The Sector Inquiry Report on Practices Concerning Handheld Terminals and Similar Devices published by the Competition Authority on 12.01.2026, provides a general framework for the evaluation of the technical features and areas of use of handheld terminals employed in the fast-moving consumer goods sector, as well as their assessment from the perspective of competition law.
According to The Sector Inquiry Report on Practices Concerning Handheld Terminals and Similar Devices (“Report”) published by the Competition Authority (“Authority”), important developments regarding competition law compliance in the fast-moving consumer goods sector have been discussed.
Also, it has been stated that the hardware and software embedded in handheld terminal devices may be used in a manner that could give rise to competition law infringements, and that the Authority will approach digital applications with heightened scrutiny in the course of its investigations.
Handheld terminals are defined as tools that allow monitoring, control, and management of processes such as production, storage, logistics, sales, and customer relationship management in a digital environment.
Within the scope of the Report, the areas of use and technical features of handheld terminals are examined in detail. In this context, it is stated that the devices can be classified as indoor and outdoor devices depending on their place of use. It is determined that indoor devices are mainly used in processes such as tracking warehouse inbound and outbound movements, stock management, and inventory control, while outdoor devices are used in sales, order taking, and field activities. Examinations conducted in terms of hardware and software reveal that the devices operate in an integrated manner with central systems and enable continuous data transmission.
The Report states that handheld terminals are widely used in fast-moving consumer goods retailing. Processes such as order collection, daily route planning, and the recording and reporting of sales data have largely been transferred to the digital environment, and this is noted to play a decisive role in the organization of distribution and sales processes. In this context, handheld terminals are positioned as tools that ensure the continuity of information flow throughout the supply chain.
According to the Report, the risks that handheld terminals may give rise to from the perspective of competition law are addressed under three main headings:
- First, the risk of resale price maintenance is assessed. The examinations indicate that the use of price data collected through handheld terminals for the purposes of price monitoring or price intervention may give rise to a risk of competition law infringement. It is stated that an infringement may occur through resale price maintenance if the supplier restricts the pricing autonomy of dealers and distributors via the systems to which the handheld terminals are connected.
- Second, the risk of customer and territorial restrictions is addressed. It is noted that customer- or territory-based distinctions may be made among dealers and distributors through the central systems to which handheld terminals are connected, and that access to certain customer groups or geographic areas may be restricted. The Report sets out that such practices may constitute customer and territorial restrictions and may amount to a competition law infringement.
- The third risk area relates to discount systems. The Report states that a dominant supplier may collect data on sales prices, sales volumes, and discount information at points of sale through handheld terminals, and that using such data in the creation of discount and incentive schemes may make it more difficult for competing undertakings to operate at the same points of sale. It is emphasized that such practices may lead to exclusionary effects and therefore require assessment under competition law.
Within the framework of the risks identified in the Report, various recommendations aimed at enhancing compliance with competition law are included. In this context, it is recommended that data collected through handheld terminals be transferred to central systems in an aggregated manner as far as possible, rather than at the level of individual points of sale. In addition, it is stated that access to competitive parameters such as price, quantity, stock, customer, and territory should be limited to authorized and a restricted number of personnel, and that user-based roles and authorization definitions should be established.
The Report also includes recommendations to support digital systems with lawful data processing and reporting mechanisms and to provide regular competition law training to field sales staff and managers regarding the use of data obtained through handheld terminals.
Especially for companies operating in the fast-moving consumer goods sector, expanding competition law compliance programs to also cover technological tools and digital systems has become critically important in order to avoid potential administrative fine risks and to ensure full compliance with competition law.
You may access the full text of the Report via this link.
