In both instances, the National Development and Reform Commission imposed small penalties for price collusion on more than a dozen rice noodle makers and service providers that wash, sterilise and wrap tableware in plastic for restaurants. Stephen Harris, a competition attorney with Winston & Strawn in Washington DC, says both cases were a signal to Chinese companies by NDRC that “new laws exist and there’s a cop on the beat”.

The NDRC’s investigations into allegedly anti-competitive behaviour by domestic firms culminated with an Rmb200m ($32.2m) fine for China’s largest liquor maker, Wuliangye, two years ago. But it takes rather more money to get the attention of multinationals, and the NDRC achieved just that in 2013 with the first in a series of investigations against foreign manufacturers of milk powder, auto parts, premium cars and semiconductors.

Foreign firms accused of anti-competitive behaviour by the NDRC have generally been hit with much higher fines than their domestic counterparts. Qualcomm agreed to pay a Rmb6.1bn penalty in February, while Mercedes and Audi were fined Rmb350m and Rmb250m respectively.

In all three instances, the fact the penalties could have been much worse has blunted some of the criticism that the NDRC has been deliberately targeting foreign companies — a charge the regulator has consistently denied.

Qualcomm’s penalty could have required much more costly changes to its business model. The San Diego company’s shares actually rose on the news. Mercedes and Audi, meanwhile, were penalised for infractions in just one province each. In theory, they could have had to pay much more had NDRC’s investigators ferreted out wrongdoing in all of China’s 32 provinces, autonomous regions and directly administered municipalities.

That suggests the NDRC’s investigations of multi­nationals, like the ones into domestic firms before them, were to a large degree motivated by the desire to send a wake-up call to the foreign investment community rather than secure maximum fines.

So what next now that the NDRC has so effectively got its intended message across? Only one previously disclosed investigation has yet to be resolved — that involving Microsoft and the State Administration of Industry and Commerce, which also polices aspects of the 2010 Anti­Monopoly Law.

Mr Harris and his colleagues at Winston & Strawn — who represent both Qualcomm and Microsoft but said they could not comment on either case — are warning multinationals about a new set of SAIC guidelines that could force them to share intellectual property with their Chinese competitors. The rules, designed to “prohibit abuse of intellectual property rights to eliminate or restrict competition”, were promulgated early last month and take effect on August 1. Just as western regulators have occasionally forced operators of telecoms networks and electricity grids to share their “essential facilities” with competitors, the SAIC could compel “dominant” companies to share intellectual property when it constitutes “an essential facility of manufacturing and business operations”.

If it were to do so, the SAIC would be following the EU in applying the essential facilities doctrine to intellectual property. But the EU has only forced companies to share intellectual property in a very small number of exceptional circumstances, while the US has refused to do so.

In a rare public comment on the new rules, one SAIC official has said the regulator will be “cautious” in applying them. For multinationals wary of being forced to transfer technology in China, the uncertainty is a worrying but useful reminder that the country’s anti-monopoly law is very much a work in progress. Very few if any of them took note of the implications for their own industries of the NDRC’s prosecutions of the domestic rice noodle and tableware cartels. It is a mistake that they should not make twice.