造纸被点名，包装责任前移：生态环境法典下，四张经营账必须重算

Code of Eco-Environment 8 Month 15 What is a real obligation and what remains to be decided? How will costs, orders and technology routes change?

The actual impact of the eco-environmental code on the paper packaging industry chain is to be dismantled, from water and fibre efficiency, packaging reduction, VOC costs to recycling and carbon data.

Code of Eco-Environment 8 Month 15 What is a real obligation and what remains to be decided? How will costs, orders and technology routes change?

Four operating accounts for FOUR OPERATING ACCOUNTS

01Paper Factory Resource Efficiency Account

02Packaging design and order billing

03VOC raw materials and tax liability

04Cycle, carbon and customer access accounts

EFFECTIVE... 2026 I'm not sure. 08 I'm not sure. 15

The Code of Eco-Environment is in effect on the countdown. 6 Jesus.

The first three issues that many paper and packaging companies might have thought of were:

Would you like to add another test? Are environmental equipment still going to be in service? Will packaging have a new limit value added?

None of these issues are wrong, but they have not yet touched the essence.

The code has the deepest impact on the chain of paper-packaging industries, not by adding an isolated “green certificate” to enterprises, but by linking past requirements scattered in pollution prevention, cleaner production, circular economy, green packaging, extended producer responsibility and carbon management into a more complete governance framework.

Pollution data are beginning to become cost data, material data is starting to become order data and recovery data are becoming product data.

The industry, on the other hand, is at a stage where it is extremely cost sensitive.

The Chinese Paper Association has a number of sources that show how the country is going to be able to make progress.2025 Our paper and cardboard production was achieved by the year 1.4135 Billions of tons, year-on-year. 3.74%consumption of 1.3879 Billions of tons, year-on-year. 1.80%Meanwhile, the income from the paper and paper industries above size has decreased in national statistics. 2.6%And the total profit fell. 13.6%With public. 443 Total profit of billions divided by 14186.7 Billion dollars in operating income, simple margin only. 3.1%— This is not a Maori rate or net interest rate, but it is sufficient to explain the tension in profit margin.

The two sets of data are statistically different and cannot be directly combined; however, they point to the same reality:

Industry is growing, but profits are not increasing at the same time. Enterprises must upgrade their resource efficiency, product structure and environmental data capabilities when they have to earn a profit.

So,8 Month 15 After a few days, four operating accounts will be required to re-calculate the paper packaging industry.

But before we do the accounting, we must put it first.8 Month 15 "What the hell is going on?"

First, we'll open four layers: not all of them.8Month15The sun suddenly appeared.

This step is very important.

If all green low-carbon policies are interpreted as “compulsory obligations added to the Code on its day of entry into force”, businesses can be prone to panic and articles misleading; if it is understood that the Code simply binds old laws together, the impact of it connecting whole-sector chain responsibilities will be underestimated.

Accurate understanding should be divided into four layers.

Layer. 01

8Month15It's a legal system switch.

Code 1242 It's clear. 2026 Year 8 Month 15 It has been in force since then; the Act on Environmental Protection, the Act for Prevention of Atmospheric Pollution and the Act to Prevent Water Pollution, the Law on the Prevention of Solid Waste and the Environment from Contamination, the Cleaner Production Promotion Act and so forth have been repealed.

This means that ecological governance is entering a new framework of codification.

But “abrogation at the same time” does not mean that all provisions were created on the same day. The extensive requirements of industrial wastewater collection, VOCs control, and restrictions on overpacking of commodities are already legal and standard-based, with codes integrating, connecting and upgrading them systematically.

Layer. 02

8Month15There's an administrative connection that the enterprise can see directly - a new version of the sewage license.

The Ministry of Eco-Environment has identified the following: 8 Month 15 The new version of the sewage licence update has been launched in trades and batches.2026 The new version of the licence covers environmental elements such as atmosphere, water, industrial solidification, industrial noise and soil, using a “one-stop-to-the-pell” structure.

Existing sewage licensing enterprises do not need to re-regulate or apply for new licences and can directly access the national sewerage licence management information platform to download new versions of permits.

What enterprises really do is not repeat submissions, but check:

(b) The conformity of production lines, capacity, raw materials and emission points in the licence with actual production;

(b) Whether production, monitoring, pollution control, solidification and environmental tax data can be validated;

The extension, process or material changes have been completed as required.

The value of the new version of the license is not just a layout change. It's more like an overall index of corporate environmental data.

Layer. 03

The obligation is clear and needs to be implemented on an ongoing basis, not waiting8Month15The day begins again.

Includes the complete collection and treatment of industrial wastewater, applicable VOCs content and use requirements, conformity of sewage permits with actual production, compliance with mandatory standards that limit overpacking of commodities.

These matters cannot be packaged as “future trends” or suspended pending the entry into force of the Code.

Layer. 04

Directions have been determined, but catalogues, standards or by-laws are still required

These include whether and when ordinary packaging is entered into the mandatory recycling list, how different products are accountable for their EPRs, specific mandatory disclosure of the carbon footprint of packing, details on implementation of low VOC product labelling, and timing and quota options for formal integration of the paper industry into the national carbon market.

The government is not in a position to do so.2027 Year 1 Month 1 The VOCs Environmental Protection Tax Pilot, implemented since, is a parallel policy to the Code and should not be written into it. 213I'm not sure.215 The article itself directly imposes taxes.

The four layers are to be removed before the enterprise knows what needs immediate modification, what has to be a data base and what awaits formal rules.

Second account: Paperworks Resource Efficiency Account - Water, Fibres, Energy can no longer be separated

Code 944 It directly combines paper with steel, non-ferrous metals, petrochemicals, chemicals, building materials and dyes, proposes binding standards such as promoting green low carbon transformation, promoting cleaner production technology equipment, upgrading processes and improving energy efficiency and carbon emissions.

"Paper-building is named" is true.

But, uh... 944 The article begins with an industrial transformation and institution-building clause, not to say that paper mills are punished directly under this provision if they do not complete a vague “green transition”.

It sends a real signal that future evaluation of paper mills will not stop at the end of their emissions, but will increasingly focus on how much water, fibre, steam, electricity and carbon are consumed per unit of product.

ACCUNT 01

The bottom of the water account is a fibre account.

Code 297I'm not sure.300 The article requires that water-contaminated enterprises undergo technological adaptation to increase the reuse of water and reduce discharges from wastewater and pollutants; industrial waste water should be fully collected and treated, toxic hazardous waste should be collected in a disaggregated manner and not dilute emissions; and pretreatment requirements should be met before entering centralized treatment facilities.

For paper factories, the value of a ton less wastewater is much more than just one ton lower for sewage treatment.

White water and wastewater often carry fine fibres, fillings, glues, leachate support, wet power agents and heat. The loss of fibres increases both the cost of raw materials and the load of sewage treatment and sludge.

The most indicative of the annual plant boundary is:

Water balance

Fresh water and other external water brought into the water = product brought out + evaporation loss + sludge and solid waste taken out & ex-offerial drainage + stock changes + other explained losses

Fibre Balance

Dry fibre entering the paper system = dry fiber in finished products + fibre in outlet byproducts + sludge, sifting and fibre in wastewater + stock changes + other explained losses

White water recovery and paper recycling are internal cycles of the system, which should be listed as process indicators that cannot be duplicated with external inputs and final output. Different paper mills also need to expand formulas based on actual conditions such as pulp integration boundaries, extra-purchase slurry water content, fillings, and chemical water belting.

If the two sets of accounts cannot be closed, it is difficult for an enterprise to judge whether a “water-saving project” reduces the total cost or shifts the problem to paper breakouts, paper disease, chemical consumption and sludge disposal.

A particular error needs to be avoided:

Increasing the reuse of water does not amount to a blind pursuit of a completely closed circuit cycle.

Water systems are over-confined, with potential accumulation of salt, inion waste, glue and microorganisms, leading to a rise in filtering failure, gel failure, sedimentation, corrosion, dissimilarity and paper breakout rates. The industry is looking not for the “zero emission slogan”, but for the best combination of fresh water, fibre loss, chemical loss and treatment costs that guarantee paper stability and paper quality.

ACCUNT 02

Energy accounts are turning into carbon, but not the future as it has happened.

GB 31825-2024The energy consumption limit for mills of paper products is already in place 2025 Year 5 Month 1 It is a mandatory national standard in force and not a new requirement that comes into effect after the Code has entered into force.

On the other hand, carbon data requirements are not just forward signals. 2026 The annual National Carbon Emission Market-related Work Notification has made it clear that annual greenhouse gas emissions in such industries as paper production are met 2.6 Tonnes of carbon dioxide equivalent, approximate combined energy consumption 1 Tonnes of standard coal units, integrated into annual GHG emissions reporting management; notification requires that relevant enterprises are in place 2026 Year 3 Month 31 Presented to the previous day 2025 Annual emissions report and supplementary data, with provincial ecological authorities in place 2026 Verification completed by the end of the year. For paper mills that have reached the threshold, what is now required is not to wait for expansion but to review the data, documents and calculation of boundaries submitted in a manner that can be verified.

However, two things must be distinguished: emissions reporting management has occurred and quota administration has not yet happened. 2026 The distribution and elimination of quotas in the current circulars are still in power generation, steel, cement, and aluminium smelting.

The paper mill is now the most valuable preparation, with four indicators per piece of paper and each line:

Fresh water consumption in cubic metres/tonne of paper;

Fibre loss, in kg/tonne of paper;

Electricity, steam and fuel consumption, distributed according to paper and process;

Pollutant load, both in terms of concentration and per unit product production and emissions.

Because most effective carbon abatement projects are first shown by the decline in steam, electricity, paper breakers, waste products and downtime costs. For a paper factory with high profitability, it is best to improve its cash flow for carbon reduction.

3nd booking: Packaging Design and Order Accounts - "Paper" does not automatically equal "Green"

Code 972 (b) The article encourages green design; 973 It encourages green packaging and reduced packaging, while specifying that the producer should be reasonable in packing, comply with mandatory standards limiting excessive packaging of goods, not overpacking, and that the material, structure and cost of the packaging shall be appropriate for the contents; 974 The Article further requires the electric power suppliers, couriers and take-out industries to reduce packaging use by prioritizing reuseable, recyclable packagings and actively recycling them.

The most significant concern for packaging enterprises here is not the word “paper replacement”, but rather that the subject has been moved from one material to a complete packing system.

A paper package that may also include:

Original paper, bottom coating, barrier layer, ink, light oil, glue, thermal envelopes, wet power systems, window materials and final formation structures.

“Higher paper content” does not automatically demonstrate better system environmental performance if, in order to replace a layer of plastic, the original paper quantity, coating usage and dry energy consumption are significantly increased; if packaging is reduced online, waste rates increase; if food contamination results in no realistic collection pathways; and if large sifting and sticky matter are produced when finally entering the replastic system.

A truly professional green packaging design, at least four doors:

GATE 01

Function door

Packaging must first satisfy the basic functions of water resistance, oil retardation, oxygen resistance, heat sealing, grinding, printing, transport safety, shelf life and transportation protection.

GATE 02

Material efficiency portal

The comparison is not a single item of “paper or plastic”, but whether the total material weights have decreased, the number and gaps of invalid layers have been reduced and there has been overpacking under the same packaging function.

GATE 03

Creating efficiency doors

A material can be ordered only if it is produced steadily on the customer’s real equipment.

GATE 04

The real-world door.

The “capable of separation” in the laboratory does not mean that packaging is necessarily collected, selected and used in reality.

So, “recyclableThe evidence should not be a mere base test report, but at least bind it:

Final package complete BOM;

(a) The amount of materials and unit space used in each layer;

(a) The most adverse amount of cloth, print space and composite structures;

(a) The applicable recycling scenario and test methods;

(b) Fibre recovery or acquisition, sifting and interference;

Recycle slurry or paper mass.

Codes do not automatically consider packaging green because it is paper; what is really evaluated is a complete packing system.

For packaging enterprises, this would directly change the order logic: in the past, customers purchased a box, cup or bag; and future head clients are more likely to buy a solution that is “functionally qualified, material reduced, stable, clear recovery path and data can be verified”.

4rd and 3rd account: VOCs raw materials and tax liability - the first order to be made may not be carbon, but material accounting

Code 213I'm not sure.215 The measures for reducing emissions from the use of VOCs containing content limits for VOC-based materials and products, low VOCS materials, production processes and a low VCs product identification system are provided.

For packaging printing, fabrication and complexes, these requirements fall on very specific materials:

Ink;

(a) Photooil;

(a) Glaciant;

Purges and dilutors;

Rigid fluids;

Painting and packaging.

But two common misunderstandings must first be corrected.

Water is not equal to water.zero VOCAnd low smell is not like low VOC.

The product VOC determines that the product type, state of use, dilution, test method and applicable criteria need to be tied. Compliance cannot be concluded by using the word “water”.

More direct business signals from 2027 Year 1 Month 1 The first industries include the printing industry and manufacturing of chemical raw materials and chemicals. 8I'm not sure.12 Dollar, VOCs Contamination Equivalent Value is 0.95 kg; VOCs original material is calculated using the material accounting method of source.

A simplified calculation for understanding the magnitude only:

If 1 The tons are all taxable VOCs emissions, not considered 18 In the case of individual material deductions, performance rating preferences and local tax differences:

1000 kg of ÷ 0.95 kg/pollution equivalent x 8I'm not sure.12 Meta/pollution equivalent

Corresponding agreement 8421I'm not sure.12632 Dollar.

The key word here is taxable emissions.

It's not. 1 Ton procurement material, no. 1 Tons of ink, and not the VOC content detected by the product, are taxed directly.18 Individual substances are deducted and local taxes are levied.

"VOCs mass ratio" in the pilot scheme is greater or equal 10%) is one of the identification calibers containing the VOCs original auxiliary emission source and not a line for determining whether the product belongs to a “low VOC”.

Therefore, the value that material suppliers can really create for their customers is not a general claim to “greener environment”, but rather a help to them calculate a comprehensive cost sheet:

Cost of materials procurement

Actual unit use

Distillation and cleaning costs

Dry energy consumption

Waste gas collection and management costs

Waste and shutdown losses

Potential taxable emission costs.

A low VOC material may not be viable if it causes a significant decline in linear speed, energy consumption and an increase in waste products; conversely, if it maintains attachments, isolation, heat seals, grinding, anti-cooties and storage stability at low dry paint levels, it can simultaneously reduce the loss of raw materials, governance, taxes and production lines.

VOCs is not a propaganda term, but rather an operational data chain from the purchase counter, material accounting, sewage licensing to tax declarations.

This is likely to be one of the fastest entry points for packaging functional material in the coming year.

5th and 4th: Cycle, Carbon and Client Access Account - Environmental data is becoming part of the product

Code 959 Article 1 establishes an extended system of producer responsibility; 977 The article further stipulates that enterprises producing, importing and selling products and packagings listed in the mandatory recycling list by law shall be required to perform their duty of recovery, use or disposal.

But this cannot be interpreted as:

“From8Month15As of this date, all cups, boxes and bags must pay the unified EPR.”

Article 977 The trigger for this article is “the mandatory recycling list, which is legally included”, and the specific lists and management methods are still being developed by the State development reform department in conjunction with the relevant authorities.

However, industry preparations have begun.

The National Development Reform Commission’s official reading of the “15th Five-Year Plan for Revolving Economic Development” clearly states that it supports self-recycling in industry, such as a combination of beverage paper packaging and a one-time drink cup. The common dilemma between these two types of packaging is typical: low value, dispersion, vulnerability to food residues, and usually contains nonfibrous layers.

The real industrial problem is not a phrase.recyclableThe following are the main reasons for this:

Who sets the recovery point and who bears the cost of receipt;

Whether the contaminated packagings still have an economic value;

(b) Where fibres and non-fibre components are entered separately;

(a) How brands, platforms, packaging plants, material dealers and paper factories share responsibility;

How recovery results are recorded, verified and prevented from being used only.

Meanwhile, the Code 1000 The article proposes that enterprises implement green procurement and establish green supply chains in accordance with national requirements; 1036 It establishes systems for accounting, hierarchy, marking certification and disclosure of information on the carbon footprint of products.

As at 2025 At the end of the year, we have published 15 National standards for carbon footprint accounting of products 200 Group standards for multiple disaggregated areas; total number of factors in the second version of national GHG emission factors database increased 576 One.

That doesn't mean all the paper wrappings are on 8 Month 15 The carbon footprint must be disclosed on day-to-day.

But a more realistic change may occur earlier: brand clients, export customers, government procurement and head-chains will first turn retroactive environmental data into supplier access conditions.

The future paper, coating or package delivery document should not be a mere quotation and TDS but should also evolve into an “product environment attribute package” within the enterprise:

(b) Product identification, formulation or structural version;

Final packaging BOM and unit packing weight;

VOC data, test methods and applicable boundaries;

Data on major energy, feedstock and manufacturing losses;

(b) The recycling compatibility and application of the final packaging;

A description of the first-hand activity data and data quality required for the carbon footprint;

Environmental declarations that can be used, restricted and not.

This is not a uniform “product passport” name that the State has established, but rather a set of data assets which enterprises should establish on their own initiative.

The important watershed in packaging the next round of competition is not one that speaks green, but who can turn green into verifiable costs, performance and data.

Which six orders come first? Not all green opportunities are at the same time.

From the paper packaging industry chain, opportunities can be divided into “near orders that have been entered” and “medium-term capacities that need to be built together”.

NOW 01

Paper mill water conservation, fibre recovery and energy efficiency improvements

The logic of payment is clear: how much fresh water, steam, electricity, fibre and sewage treatment costs per ton of paper are saved; whether break-throughs, scrappings and shutdowns are reduced. Value can enter the financial model by measuring a clear boundary.

NOW 02

Low VOCs ink, light oil, glue, detergent and functional coating

The customer will not compare prices per kilogram, but will gradually compare the actual use of the finished product, linear speed, drying, governance, cleaning, scrap and potential taxable emissions.

NOW 03

Reduction in quantification and structural optimization

Reduction of the inert layer, reduction of unit packaging weights, closing of gaps, optimization of box and sturgery layouts and improvement of transport loading efficiency are also responding to overpacking, cost and logistics efficiencies, often making it easier to establish commercial closed rings than simply replacing materials.

NEXT 01

recyclableDeter- and complete packaging validation

The opportunity is not just to "replace the PE" but to satisfy.food contact(b) Reduction of non-fibre layers, reduced sifting and sticky material risk while blocking, heat sealing and shelf life, and certification on final packaging.

NEXT 02

Recovering system for Composite Beverage Paper Packaging and Extra Cups

The laboratory results of individual materials are not a substitute for real collection and final utilization.

NEXT 03

Product carbon footprint and green supply chain data

Short-term client questionnaires and reviewer information are expected to move into product design, procurement, pricing and vendor grading in the long term. The earlier raw activity data is established, the lower the future accounting costs and explaining risks.

Thus, the industrial opportunities offered by the Code are not a generalized “environmental market”, but three categories of value that can be purchased:

Quantifiable cost reductions, verifiable product upgrades, data capabilities for access to client systems.

What do seven enterprises do now: one?30I'm not sure.90I'm not sure.180The Sky Map

NEXT 30Jesus.

We'll split the obligations and then we'll get back to the bottom.

Establish a policy matrix that will divide matters into:

(a) Practical obligations already in force;

8 Month 15 (a) The legal or administrative connection that occurs on a daily basis;

(a) Policies that have been published and will be in effect in the future;

System of clearly oriented but still to be catalogued, standards and rules.

Also check for CE, sewage permits, physical production lines and emission points; inventory of priority products BOM; establishment of basic counter accounts for water, fibres, energy, VOCs and waste streams; clean-upzero VOCCompleterecyclableI'm not sure.100%biodegradableLack of border advocacy terms such as zero carbon, code compliance etc.

NEXT 90Jesus.

Just pick one SKU, and make a comparison of the three options.

Do not start with whole-product line modifications. Select a package that is large in volume, high in client interest and has an improved structure, comparing three options with the same functional unit:

Existing base structure;

(a) Minimum change scenario;

Structural upgrading programme.

Harmonized comparison: total packaging weight, number of material layers, functional performance, unit use, linear speed, dry energy consumption, waste rate, VOC input, handling loads, recovery performance and full cost.

Only by comparing calibres can it be avoided that “a single indicator is greener and system costs and environmental loads are higher”.

NEXT 180Jesus.

Create a portfolio of evidence that can be submitted to the client for review.

Select at least one product to form a complete document from the feedstock, manufacture, use and recovery boundary:

Technical specifications and versions;

Performance and testing methods;

food contactor product safety information;

VOC and actual use data;

(b) Full packaging recovery compatibility;

Carbon footprint activity data;

Environmental statement and its evidence level.

The value of this document is to harmonize the research and development, production, environmental protection, procurement, sales and customer review.

VIIIBIOTENObservation: Value standards for functional material are changing

The eco-environmental code doesn't name. PHANo paper, water orbio-based materialsAutomatically belongs to green material.

So,PHA Opportunities for aquatic functional materials cannot be based on material names, but rather on a verifiable customer value chain:

(a) The availability of the required water resistance, oil retardation, heat containment or grinding in lower quantities;

(b) The ability to maintain speed, attachment and stability on the customer ' s real equipment;

(b) Whether VOCs can be reduced in input and governance load;

Whether realistic recovery pathways for final paper packaging can be maintained to the extent possible;

Availability of data for chemical compliance, source of materials and carbon footprint.

“Biobase” may be transformed into a low carbon advantage only if carbon footprint comparisons are conducted at the same functional unit and clear system boundaries;”biodegradable"The true value may be converted only when environmental conditions, time and end disposal paths are specified;"repulpable“And only when final printing, coating, composite and finished packaging is validated can a credible statement be made.

For suppliers of functional materials, the future will require delivery not only of a ton of material but rather:

Material performance + manufacturing window + combined cost + recovery compatibility + environmental data.

And this is it.BIOTENPackaging is more deserving of a professional position: rather than declaring “compliance” on behalf of customers, it helps clients to turn a green direction into a productive, verifiable and traded package.

Concluding remarks

The impact of eco-environmental codes on the paper packaging industry can be condensed into three sentences.

For paper mills:

Upstream not only demonstrates that emissions are met, but also how to stabilize the same paper with fewer water, fibre and energy sources.

For packing enterprises:

Downstreams not only prove the use of paper, but also demonstrate how complete packaging is reduced, stabilized and preserved a realistic cycle path.

For material suppliers:

It is not only proof of material performance, but also how it reduces the combined costs and environmental loads of clients.

8 Month 15 Rather than completing the end of a landing at the same time for all green rules, the paper packaging industry has re-advertised environmental liability to the starting point of an operating model.

Future firms that are truly competitive, not those with the largest green terms, can demonstrate by process and data:

To the same packaging function, less resources are consumed, less pollution is generated, better circulation routes are preserved and measurable business value is created for customers.

This is the most important effect of eco-environmental codes on the chain of paper and packaging industries.

According to sources and calibres

The full text of the Environmental Code of the People ' s Republic of China is attached to the Ministry of Eco-Environment.

Circular on the Optimization of the Format of Sewerage Licences (Records)

Pilot Implementation Scheme for the Collection of Taxes on Environmental Protection of Volatile Organic Substances (VOC)

Expert interpretation of the “15th Five-Year Plan”

Progress in the development of a carbon footprint management system for products 2026 Year 6 Monthly press conference

About doing good. 2026 Annual notification of work on the national carbon trading market, Ministry of Eco-Environment

The country's carbon market, paper-making industries and so forth are ready to answer the press to the Ministry of Ecology.

GB 31825-2024Energy consumption limits for mills of paper per unit of product

2025 National Forestry and Grassland Institute for Income and Profiting in Paper and Paper Products of National Size and Higher Year

Chinese Paper Industry 2025 Annual Report Chinese Paper Association

Note: This paper is an industrial research and business analysis that does not constitute a legal, tax, certification or compliance opinion for a particular enterprise.

Research:2026Year8Month9SunnyBIOTENPackaging, industry insight.