The Competition Commission of Pakistan (CCP) has imposed a total penalty of PKR 60 million on the All Pakistan Edible Oil Tanker Owners Association (APEOTOA) for fixing transportation charges and allocating business among tanker owners through a restrictive queue system, in violation of Section 4 of the Competition Act, 2010. The Commission imposed PKR 30 million each for price fixing and market allocation.
The case originated from CCP’s market surveillance, which detected circulars fixing transportation charges for edible oil, ghee and fats from Karachi ports to destinations across Pakistan. A suo motu enquiry was initiated in August 2024, followed by a search and inspection in February 2025.
The enquiry established from the material impounded during the search that APEOTOA revised transportation rates 89 times between 2019 and 2025, comprising 52 increases and 37 decreases. Corresponding circulars issued by the Pakistan Vanaspati Manufacturers Association (PVMA) communicated matching rate changes, while APEOTOA representatives acknowledged that transport rates were set through an agreement between the two associations.
The Commission rejected APEOTOA’s claim that its rate circulars were merely advisory, holding that even non-binding recommendations by a trade association may restrict competition by influencing members’ independent commercial decisions. It also relied on the Supreme Court’s judgment in the PVMA case, affirming that competitors must remain free to determine their prices independently.
The Commission separately found that APEOTOA’s queue system allocated consignments among tanker owners instead of allowing independent competition for business. The Association issued parchis for lifting consignments and enforced compliance with the system. A September 2023 circular prescribed a PKR 500,000 fine each for a tanker and its owner for violating specified allocation conditions.
The relevant market was determined as road transportation services for edible oil, ghee and fats across Pakistan. In assessing the penalty, the Commission considered APEOTOA’s substantial market position, the nearly six-year duration of the pricing conduct, senior management involvement, and continuation of rate revisions even after enforcement proceedings commenced.
APEOTOA has also been directed to immediately cease the anti-competitive practices, recall existing price circulars and discontinue the queue system having the effect of dividing the market. It must publish notices in two Urdu and two English national newspapers clarifying that tanker owners are free to independently determine transportation rates and lift consignments irrespective of Association membership.
The penalty must be deposited and compliance reported within 60 days. Failure to comply may attract an additional penalty of PKR 50,000 per day and possible criminal proceedings under Section 38.
