the price is determined in advance or, failing that, a method of calculating this price or a quote for a given type of service” and that he “must respond to any request for information on his fees or on the cost of a treatment”.

^[28] See D. Bosco, « Médecine vétérinaire – L’Autorité de la concurrence se penche sur le fonctionnement concurrentiel de la médecine vétérinaire », Contrats Concurrence Consommation, n°12, 2025, comm. 172.