Hello. I am Attorney Lee Young-kyung from Cheongchul Law Firm.

Recently, the sanctions imposed by the Fair Trade Commission regarding collusion in the sugar market have sent a significant shock to the food industry. The so-called 'Big 3' sugar companies, including CJ CheilJedang, Samyang, and Daehan Sugar, were found to have colluded on the fluctuation range and timing of sugar sales prices from 2021 for about four years, resulting in an astronomical fine of 408.3 billion won. This is the second-highest total fine for collusion events in history and represents the maximum average fine per participant (an average of 136.1 billion won per company), clearly indicating how seriously the Fair Trade Commission regards food collusion.

Importantly, the Fair Trade Commission is raising surveillance and sanctions on so-called closely related livelihood items, starting with the sugar collusion, to unprecedented levels; it has been confirmed that intense investigations are ongoing regarding price and supply adjustments in basic food ingredient markets, such as starch syrup, eggs, and pork.

[Investigation and deliberation of collusion on closely related livelihood items confirmed by the Fair Trade Commission in January 2026]

The key phrase that runs through the Fair Trade Commission's main work plans for 2025 and 2026 is 'Livelihood'. In December 2025, the Fair Trade Commission has already made it clear that they will intensively inspect collusion in the four 'livelihood closely related areas' (food, education, construction, energy) in their 2026 report, and that for long-term habitual collusion, they will actively consider price redetermination orders in addition to fines, reinforcing their commitment to strong measures against collusion in closely related livelihood fields. Following this, on February 11, 2026, the Fair Trade Commission participated in the launch of the 'Special Management Task Force for Livelihood Price' in cooperation with multiple ministries to focus on unfair trading practices that undermine price stability, announcing that they will have a 'dedicated team for unfair trading' with the deputy chairperson of the Fair Trade Commission as the team leader, overseeing monitoring and post-management teams and field investigation teams.

Thus, the companies in the four sectors (food, education, construction, energy) pointed out by the Fair Trade Commission should once again review their price determination processes and be particularly cautious about the activities of business associations (organizations). The sanctions against sugar collusion are just the beginning, and strong sanctions against closely related livelihood products, including basic food materials, are expected to continue in 2026. Notably, the newly introduced legal concept of 'information exchange collusion' completely redefines the old notion of 'agreement'; company executives need to be keenly aware that sharing information between competitors through practical operators can lead to fines of up to 30% and price redetermination orders.

Now, compliance with fair trading is no longer just a task for the legal team but has become a core management strategy that determines a company's trust and sustainability. Legal representatives must carefully monitor changing investigation trends and increased sanction levels, establish an internal control system that operates effectively beyond mere formal compliance programs, and in that process, build precise systems through collaboration with law firms experienced in responding to fair trade commission investigations.

Please keep following the recent enforcement cases of the Fair Trade Commission regarding collusion, and if you need expert assistance during this process, do not hesitate to contact Cheongchul.

Cheongchul Law Firm consists of lawyers from the top five large law firms in Korea, the prosecutor's office, and corporate legal teams. Rather than just one lawyer, a team of specialty lawyers related to the case is formed to respond. Cheongchul provides legal consulting that focuses on delivering comprehensive solutions for the entire business beyond resolving specific issues, ultimately achieving what the clients desire. If you need assistance in achieving your goals, please do not hesitate to contact Cheongchul.