On 31 March 2022, the CMA published one of its longest decisions (1077 pages), in which it imposed fines of £155 million on Accord-UK (previously Auden McKenzie/Actavis) for excessive price increases on hydrocortisone tablets after they were de-branded and fell outside the UK NHS price regulations. The CMA also imposed additional fines of £111.5 million for cartel agreements entered into when other parties threatened to enter the market (UK Competition and Markets Authority, Case 50277, Auden McKenzie/Actavis, 15 July 2021). An unusual aspect of the decision compared to other excessive price decisions is that Auden/Actavis received an unintended competitive advantage due to the application of the Orphan Medicines Regulation. In 2011, a separate company (Shire Pharmaceuticals – now
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