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

The Ecological and Environmental Code takes effect on August 15. What will truly change the papermaking and packaging industry is not the addition of another test, but the fact that pollution, resources, packaging, recycling, and carbon data are beginning to enter the same operating ledger. Which obligations are already real, and which still await implementing rules? How will costs, orders, and technology pathways change?

From water and fiber efficiency, packaging reduction, and VOC costs to circularity and carbon data, this article examines the real impact of the Ecological and Environmental Code on the papermaking and packaging value chain.

The Ecological and Environmental Code takes effect on August 15. What will truly change the papermaking and packaging industry is not the addition of another test, but the fact that pollution, resources, packaging, recycling, and carbon data are beginning to enter the same operating ledger. Which obligations are already real, and which still await implementing rules? How will costs, orders, and technology pathways change?

FOUR OPERATING ACCOUNTS | Four Operating Accounts

01 Paper Mill Resource-Efficiency Account

02 Packaging Design and Order Account

03 VOC Raw-Material and Tax Account

04 Circularity, Carbon, and Customer-Access Account

EFFECTIVE · 2026 / 08 / 15

6 Days Until the Ecological and Environmental Code Takes Effect

Many papermaking and packaging companies may first think of three questions:

Will another test be required? Will further investment in environmental equipment be necessary? Will new limits be imposed on packaging materials?

These are all valid questions, but they do not yet reach the core issue.

The Code’s deepest impact on the papermaking and packaging value chain is not to add an isolated “green certificate,” but to connect requirements previously dispersed across pollution prevention and control, cleaner production, the 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 are beginning to become order data, and recycling data are beginning to become product data.

And the industry happens to be at a stage of extreme cost sensitivity.

According to the China Paper Association, China’s paper and paperboard production reached 141.35 million metric tons in 2025, up 3.74% year over year, while consumption reached 138.79 million metric tons, up 1.80%. Meanwhile, under national statistical reporting, operating revenue of paper and paper products enterprises above designated size declined 2.6% year over year, and total profit fell 13.6%. Dividing the publicly reported RMB 44.3 billion in total profit by RMB 1,418.67 billion in operating revenue gives a simple ratio of only approximately 3.1%—this is neither gross margin nor net margin, but it is sufficient to illustrate how tight profit headroom has become.

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

The industry is still growing, but profits are not growing in step. Companies must upgrade resource efficiency, product mix, and environmental-data capabilities while margins remain under pressure.

Therefore, after August 15, what the papermaking and packaging industry truly needs to recalculate are four operating accounts.

But before doing the calculations, it is essential to clarify exactly what changes on August 15.

I. First Separate Four Timing Layers: Not Every Requirement Suddenly Appears on August 15

This step is critical.

If every green and low-carbon policy is interpreted as a “new mandatory obligation created on the day the Code takes effect,” companies may make panic-driven investments and articles may mislead readers; if the Code is understood as merely binding old laws together, its impact in connecting responsibilities across the entire value chain will be underestimated.

An accurate understanding should distinguish four layers.

LAYER 01

August 15 Marks a Transition in the Legal System

Article 1242 of the Code expressly provides that it takes effect on August 15, 2026; at the same time, ten laws, including the Environmental Protection Law, the Atmospheric Pollution Prevention and Control Law, the Water Pollution Prevention and Control Law, the Law on the Prevention and Control of Environmental Pollution by Solid Waste, and the Cleaner Production Promotion Law, are repealed.

This means ecological and environmental governance is entering a new codified framework.

However, “repealed at the same time” does not mean that existing obligations disappear, nor does it mean that every provision was newly created on that date. Many requirements—including complete collection and treatment of industrial wastewater, VOCs controls, and restrictions on excessive commodity packaging—already had legal and standards-based foundations; the Code systematically integrates, coordinates, and strengthens them.

LAYER 02

August 15 Brings One Administrative Transition Companies Can Directly See—the New Version of the Pollutant Discharge Permit

The Ministry of Ecology and Environment has made clear that, beginning August 15, updates to the new version of pollutant discharge permits will be launched by industry and in batches, with full application by the end of 2026. The new permit covers environmental elements including air, water, industrial solid waste, industrial noise, and soil, and adopts a “one outlet, one table, one code” structure.

Companies already subject to pollutant discharge permit management do not need to resubmit information or reapply; they may directly log in to the National Pollutant Discharge Permit Management Information Platform to download the new permit.

What companies actually need to do is not resubmit the same materials, but verify:

Whether the production lines, capacity, raw and auxiliary materials, and discharge outlets listed in the permit are consistent with actual production;

Whether production, monitoring, pollution-control, solid-waste, and environmental-tax data can corroborate one another;

Whether the required procedures have been completed for expansions, modifications, process changes, or material changes.

The value of the new permit is not merely a change in format. It is more like the master index for a company’s environmental data.

LAYER 03

Obligations That Are Already Clear Must Continue to Be Implemented Rather Than Waiting Until August 15

These include complete collection and treatment of industrial wastewater, applicable VOCs content and use requirements, consistency between pollutant discharge permits and actual production, and compliance with mandatory standards restricting excessive commodity packaging.

These matters cannot be packaged as “future trends,” nor can management of them be deferred simply because the Code has not yet taken effect.

LAYER 04

The Direction Is Set, but Catalogs, Standards, or Detailed Rules Are Still Needed

These include whether and when ordinary packaging will enter mandatory recycling catalogs, how EPR obligations will be fulfilled for different products, the specific scope of mandatory carbon-footprint disclosure for packaging, implementation details for low-VOC product labeling, and the timing and allowance methodology for formally including the papermaking industry in the national carbon market.

In addition, the VOCs environmental protection tax pilot taking effect on January 1, 2027 is a parallel policy coordinated with the Code and should not be described as a tax directly imposed by Articles 213–215 of the Code themselves.

Only by separating these four layers can companies know what requires immediate correction, what requires a data foundation, and what should await formal rules.

II. The First Account: Paper Mill Resource Efficiency—Water, Fiber, and Energy Can No Longer Be Calculated Separately

Article 944 of the Code expressly lists papermaking alongside steel, nonferrous metals, petrochemicals, chemicals, building materials, printing and dyeing, and other industries, calling for green and low-carbon transformation, promotion of cleaner-production technologies and equipment, process renewal and upgrading, and improved mandatory standards for energy efficiency, carbon emissions, and other indicators.

It is true that “papermaking is specifically named.”

But Article 944 is first and foremost an industrial-transformation and institutional-development provision; it does not mean that a paper mill can be penalized directly under this article simply because it has not completed some vaguely defined “green transformation.”

Its real signal is that future evaluation of paper mills will not stop at whether end-of-pipe emissions meet standards, but will increasingly focus on how much water, fiber, steam, electricity, and carbon emissions are consumed per unit of product.

ACCOUNT 01

Behind the Water Account Is Actually a Fiber Account

Articles 297–300 of the Code require enterprises causing water pollution to carry out technical modifications, increase water reuse rates, and reduce wastewater and pollutant discharges; industrial wastewater must be fully collected and treated, toxic and hazardous wastewater must be collected separately and may not be diluted for discharge; and pretreatment requirements must be met before wastewater enters centralized treatment facilities.

For a paper mill, the value of discharging one metric ton less wastewater goes far beyond saving the treatment cost for one metric ton of wastewater.

White water and wastewater often carry fines, fillers, sizing agents, retention and drainage aids, wet-strength agents, and heat. Fiber lost with water increases both raw-material costs and wastewater-treatment loads and sludge volumes.

Truly valuable water management must first define the company or production-line boundary and then establish two balances simultaneously. The following are the simplest illustrative equations for an annual plant boundary:

Water Balance

Fresh water and other externally introduced water = water leaving with products + evaporation losses + water leaving with sludge and solid waste + discharged water + inventory changes + other explainable losses

Fiber Balance

Oven-dry fiber entering the papermaking system = oven-dry fiber in finished products + fiber in externally discharged by-products + fiber in sludge, screen rejects, and wastewater + inventory changes + other explainable losses

White-water recovery and broke reuse are internal system recirculation and should be reported separately as process indicators; they must not be added repeatedly to external inputs or final outputs. Different mills must also expand the equations according to actual conditions such as integrated pulp-and-paper boundaries, moisture in purchased pulp, and water introduced by fillers and chemicals.

If these two balances cannot be closed, a company will struggle to determine whether a “water-saving project” actually reduces total cost or merely shifts the problem into web breaks, paper defects, chemical consumption, and sludge disposal.

One misconception must be avoided in particular:

Increasing the water reuse rate does not mean blindly pursuing a completely closed-loop water system.

If the water system is excessively closed, salts, anionic trash, stickies, and microorganisms may accumulate, causing poorer drainage, sizing failure, deposits, corrosion, odor, and increased web-break rates. The industry should not pursue a “zero-discharge slogan,” but the overall optimum among fresh-water use, fiber loss, chemical loss, and treatment cost while maintaining paper-machine stability and paper quality.

ACCOUNT 02

The Energy Account Is Becoming a Carbon Account, but the Future Must Not Be Written as Though It Has Already Happened

GB 31825-2024, The Norm of Energy Consumption per Unit Product of Pulp and Paper, took effect on May 1, 2025. It is a currently effective mandatory national standard, not a new requirement created only after the Code takes effect.

Meanwhile, carbon-data requirements are not merely a long-term signal. The Ministry of Ecology and Environment’s Notice on Relevant Work for the National Carbon Emissions Trading Market in 2026 has already made clear that entities in papermaking and other industries with annual greenhouse gas emissions of 26,000 metric tons of CO₂ equivalent, approximately equivalent to comprehensive energy consumption of 10,000 metric tons of standard coal, are included in annual greenhouse gas emissions reporting management; the notice requires relevant companies to submit their 2025 emissions reports and supplementary data by March 31, 2026, and provincial ecology and environment authorities to complete verification by the end of 2026. For paper mills meeting the threshold, the task now is not to wait for market expansion, but to review whether the submitted data, supporting documentation, and calculation boundaries can withstand verification.

But two matters must be distinguished: emissions-reporting management has already begun, while allowance management has not. Under the current 2026 notice, the industries subject to allowance allocation and surrender remain power generation, steel, cement, and aluminum smelting. The Ministry of Ecology and Environment has begun preparations to expand coverage to papermaking and other industries, but the formal inclusion date and allowance methodology still await an official plan; conclusions should not be drawn in advance of the competent authority.

The most valuable preparation for paper mills now is to establish four robust metrics for every paper grade and production line:

Fresh-water consumption, unit: m³/metric ton of paper;

Fiber loss, unit: kg/metric ton of paper;

Electricity, steam, and fuel consumption, allocated by paper grade and process;

Pollutant load, considering both concentration and generation and discharge per unit of product.

This is because most effective decarbonization projects first appear as reductions in steam, electricity, web breaks, rejects, and downtime costs. For paper mills under margin pressure, decarbonization that first improves operating cash flow has the greatest implementation value.

III. The Second Account: Packaging Design and Orders—“Paper” Does Not Automatically Mean “Green”

Article 972 of the Code encourages green design; Article 973 encourages green packaging and packaging reduction, while expressly requiring business operators to use reasonable packaging, comply with mandatory standards restricting excessive commodity packaging, refrain from excessive packaging, and ensure that packaging materials, structures, and costs are appropriate for the contained product; Article 974 further requires e-commerce, express delivery, food delivery, and other industries to reduce packaging use, prioritize reusable and readily recyclable packaging, and actively recover and utilize packaging.

What packaging companies should focus on most is not the phrase “paper replacing plastic,” but the fact that the object of evaluation has shifted upstream from a single material to the complete packaging system.

A paper-packaging solution may simultaneously include:

Base paper, primer, barrier layer, ink, overprint varnish, adhesive, heat-seal layer, wet-strength system, window material, and final forming structure.

If replacing one plastic layer significantly increases base-paper basis weight, coating usage, and drying energy; if packaging-line speed falls and reject rates rise; if food-contaminated packaging has no practical collection pathway; or if the final package generates large amounts of screen rejects and stickies in the repulping system, then “higher paper content” does not automatically demonstrate better system-level environmental performance.

Professional green-packaging design must pass at least four gates:

GATE 01

Function Gate

Packaging must first satisfy basic functions including water resistance, grease resistance, oxygen barrier, heat sealing, abrasion resistance, printing, migration safety, shelf life, and transport protection. Environmental concepts cannot substitute for product safety and use performance.

GATE 02

Material-Efficiency Gate

The comparison is not the single question of “paper or plastic,” but whether total material weight declines for the same packaging function, whether unnecessary layers and void space are reduced, and whether excessive packaging exists.

GATE 03

Manufacturing-Efficiency Gate

Line speed, drying energy consumption, changeover time, cleaning-agent usage, reject rate, and quality variability must be included in the calculation. A material can generate orders only if it can be produced reliably on the customer’s actual equipment.

GATE 04

Real-World Circularity Gate

The packaging must specify in which region, through what collection system, and under what sorting and repulping conditions it will be handled. Being “separable” in a laboratory does not mean it will necessarily be collected, sorted, and utilized in the real world.

Therefore, evidence for “recyclability” should not consist only of a substrate test report, but should at minimum be tied to:

The complete BOM of the final package;

Materials in each layer and their usage per unit area;

Worst-case coating weight, printed area, and laminated structure;

Applicable recycling scenarios and test methods;

Fiber recovery or yield, screen rejects, and interfering substances;

Quality of recovered pulp or paper made from it.

The Code will not automatically deem packaging green simply because it is made of paper; what is actually evaluated is the complete packaging system.

For packaging companies, this will directly change the logic of orders: in the past, customers bought a box, a cup, or a bag; in the future, leading customers are more likely to buy a solution that is “functionally compliant, material-efficient, stable in manufacturing, clear in its recycling pathway, and supported by verifiable data.”

IV. The Third Account: VOCs Raw Materials and Tax Burden—The Fastest Route to Orders May Be Material Balance, Not Carbon

Articles 213–215 of the Code provide for content limits on raw and auxiliary materials and products containing VOCs, the use of low-VOCs materials, emission-reduction measures during production and use, and a low-VOCs product labeling system.

For packaging printing, coating, and laminating companies, these requirements translate into very specific materials:

Inks;

Overprint varnishes;

Adhesives;

Cleaning agents and thinners;

Fountain solutions;

Coating agents and finishing agents.

But two common misconceptions must first be corrected.

Water-based does not mean zero VOC, and low odor does not mean low VOC.

VOC determinations for a product must be tied to the product category, ready-for-use state, dilution method, test method, and applicable standard. Compliance conclusions cannot be drawn solely from the words “water-based.”

A more direct operating signal comes from the VOCs environmental protection tax pilot taking effect on January 1, 2027. The first group of industries expressly includes printing and the manufacture of chemical raw materials and chemical products. The tax rate ranges from RMB 8–12 per pollution equivalent, and the VOCs pollution-equivalent value is 0.95 kg; emission-source items involving the use of raw and auxiliary materials containing VOCs are calculated using a material-balance method.

Consider a simplified example solely to understand the order of magnitude:

If 1 metric ton consists entirely of taxable VOCs emissions, without considering deductions for 18 individual substances, performance-level incentives, or differences in locally applicable tax rates:

1,000 kg ÷ 0.95 kg/pollution equivalent × RMB 8–12/pollution equivalent

This corresponds to approximately RMB 8,421–12,632.

The key term here is taxable emissions.

It is not 1 metric ton of purchased material, not 1 metric ton of ink, and not simply the VOC content measured in a product multiplied by the tax rate. Whether a company is taxable and the amount of taxable emissions depend on industry classification, pollutant-discharge-permit identification, actual emission-source items, material balance, collection and treatment, deductions for 18 individual substances, and local tax rates.

Under the pilot measures, “VOCs mass fraction greater than or equal to 10%” is one of the identification criteria for emission-source items involving raw and auxiliary materials containing VOCs; it is not a qualification threshold for determining whether a product is “low VOC.”

Therefore, the real value a material supplier can create for customers is not a broad claim that a product is “more environmentally friendly,” but helping customers calculate a comprehensive cost sheet:

Material procurement cost

Actual unit consumption

Dilution and cleaning costs

Drying energy consumption

Waste-gas collection and treatment costs

Reject and downtime losses

Potential taxable-emissions cost.

If a low-VOC material causes line speed to decline significantly while energy consumption and rejects increase, the overall benefit may not hold; conversely, if it can maintain adhesion, barrier performance, heat sealing, abrasion resistance, blocking resistance, and storage stability at a low dry coat weight, it may simultaneously reduce raw-material, treatment, tax, and production-line losses.

VOCs are not a marketing term, but an operating-data chain running from procurement records and material balance to pollutant discharge permits and tax filings.

This is likely to become one of the fastest routes to real orders for functional packaging materials over the next year.

V. The Fourth Account: Circularity, Carbon, and Customer Access—Environmental Data Are Becoming Part of the Product

Article 959 of the Code establishes an extended producer responsibility system; Article 977 further provides that enterprises producing, importing, or selling products and packaging legally included in mandatory recycling catalogs must fulfill responsibilities for recovery, utilization, or harmless disposal as required.

But this cannot be interpreted to mean:

“Beginning August 15, all paper cups, paper boxes, and paper bags must pay a uniform EPR fee.”

The trigger under Article 977 is being “legally included in a mandatory recycling catalog,” and the specific catalogs and administrative measures are still to be formulated by the national development and reform authority together with relevant departments.

However, industry preparations have already begun.

The National Development and Reform Commission’s official interpretation of the “15th Five-Year Plan” for Circular Economy Development expressly proposes supporting industry-led voluntary recycling initiatives for beverage cartons and disposable takeaway beverage cups. The shared challenges of these two packaging categories are highly representative: low value, dispersed distribution, susceptibility to food-residue contamination, and the typical presence of non-fiber functional layers.

The real industry question is not simply whether something is “recyclable,” but:

Who establishes collection points, and who bears collection and transportation costs;

Whether contaminated packaging still has economic value;

Where the fiber and non-fiber components respectively go;

How brands, platforms, packaging converters, material suppliers, and paper mills share responsibility;

How recycling outcomes are recorded and verified, and how recovery without actual utilization is prevented.

At the same time, Article 1000 of the Code calls for companies to implement green procurement and establish green supply chains in accordance with national requirements; Article 1036 establishes systems for product carbon-footprint accounting, tiered management, labeling and certification, and information disclosure.

By the end of 2025, China had issued 15 national standards for product carbon-footprint accounting and more than 200 group standards for specific sectors; the second edition of the national greenhouse gas emission factor database increased the total number of factors to 576.

This does not mean that every paper package must disclose its carbon footprint on August 15.

But a more practical change may arrive sooner: brand customers, export customers, government procurement, and leading supply chains may first turn traceable environmental data into supplier-access requirements.

In the future, delivery documentation for a paper, coating, or package should not consist only of a quotation and TDS, but should progressively include an internal “product environmental attributes dossier”:

Product identity and formulation or structural version;

Final packaging BOM and weight per package;

VOC data, test methods, and applicable boundaries;

Key energy, raw-material, and manufacturing-loss data;

Recycling compatibility of the final package and applicable scenarios;

Primary activity data required for carbon-footprint accounting and a description of data quality;

Environmental claims that may be used, may be used with limitations, and must not be used.

This is not a nationally prescribed uniform name for a “product passport,” but a data asset that companies should proactively establish.

An important dividing line in the next round of packaging competition will not be who talks about green concepts more effectively, but who can convert green performance into verifiable costs, performance, and data.

VI. Which Orders Will Come First? Not Every Green Opportunity Arrives at the Same Time

From the perspective of the papermaking and packaging value chain, opportunities can be divided into “near-term orders that can already be transacted” and “medium-term capabilities that require joint development.”

NOW 01

Paper Mill Water Saving, Fiber Recovery, and Energy-Efficiency Upgrades

The payment logic is clearest here: how much fresh water, steam, electricity, fiber, and wastewater-treatment cost is saved per metric ton of paper; and whether web breaks, rejects, and downtime are reduced. As long as the measurement boundary is clear, the value can enter the financial model.

NOW 02

Low-VOCs Inks, Overprint Varnishes, Adhesives, Cleaning Agents, and Functional Coatings

Customers will not compare only price per kilogram; they will increasingly compare actual consumption per finished product, line speed, drying, treatment, cleaning, rejects, and potential taxable emissions. Suppliers able to provide material-balance data and real production-line data are more likely to enter procurement decisions.

NOW 03

Material Reduction and Structural Optimization

Reducing unnecessary layers, lowering packaging weight per unit, minimizing void space, optimizing box design and die-cut layouts, and improving transportation loading efficiency simultaneously address excessive packaging, cost, and logistics efficiency and generally make it easier to establish a commercial closed loop than simply replacing one material with another.

NEXT 01

Recyclable Barriers and Complete-Packaging Validation

The opportunity is not simply to “replace PE,” but to reduce non-fiber layers and lower the risks of screen rejects and stickies while meeting food-contact, barrier, heat-sealing, and shelf-life requirements and completing validation on the final package.

NEXT 02

Recycling Systems for Beverage Cartons and Takeaway Cups

This is a systems-engineering challenge requiring coordination among brands, platforms, stores, collection and transportation operators, recycled-paper mills, and material suppliers. Laboratory results for an individual material cannot substitute for real-world collection rates and final utilization rates.

NEXT 03

Product Carbon Footprints and Green Supply-Chain Data

In the short term, these appear in customer questionnaires and audit materials; in the long term, they will enter product design, procurement, pricing, and supplier segmentation. The earlier original activity data are established, the lower the future accounting cost and interpretation risk.

This shows that the industrial opportunities created by the Code are not a generalized “environmental market,” but three types of value that can be purchased:

Quantifiable cost reductions, verifiable product upgrades, and data capabilities that can enter customer systems.

VII. What Companies Should Do Now: A 30/90/180-Day Roadmap

NEXT 30 DAYS

First Distinguish Obligations, Then Complete the Baseline Records

Establish a policy matrix and divide matters into:

Existing obligations already in force;

Legal or administrative transitions occurring on August 15;

Policies already issued that will take effect in the future;

Systems whose direction is clear but that still await catalogs, standards, and detailed rules.

At the same time, reconcile environmental impact assessments, pollutant discharge permits, actual production lines, and discharge outlets; inventory the BOMs of key products; establish baseline records for water, fiber, energy, VOCs, and waste streams; and remove promotional claims such as “zero VOC,” “fully recyclable,” “100% biodegradable,” “zero carbon,” and “compliant with the Code” when they lack defined boundaries.

NEXT 90 DAYS

Select Only One SKU and Compare Three Options

Do not begin by transforming the entire product line. Select one high-volume package with strong customer attention and room for structural improvement, and compare three options using the same functional unit:

Existing baseline structure;

Minimum-change option;

Structural-upgrade option.

Compare on a consistent basis: total packaging weight, number of material layers, functional performance, unit consumption, line speed, drying energy consumption, reject rate, VOC input, treatment load, recycling performance, and total cost.

Only a like-for-like comparison can avoid a situation in which “one individual indicator is greener while total system cost and environmental burden are actually higher.”

NEXT 180 DAYS

Build an Evidence Package That Can Be Submitted for Customer Audit

Select at least one product and create complete documentation covering the boundaries from raw materials and manufacturing through use and recycling:

Technical specifications and version;

Performance and test methods;

Food-contact or product-safety documentation;

VOC and actual-use data;

Recycling compatibility of the complete package;

Carbon-footprint activity data;

Environmental claims and their levels of evidence.

The value of this documentation is to unify the basis used by R&D, production, environmental management, procurement, sales, and customer audits.

VIII. BIOTEN View: The Value Standard for Functional Materials Is Changing

The Ecological and Environmental Code does not specifically name PHA, nor does it provide that paper, water-based, or bio-based materials automatically qualify as green materials.

Therefore, the opportunity for water-based PHA functional materials cannot be built on the material name itself, but must be built on a verifiable customer value chain:

Can the required water resistance, grease resistance, heat sealing, or abrasion resistance be delivered at a lower unit consumption;

Can line speed, adhesion, and stability be maintained on the customer’s actual equipment;

Can VOCs input and treatment load be reduced;

Can the real-world recycling pathway of the final paper package be preserved as much as possible;

Can the data required for chemical compliance, material sourcing, and carbon-footprint accounting be provided.

“Bio-based” can translate into a low-carbon advantage only when carbon footprints are compared using the same functional unit and clearly defined system boundaries; “biodegradable” can translate into real value only when environmental conditions, time, and end-of-life pathways are specified; and “repulpable” can become a credible claim only when validated on the final printed, coated, laminated, and converted package.

For functional-material suppliers, what truly needs to be delivered in the future is not merely one metric ton of material, but:

Material Performance + Manufacturing Window + Total Cost + Recycling Compatibility + Environmental Data.

This is also the professional position BIOTEN Packaging should build: not declaring “compliance” on behalf of customers in advance, but helping customers turn a green direction into a packaging solution that is manufacturable, verifiable, and commercially viable.

Conclusion

The impact of the Ecological and Environmental Code on the papermaking and packaging industry can be condensed into three statements.

For paper mills:

Upstream operations must not only demonstrate compliant emissions, but also demonstrate how to produce the same paper consistently using less water, fiber, and energy.

For packaging companies:

Downstream operations must not only demonstrate the use of paper, but also demonstrate how the complete package reduces material use, can be manufactured consistently, and preserves a realistic circularity pathway.

For material suppliers:

They must not only demonstrate material performance, but also show how the material reduces customers’ total costs and environmental burden.

August 15 is not the endpoint at which all green rules simultaneously become fully implemented, but the starting point for the papermaking and packaging industry to rewrite environmental responsibility into its operating model.

The companies that will truly be competitive in the future are not those with the most green terminology, but those able to demonstrate through processes and data that:

For the same packaging function, they consume fewer resources, generate less pollution, preserve better circularity pathways, and create quantifiable operating value for customers.

This is the most fundamental impact of the Ecological and Environmental Code on the papermaking and packaging value chain.

Sources and Scope Notes

Full Text of the Ecological and Environmental Code of the People’s Republic of China | Ministry of Ecology and Environment

Notice on Optimizing the Format of Pollutant Discharge Permits (Duplicate Copy) | Ministry of Ecology and Environment

Pilot Implementation Measures for Levying Environmental Protection Tax on Volatile Organic Compounds | Ministry of Finance, State Taxation Administration, Ministry of Ecology and Environment

Expert Interpretation II of the “15th Five-Year Plan” for Circular Economy Development | National Development and Reform Commission

Progress in Building the Product Carbon-Footprint Management System | Ministry of Ecology and Environment, June 2026 Press Conference

Notice on Relevant Work for the National Carbon Emissions Trading Market in 2026 | Ministry of Ecology and Environment

Q&A on Preparations to Expand the National Carbon Market to Papermaking and Other Industries | Ministry of Ecology and Environment

GB 31825-2024, The Norm of Energy Consumption per Unit Product of Pulp and Paper | National Standards Full-Text Disclosure System

2025 Revenue and Profit of Paper and Paper Products Enterprises Above Designated Size Nationwide | National Forestry and Grassland Administration

“2025 Annual Report on China’s Paper Industry” | China Paper Association

Note: This article is industry research and operating analysis and does not constitute legal, tax, certification, or compliance advice for any specific company. Companies should make determinations based on product category, production process, pollutant discharge permit, local policies, and formally issued supporting rules. The simplified examples in this article are solely intended to explain orders of magnitude and do not replace actual company filing calculations.

Research: August 9, 2026 | BIOTEN Packaging Industry Insights