While there is a debate to have on the point, it is generally agreed that the UK’s Competition and Markets Authority (CMA) and the EU’s Competition Directorate-General, have become closer to the executive branch. An example is the CMA’s recognition to support competitiveness in a broader international context. Would this extend to industrial chokepoints?

Published: 24 February 2026
Authors: Kiran Desai

Two studies named in a Financial Times article identify chokepoints, namely, goods or services where Europe is particularly strong and others (in particular, China and/or the USA) are reliant on Europe. For example, countries outside Europe are reliant on the chip production machinery produced by Dutch firm ASML.  One study identified 41 chokepoints where China depends upon the EU for 80 per cent of its imports, and 67 chokepoints where the United States is as dependent.

Competition authorities such as the CMA might be persuaded by the executive branch to implement competition law such that a merger that creates or strengthens a UK‑based chokepoint may be welfare‑enhancing or strategically desirable even if it lessens competition downstream.

Existing UK checkpoint examples include the civil nuclear fuel cycle (conversion, enrichment, services) as the UK (via Urenco) sits at the core of Western uranium enrichment capacity. Any merger consolidating enrichment, fuel services, or small modular reactors (SMR)‑linked fuel supply would strengthen a strategic chokepoint even if it reduced competition. Hypothetical others include aerospace engines and related high-value components, pharmaceutical manufacturing, advanced therapeutics, vaccine process development, interest rate derivatives clearing, FX trading, certain commodities benchmarks, and certain defence inputs.

Speculatively, sectors that could become UK chokepoints if major mergers were allowed include AI compute infrastructure and model deployment platforms, satellite services and space-based data (earth observation, navigation augmentation), and synthetic biology platforms (design-build-test infrastructure).

As regards practicalities, the legal advisory role comes in the ability to deliver a successful outcome for parties in the context of the tension that exists in the UK between the current law, which identifies the CMA should block mergers that likely result in a substantial lessening of competition, and the political agenda, recognised by the CMA, where “the need for capital” (read, transactions) are important “to unlock opportunities in critical sectors where the UK has a comparative advantage, like life sciences and AI”, (Doug Gurr, Interim Chair, CMA, speech, 23 October 2025) which is classic industrial-policy language.