Proposed Commercial Cooperation between Singapore Airlines Limited and All Nippon Airways Co., Ltd.

Notifying Party:

• Singapore Airlines Limited (“SIA”); and
• All Nippon Airways Co., Ltd. (“ANA”),

Summary of Transaction:

Note: The summary information posted on this Public Register on the nature and objectives is provided by the Parties. CCCS makes no representation as to the accuracy or veracity of the summary information posted.

The Parties have entered into a Joint Venture Framework Agreement, pursuant to which the Parties agree to cooperate in relation to, among other things, scheduling, pricing, sales and marketing, and other commercial areas (including expanded code-sharing and special prorate arrangements) to bring about a metal-neutral alliance in respect of services between Japan and Singapore (the “Proposed Commercial Cooperation”).

The Proposed Commercial Cooperation will extend to the overlapping routes (which are set out below) operated by the Parties and the following subsidiaries of the Parties between Japan and Singapore:

• SIA: SilkAir (Singapore) Private Limited, which is in the process of being integrated into SIA; and
• ANA: Air Japan Co., Ltd. and ANA Wings Co., Ltd.

The Proposed Commercial Cooperation is expected to result in significant consumer and economic benefits, and efficiencies. Including, inter alia:

• an enhanced air travel product for Japan to Singapore services;
• expanded virtual networks of the airlines, thereby providing an increased number of service offerings to passengers;
• more competitive fares through the reduction of double marginalisation and better fare combinability;
• significant benefits to corporate account customers;
• benefits to both airlines’ frequent flyer programme members; and
• improved connectivity for both Japan and Singapore, better utilisation of both parties’ assets and combined efforts to recover from the devastating effects of COVID-19, with consequential benefits to both countries’ aviation industry and tourism.

The Proposed Commercial Cooperation relates to the provision of international air passenger transport services. The scope of the Proposed Commercial Cooperation will include all direct services operated by the respective Parties under the SQ and NH flight codes between Japan and Singapore and, where agreed between the Parties, the relevant feeder routes.

The Parties submit that the COVID-19 pandemic has severely impacted the aviation industry, and consequently many airlines are operating at vastly reduced capacities and frequencies. Notwithstanding this, the Parties consider that pre-COVID-19 information (including market shares, operating patterns, flight schedules and pricing information etc.) still provides the most reliable basis on which to assess the present application.

The Parties submit that the relevant routes for the purposes of the competitive analysis should be limited to the Origin-Destination routes where both Parties (including their respective subsidiaries listed above) provide direct and one-stop air passenger transport services, as follows:

Notes: 

1. “vv” is used to indicate services provided in either direction (i.e., “Singapore to Tokyo vv” refers to services provided from Singapore to Tokyo, and from Tokyo to Singapore).
2. For SIN-CTS vv, SIA mainly operates on this route via Scoot Tigerair Pte Ltd., which is excluded from the scope of the Proposed Commercial Cooperation, with some supplementary operations by SIA. For the latest International Air Transport Association season (pre-COVID), SIA operated on this route from 30 November 2019 to 6 January 2020.

Interested parties are invited to submit their views on the Application. If the submission or correspondence contains confidential information, interested parties should also provide CCCS with a non-confidential version of the submission or correspondence.

Comments should reach CCCS no later than 12 Jul 2021. Please write or email your comments

(titled: Comments on Proposed Commercial Cooperation between Singapore Airlines Limited and All Nippon Airways Co., Ltd.)  to:

Attention: Mr. Terence Seah, Deputy Director (Business and Economics)

Interested third parties may request in writing to obtain more information on the transaction.

The Parties have provided an updated submission to CCCS for decision on 24 July 2023 in relation to whether the Proposed Commercial Cooperation would infringe Section 34 of the Competition Act 2004 (“the Act”).

The Parties’ updated submission noted that the relevant routes for the purposes of the competitive analysis should be limited to the origin-destination routes where both Parties (including their affiliates) provide direct and one-stop air passenger transport services: 

In addition to the above, ANA also operates one-stop services from Singapore to 26 destinations in Japan that SIA codeshares on (the “Other Routes”).

The Parties’ updated submissions on the expected consumer and economic benefits, and efficiencies of the Proposed Commercial Cooperation, which are listed above, remains largely the same (edit struck out for reference).