关键词: 乳业反垄断, 乳业高质量发展, 农业适用除外, 转售价格维持

Abstract: The dairy industry possesses both agricultural production and industrial processing attributes, and its antitrust regulation has long faced institutional tensions between agricultural protection and the maintenance of competitive order. This paper focused on whether the agricultural exemption system under Article 69 of China's Anti-Monopoly Law applies to the dairy industry. From the perspective of industrial structure, this paper found that China's dairy market has gradually developed into an oligopolistic competitive structure dominated by a small number of large enterprises, which creates potential anticompetitive risks. Taking the Infant Formula Price-Fixing Case as a typical resale price maintenance (RPM) case, this article argues that the formal identification of vertical agreements may conceal the essence of horizontal coordination, revealing limitations in the current enforcement approach. By clarifying the scope of application of Article 69, improving the regulatory framework for resale price maintenance, and incorporating structural guidance and behavioral constraints at the competition policy level, this paper aimed to achieve a balance between enhancing industrial efficiency and safeguarding market competition, thereby promoting the high-quality development of China's dairy industry.

Key words: Dairy Industry Antitrust Regulation, high-quality development of the dairy industry, agricultural exemption, resale price maintenance