Notification | Pending
CCS Seeks Public Feedback on the Proposed Acquisition of NatSteel by Zenith Singapore
21 September 2026
Reference: | CCS 400-140-2026-006 |
Notifying Party: | Joint notification by:
|
Legal Representative(s): | Allen & Gledhill LLP |
Notifying Date: | 31 July 2026 |
Summary of Transaction: | 1. the names of the merger parties; The merger parties are Zenith Steel (Singapore) Pte. Ltd. (“Zenith Singapore”) and NatSteel Holdings Pte. Ltd. (“NatSteel”), which is wholly owned by Toptip Holding Pte. Ltd. (“Toptip”). 2. a description of the transaction; The proposed acquisition of NatSteel by Zenith Singapore (collectively, the “Parties”) from Toptip (the “Proposed Transaction”). 3. a description of the business activities of the merger parties worldwide and in Singapore; Zenith Singapore Zenith Singapore is a private company incorporated in Singapore. Zenith Singapore has two wholly owned subsidiaries, Super Steel Pte. Ltd. (“Super Steel”) and Super Bend Pte. Ltd. (“Super Bend”). Through Super Steel and Super Bend, Zenith Singapore is involved in the processing and distribution of reinforcing steel products for the construction industry. Zenith Singapore is a wholly owned subsidiary of Zenith Steel Group Company Limited. NatSteel NatSteel is a company incorporated in Singapore, with a presence across Southeast Asia. It provides steel products and solutions to the construction industry. In particular, it is involved in the processing, and distribution of reinforcing steel products, as well as the recycling of metal. 4. a description of the overlapping goods or services, including brand names; The Parties submit that they overlap in the processing and distribution of reinforcing steel products. Specifically, in the following products:
collectively, the “Overlapping Products”. 5. a description of substitute goods or services from demand-side and supply-side considerations; Demand-side substitutes The Parties submit that in respect of cut and bend, prefab and rebars, these generally constitute basic construction materials and each product does not currently have viable substitutes, although structural steel and mass engineered timber could potentially replace certain components of civil structures. In practice, however, the Parties submit that customers tend to address their requirements by switching between alternative suppliers of cut and bend, prefab and rebars, including main contractors, subcontractors and precast manufacturers that process rebars on-site, or other market suppliers. In respect of couplers, while these also generally constitute basic construction materials, “lapping” is considered a close alternative to coupling. Supply-side substitutes The Parties submit that suppliers have been observed to move between supplying different types of reinforcing steel products. 6. the Applicant’s views on: (i) the definition of the relevant market(s); The Parties consider that the relevant market for the purposes of this notification is the processing and distribution of reinforcing steel products in Singapore (“the Relevant Market”). (ii) the way in which competition functions in this market; The Parties submit that competition in the Relevant Market is primarily price-driven, as the market is subject to strong competitive pressures from competitors, as well as strong countervailing buyer power. Reinforcing steel products are commodity goods with minimal differentiation and marginal variations in quality between suppliers, and there is limited brand loyalty. The Parties submit that processing and distribution of reinforcing steel products in Singapore forms part of the supply chain for building construction in Singapore. There are multiple tiers in this supply chain in which competition takes place, and strong competitive pressure down the supply chain to suppliers of reinforcing steel products. (iii) barriers to entry and countervailing buyer power; and Low barriers to entry The Parties submit that there are low barriers to entry. There are no planning restraints, technology, research & development (R&D) requirements, regulatory barriers, import restrictions (tariffs, licensing, or quarantine), intellectual property (IP) rights, low availability of raw materials or length of contracts that would affect entry. Strong countervailing buyer power The Parties submit that there is strong countervailing buyer power in the Relevant Market given the high-volume and price-sensitive nature of the reinforcing steel product business. Customers are generally able to switch suppliers without significant difficulty. In addition, there is a large number of competing reinforcing steel fabricators in Singapore capable of supplying substitutable products. Customers are able to, and do, use multiple suppliers of reinforcing steel products as well as switch between suppliers, including suppliers from Malaysia at times. (iv) the competitive effects of the merger (non-coordinated, coordinated, vertical and/or conglomerate effects, as relevant). Non-coordinated effects The Parties submit that the Proposed Transaction will not give rise to any non-coordinated effects, for the following reasons: 1. there is a multitude of new and existing competitors in the Relevant Market that can reliably compete with the Parties in the supply of the Overlapping Products to customers; 2. customers can easily switch between suppliers of the Overlapping Product as there are no or minimal switching costs involved in doing so; 3. barriers to entry into the relevant market are not restrictive, which allows new entrants to enter the Relevant Market and with ease and post credible competitive constraints on the Parties; 4. the nature of the supply chain, in which the Relevant Market is a part of, ensures competitive pressures on suppliers. There are multiple tiers in the building construction supply chain in which competition takes place, and strong countervailing buyer power from large real estate and/or infrastructure developers on main contractors translates into immense pricing pressure on suppliers in the Relevant Market. Coordinated effects The Parties submit that the Proposed Transaction will not give rise to any coordinated effects in the Relevant Markets, for the following reasons: 1. there is a large number of competitors of differing sizes, making any coordination unlikely and in any event, difficult to monitor or enforce; 2. there is a substantial level of excess capacity in the market which, together with incentives for suppliers to increase production in order to capture demand from switching customers, further reduces the feasibility of coordinated outcomes; and 3. the prospect of new market entry given the insignificant and low barriers to entry introduces competitive disruption, thereby undermining the sustainability of any coordinated behaviour. Vertical and conglomerate effects The Parties submit that the Proposed Transaction is not expected to give rise to any vertical foreclosure concerns, given that alternative sources of supply of rebars are readily available from numerous international suppliers. Likewise, the merged entity would not be able to foreclose upstream rivals' access to customers, as downstream purchasers can and do source from multiple suppliers. The Parties also submit that there are no conglomerate effects as outside of the Relevant Markets, the Parties do not provide complementary products that may be purchased by the same customers in Singapore. |
Consultation | Interested parties are invited to submit their views on the Proposed Acquisition of NatSteel by Zenith Singapore (the “Proposed Transaction”). When submitting confidential information, interested parties should take note of the procedures outlined in CCS Guidelines on Merger Procedures. Comments should reach CCS no later than 2 October 2026, 5.00pm. Please write or email your comments (titled: Comments on the Proposed Acquisition of NatSteel by Zenith Singapore) to: Email: ccs_consultation@ccs.gov.sg (opens in new tab) Attention: Ms. Ethel Lin, Principle Legal Counsel (Enforcement) |
Supporting Documents | Interested third parties may request in writing to obtain more information on the Proposed Transaction. Please write or email your submission (titled: Comments on the Proposed Acquisition of NatSteel by Zenith Singapore) to the above contact details. |