21st Century Business Herald Reporter Xiao Xia
For many years, private label liquor has grown wildly due to its low entry barriers and high profits. Especially in the sauce liquor industry, issues such as unqualified private labeling, poor quality bottling, and false advertising have persisted, leading to numerous consumer rights protection incidents.
In December of this year, the &#34;Supervision and Administration Measures for Food Entrusted Production&#34; will officially take effect. According to the new regulations, the entrusted production model for liquor will face stricter supervision, requiring both the entrusting party and the production party to obtain the corresponding qualifications and file records, as well as fulfill more detailed traceability and information disclosure obligations. This means that private label liquor, which has previously existed on the fringes of regulation, will usher in systematic and normalized management.
With several months remaining until the new regulations are implemented, the chaos in the private label liquor sector has not disappeared.
The 21st Century Business Herald reporter has noted that from the end of 2025 to the beginning of 2026, police and market regulatory departments across various regions have successively cracked down on multiple cases of unqualified private label liquor. Many gangs are simultaneously operating counterfeit famous liquor and private label liquor businesses, reflecting that private label liquor remains a major disaster area in the liquor industry.
The so-called legitimate and compliant private label liquor entrusted production is currently facing dual pressures from market downturns and tightening regulations.
On the eve of March 15, the 21st Century Business Herald reporter consulted several Kunsha sauce liquor companies claiming to be from the Moutai Town production area. According to feedback from business personnel, influenced by market conditions, the prices of customized private label liquor have significantly declined compared to the previous two years, and due to stricter regulations, the customizable content has also been tightened.
It is important to clarify that, unlike counterfeit famous liquor, private label liquor is originally a normal entrusted production model—where the entrusting party, having customers and channels, collaborates with the production party, which has qualifications and base liquor. The former can enrich the product matrix and expand business lines, while the latter can effectively utilize production capacity and expand operations.
Even now, some well-known liquor companies are engaging in similar business collaborations with third parties, where the liquor companies are only responsible for product production, while the products and brands belong to the entrusting party.
However, in practice, many small and medium-sized liquor companies have abandoned market development and user cultivation, directly using &#34;private label liquor&#34; as their core business strategy to acquire customers.
Especially during the recent &#34;sauce liquor boom,&#34; private label liquor from Renhuai attracted a large number of industry distributors and external customers by relying on labels such as &#34;Moutai Town&#34; and &#34;Kunsha liquor.&#34;
Since the penetration of sauce liquor in the national market has been relatively late, many consumers are not familiar with the differences between various qualities of sauce liquor, such as Kunsha, fansha, and suisha. &#34;Produced in Moutai Town&#34; once became a pass for private label sauce liquor. Many so-called &#34;well-connected&#34; unknown sauce liquors hardly engage in channel recruitment, instead relying on word-of-mouth at drinking tables, selling tens of millions or even over a hundred million yuan in a year.
However, this fervor did not last long. As consumers gradually became aware of the quality of sauce liquor, the &#34;sauce liquor boom&#34; quickly cooled down.
Liquor industry commentator Xiao Zhuqing told the 21st Century Business Herald reporter that many small liquor factories focusing on &#34;private label&#34; and &#34;customization&#34; lack brand cultivation, market investment, and the construction of marketing service systems. Long-term reliance on simple and crude &#34;private label liquor recruitment marketing&#34; has directly overdrawn the market credibility of Moutai Town sauce liquor, leading to the rapid marginalization of many small and medium-sized sauce liquor enterprises
The profit margin of sauce liquor has attracted a group of unqualified teams to enter the market.
During the hot market period, even unknown sauce liquor brands could easily sell for seven to eight hundred yuan or even a thousand yuan. In the past, the parties commissioning private label production did not need qualifications or registration; as long as they registered a simple trademark, they could find some unqualified small workshops or black factories for processing, forming a &#34;no qualifications, no quality control, no after-sales&#34; three-no private label model.
Last year, CCTV reported that some merchants in Renhuai were suspected of adding edible alcohol in the production of sauce liquor, passing off fake as real, and falsely labeling production dates. The Renhuai Market Supervision Administration subsequently investigated local liquor companies and found that some products sold by these companies not only did not have the typical sauce liquor style but were not even solid-state liquor, suspected of being blended with edible alcohol.
There were even individuals who took risks.
In the past two consecutive years, Renhuai had investigated cases of individuals purchasing packaging materials and producing liquor themselves. A case reported last year mentioned that a privately produced private label liquor failed multiple tests but still entered the catering channels openly.
Such unqualified private label liquor production gangs have been discovered across the country. A reporter from the 21st Century Business Herald noted that from the second half of 2025 to early 2026, similar unqualified enterprises and individuals accepting commissions for production were found in places like Huaiyuan, Anhui, Jianli, Hubei, and Zhongshan, Guangdong, many of which actually purchased low-quality base liquor or even edible alcohol for blending.
Moreover, to gain business, these gangs often accept all kinds of special supply liquor, further disrupting market order.
The unqualified and unscrupulous &#34;wild&#34; private label liquor has also impacted the legitimate private label liquor commissioned production.
A reporter from the 21st Century Business Herald inquired about customized liquor from several registered liquor companies in Renhuai and learned that the current customization costs are much cheaper compared to the previous two years.
&#34;Our liquor is divided into three grades: Crushed Sand 25 yuan/bottle, Kun Sand 45 yuan/bottle, Daqu Kun Sand 80 yuan/bottle, packaging is extra, ordinary gift boxes are 40 yuan/box, with 6 bottles per box, the cheapest box is 190 yuan, you can resell it for two to three hundred or three to four hundred without any problem,&#34; a salesperson from a liquor company in Maotai Town told the 21st Century Business Herald. &#34;The cost performance is very high, and if you customize 40 boxes, you can get a discount on single bottles.&#34;
Another liquor company registered in Renhuai emphasized that the product process and quality are consistent with Maotai Town sauce liquor, and stated that they could send sample liquor or allow factory inspections, offering a single bottle price for Crushed Sand liquor as low as 20 yuan/bottle, with further discounts available for negotiation.
When asked about the reasons for the low prices, a staff member surnamed Zhou told the 21st Century Business Herald that it is mainly due to the current poor market conditions and intense competition. &#34;Many liquor factories from other places are taking private label customization, and many are actually sourcing liquor from us for bottling; their advantage is being closer to the customers.&#34;
Another factor is that private label liquor now faces more restrictions, and the space has become smaller.
The reporter consulted four customized liquor producers, all of whom stated that they currently do not accept any special supply or dedicated customization involving party and government agencies or the military, nor can they customize packaging involving national symbols or well-known geographical indications. The aforementioned Renhuai liquor company stated that if customization requires labeling the company name, the commissioning document must have the corresponding unit's seal
The &#34;Supervision and Administration Measures for Food Entrusted Production&#34; (hereinafter referred to as the &#34;Measures&#34;), which will be implemented at the end of this year, will further regulate the production of private label liquor.
The &#34;Measures&#34; require that both the entrusting party and the entrusted party must obtain food production and operation licenses (or complete pre-packaged food sales filing) and food production licenses. The entrusted party must also have the corresponding production capacity and safety assurance capability, and must produce food with a complete process; they are not allowed to outsource part of the production process.
This regulation will directly eliminate a large number of unqualified private label manufacturers and illegal subcontracting workshops from the market. To engage in private label liquor business, producers must comply with filing requirements, have complete qualifications, and must complete production independently without purchasing base liquor.
In addition to clarifying the entry threshold, the new regulations also further solidify the main responsibility.
In the past, when quality issues arose with private label liquor leading to consumer complaints, the entrusting party and the producing party often shifted blame onto each other. The new regulations clearly define the rights and responsibilities of both parties, stipulating that the entrusting party bears overall responsibility for food safety and must supervise the production behavior of the entrusted party, including third-party on-site inspections and using information technology for supervision; the entrusted party is directly responsible for the production process and must strictly control raw materials, production, and testing, refusing illegal private label requests; both parties must sign standardized contracts and file them with local regulatory authorities.
Furthermore, the new regulations emphasize the information disclosure obligations of both parties, enhancing consumer rights protection.
The &#34;Measures&#34; mandate that pre-packaged foods produced under entrustment must clearly label the names, addresses, and contact information of both the entrusting party and the entrusted party in close proximity on the packaging; at the same time, both parties must establish a full-process traceability system, with records retained for no less than six months after the expiration date.
As a result, consumers can easily identify the qualifications and sources of private label liquor by checking the product label, and regulatory authorities can quickly locate the source of issues through product labels and the traceability system.
Compared to previous phased special rectifications, the series of requirements in the new regulations is expected to achieve normalized and systematic supervision, significantly increasing the illegal costs of private label liquor, and providing protection for legitimate and compliant private label liquor production.
Undoubtedly, the market reshuffle will accelerate further.
&#34;The tens of thousands of mixed private label products in the liquor market have completed their historical mission, and the vast majority will be directly cleared and eliminated in this round of adjustments,&#34; judged Quan Tu, general manager of Quan Tu Liquor Studio, in the annual report

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The private label liquor industry has rapidly developed due to low entry barriers and high profits, but it is also accompanied by issues such as unqualified production and false advertising. The new regulation "Supervision and Administration Measures for Food Entrusted Production" will be implemented in December, requiring both producers and entrusting parties to have qualifications and be filed, strengthening supervision. Despite the imminent implementation of the new regulation, the chaos in the industry has not yet disappeared, and the police have investigated multiple cases of unqualified private label liquor. The prices of private label liquor have been affected by the downward market trend and stricter regulations, and some liquor companies still cooperate with third parties for production

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