Independent bids
For the same specification and delivery requirement, how many qualified suppliers submit a commercially usable bid? Record unsuccessful quotations and the reasons a supplier could not participate.
The product markets
Why orbital motors and hydraulic steering units became the focus of the U.S. challenge.
Research and analysis · Reviewed October 25, 2026
The 2021 allegations
DOJ defined separate U.S. markets for orbital motors and hydraulic steering units used in mobile off-road equipment. Its complaint reported the following supplier shares and concentration measures. These are historical allegations for the proposed transaction, not 2026 market-share estimates. Complaint, paragraphs 31–34
| Measure | Orbital motors | Steering units |
|---|---|---|
| Danfoss share | Approximately 53% | Approximately 43% |
| Eaton share | Approximately 24% | Approximately 41% |
| Pre-merger HHI | 3,605 | 4,155 |
| Proposed post-merger HHI | 6,087 | 8,273 |
HHI measures concentration by summing squared supplier shares. The figures above are DOJ’s reported calculations. The steering shares in paragraph 32 do not reconcile with the HHI change reported in paragraph 34. That discrepancy remains unresolved here; the table preserves the figures as filed.
Why another component was not an easy substitute
In its Competitive Impact Statement, DOJ described orbital motors as compact, economical sources of low-speed torque. It argued that switching to another motor technology could change price, performance, or machine design. For hydraulic steering units, replacing the underlying steering technology could also require a substantial redesign. Its geographic analysis emphasized U.S. inventory, replacement parts, service, and delivery. Competitive Impact Statement, Section II
Our analysis: qualification is part of competition
A supplier becomes a practical alternative when it can meet the application, complete qualification, deliver on the required schedule, and support the installed machine. A catalog match establishes only part of that capability. The burden is different for a new platform, an existing production program, and a repair needed immediately.
That makes engineering support and aftersales capacity commercially significant. A purchasing team may receive several offers while having fewer sources that are ready for the actual duty, interface, validation schedule, and service requirements.
The European scope
The European competition assessment also addressed electrohydraulic steering valves. Its divestment package included priority valves. Its product and geographic analysis belongs to the European proceeding and its own market evidence. U.S. shares should not be applied to Europe or to the entire hydraulics industry. European decision, product markets and competitive assessment
What would measure competition now?
Switching work
What engineering, testing, tooling, inventory, or customer approval is necessary to change source? Measure the time and cost by application rather than assuming every motor is interchangeable.
Service coverage
Can the supplier provide replacements, technical responses, and local stock for the equipment’s service life? A new-machine quote does not establish the strength of the repair channel.
Delivered performance
Compare the accepted specification, promised date, actual shipment, quality result, and response to a problem. Price comparisons are more useful when the surrounding terms are comparable.
These are our proposed measures for further reporting. This dossier does not yet contain a current market census or an independent comparison of supplier performance.
The same component presents three competitive questions
Consider the difference between a new machine design, an established production program and a machine awaiting repair. This is an analytical comparison. A new design may have time to evaluate a different architecture. An existing program carries approved interfaces and accumulated testing. An urgent repair may depend most heavily on an accepted replacement being available immediately.
The number of usable alternatives could differ across those situations even for a related component family. A credible follow-up should therefore state which purchasing problem it examines before counting bids or comparing lead times. That would help explain why a supplier’s catalogue breadth, engineering response and replacement stock each matter, without treating any one of them as a complete measure of competition.