# China’s packaging duties moved into a new Code in August 2026, but the standards that decide a pack’s fate did not change

> Since 15 August 2026, China's packaging duties sit in the Ecological Environment Code, which repealed the 2020 Solid Waste Law; the Code restates the excessive packaging, e-commerce and single-use plastics duties, while the mandatory standards GB 23350-2021, GB 43284-2023, GB 43352-2023 and GB 45186-2024 still set the tests a pack must pass.

Publisher: Strategic Packaging Insights  
Published: 2026-10-26  
Last updated: 2026-10-26  
Page: https://www.strategicpackaginginsights.com/insights/china-packaging-rules-ecological-environment-code/

**Since 15 August 2026, China's packaging duties sit in the Ecological Environment Code, which repealed the 2020 Solid Waste Law; the Code restates the excessive packaging, e-commerce and single-use plastics duties, while the mandatory standards GB 23350-2021, GB 43284-2023, GB 43352-2023 and GB 45186-2024 still set the tests a pack must pass.**

The Code, adopted by the National People's Congress on 12 March 2026, folds ten environmental laws into 1,242 articles. For packaging teams the useful reading is a map: which old article moved where, which standard now hangs off it, and which fines SPI can still state in CNY.

## Executive summary

China does not run a packaging EPR fee scheme of the European kind, and SPI has found no national packaging fee or producer responsibility organisation. Its rulebook works through four instruments at once: a statute that states the duty, State Council and ministry rules that assign it to carriers, platforms and retailers, mandatory national standards that set measurable tests, and policy documents that set dated targets. The [SPI Regulation Tracker](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/china/) follows one of each kind of instrument in its three China rules, [PR-CN-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/china/pr-cn-001/), [PR-CN-002](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/china/pr-cn-002/) and [PR-CN-003](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/china/pr-cn-003/).

The statute changed on 15 August 2026. The Ecological Environment Code, published by Presidential Order No. 70 after the fourth session of the 14th National People's Congress adopted it on 12 March 2026, repealed ten laws through Article 1242, the 2020 Solid Waste Pollution Prevention and Control Law among them. That law had carried the packaging duties in Articles 68 and 69 and the fines in Articles 105 and 106.

The duties survived the move, and in places the wording is firmer (Exhibit 2). Code Article 973 tells producers to keep packaging reasonable, follow the mandatory excessive packaging standards and "not engage in excessive packaging". Article 974 puts cutting packaging first for e-commerce, express and food delivery firms, and Article 998 restates the single-use plastics bans and the reporting duty of retail venues, platforms, couriers and food delivery firms.

What SPI cannot yet state is the new price of a breach. The penalty articles of the Code sit in Part 5, and SPI has not yet confirmed from the official text which articles and CNY amounts now replace the old fines of CNY 2,000 to 100,000. Every fine in this piece that rests on the repealed law is marked as the position before 15 August 2026.

For brand owners the practical tests are unchanged, and some tightened during 2025 and 2026. Tea packs have been capped at three layers since 1 March 2025, and parcels have faced a mandatory express packaging standard, GB 45186-2024, since 1 July 2026. The moves that matter now are to re-test packs against the amended standards, refresh carrier and platform paperwork that still cites the old law, and keep the twice-yearly single-use plastics reports running while the new penalty articles are confirmed.

## Key findings

1. The Ecological Environment Code took effect on 15 August 2026 with 1,242 articles, and Article 1242 repealed ten laws, including the 2020 Solid Waste Law (Presidential Order No. 70; Jiangmen government summary, 31 August 2026).
2. Four Code articles carry the old packaging duties forward: Article 973 on excessive packaging, Article 974 on e-commerce, express and food delivery, Article 977 on mandatory recovery lists and Article 998 on single-use plastics (Xinhua authorised text of Part 4, 13 March 2026).
3. **SPI analysis:**  the Code adds "不得进行过度包装" (must not over-package) and a duty to reduce packaging waste to the producer duty that Solid Waste Law Article 68 stated as "避免过度包装" (avoid excessive packaging), so the duty now reads as a prohibition as well as a standard.
4. GB 23350-2021 has had two amendments: No. 1 cut mooncake and zongzi packs to three layers and a 15% cost share above CNY 100 from 15 August 2022, and No. 2 cut tea packs to three layers from 1 March 2025, with a 15% cost share at CNY 200 and above.
5. **SPI calculation:**  Amendment No. 1 cut the largest permitted box for 500 g of mooncakes from 8.57 litres to 5.00 litres, 41.7% smaller, by lowering the space coefficient k from 12.0 to 7.0 (Exhibit 6).
6. The express rulebook now has two mandatory standards, GB 43352-2023 on heavy metals and named substances from 1 June 2024 and GB 45186-2024 on excessive express packaging from 1 July 2026, the latter issued on 31 December 2024 (SAMR open standards record).
7. The State Post Bureau reported more than 800 million cardboard boxes reused a year and a 10% reusable packaging share in same-city express at the end of 2025, matching the 10% target the November 2023 action plan set for end-2025 (State Post Bureau, 25 December 2025).

## What the Code changed, and what it kept

The Code is China's second law titled a code (China Daily, carried by the Henan Provincial Government, 21 August 2026), and its five parts run from general provisions through pollution control, ecological protection and green, low-carbon development to legal liability (Jiangmen government summary). The order promulgating it states that it was adopted on 12 March 2026 and applies from 15 August 2026 (Presidential Order No. 70). The NPC Standing Committee announced a bilingual edition with an English text on the NPC website on 21 August 2026, under the English title Ecological and Environmental Code (Henan Provincial Government, carrying China Daily, 21 August 2026).

Article 1242 is the hinge for packaging. It repeals the Environmental Protection Law, the Environmental Impact Assessment Law, the Marine Environmental Protection Law, the Air, Water, Soil, Solid Waste, Noise and Radioactive Pollution laws and the Cleaner Production Promotion Law, all from 15 August 2026 (Jiangmen government summary). Every packaging rule that named the Solid Waste Law as its parent lost that parent on that day.

The packaging duties now sit in Part 4, Chapter 2 on developing the circular economy. Articles 968 to 974 form the cleaner production section, which ends with the two packaging articles, Article 975 opens the waste recycling section, and Article 998 sits in the green consumption section (Xinhua authorised text of Part 4). Exhibit 2 sets the old and new wording side by side.

Three changes deserve a packaging team's attention. First, Article 973 states that producers "不得进行过度包装" (must not over-package), where Article 68 asked them to avoid it, and adds a duty to reduce packaging waste. Second, Article 974 now opens with "应当减少包装物的使用" (shall reduce the use of packaging), a stronger order of priorities for platforms and couriers. Third, Article 998 adds that substitutes for single-use plastics should be harmless as well as recyclable or degradable, which gives regulators a new hook for testing degradable mailers and tableware.

SPI analysis

None of these changes creates a new test a pack must pass on its own. The numbers still come from the mandatory standards that Article 973 points to, so a pack that passed GB 23350-2021 on 14 August 2026 still passes it today. What changed is the legal route from a failed test to a sanction, and that route runs through Part 5 penalty articles SPI has not yet confirmed.

Article 959 opens with "国家建立健全生产者责任延伸制度" (the state establishes and improves an extended producer responsibility system). The 2020 law's EPR article, Article 66, named electrical and electronic products, lead-acid batteries and vehicle traction batteries and did not name packaging. SPI has not yet confirmed whether the rest of Article 959 names product groups, so this piece does not treat it as a packaging EPR duty.

## How China's packaging rulebook is built

Most readers outside China look for one packaging law. There is none, and the Code does not create one. SPI groups the instruments into a five-layer stack, because each layer answers a different question for a compliance team (Exhibit 3).

Read from the top, the stack shows where the August 2026 change bites. Layers 1 and 4 are current: the Code is new and the standards still apply. Layers 2 and 3 are in force but three of their texts still name the Solid Waste Law as their parent or penalty source, and SPI has not yet confirmed whether the State Council, the Ministry of Transport or MOFCOM has amended them to cite the Code. Layer 5 has run out of dated targets, because the 2021 action plan and the 2023 express plan both aimed at the end of 2025.

The stack also explains why a single product can face several regulators. A mooncake gift box shipped by courier answers to market supervision departments for its sales packaging under GB 23350-2021, and to postal administrations for the parcel around it under the Ministry of Transport measures and GB 45186-2024 ([PR-CN-002](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/china/pr-cn-002/) rule notes, Article 3). The commerce department enters if the platform that sold it supplied a plastic bag or mailer.

## Who carries which duty

Exhibit 4 turns the stack into a role map. It is built from the role sections of SPI's three China rule notes and the four instruments outside the tracker, and each cell names the article that places the duty.

SPI analysis

In China the packaging maker is rarely the obligated party. Duties land on the brand owner whose pack is tested on the shelf, the platform that reports, and the courier that packs the parcel, and those three pass requirements back to suppliers by contract. A converter selling into China should expect test reports and material declarations to be the price of entry rather than a fee.

In practice: Cainiao, Alibaba's logistics arm.

The SPI Buyers Database profile of Alibaba records about 169,000 tons of packaging material avoided in Cainiao's fiscal year to 31 March 2025, nearly 36 million cardboard boxes reused and more than 680 million packages shipped in their original containers. The China E-commerce Group earned CNY 554,217 million in fiscal 2026 (SPI Packaging Buyers Database, Alibaba profile, citing Alibaba's FY2025 ESG report and annual filing). SPI calculation: reused boxes equal about 5.3% of original-container shipments. Alibaba publishes no numeric packaging target with a target year.

## GB 23350-2021: the three tests, and two amendments

GB 23350-2021, Requirements of restricting excessive package: foods and cosmetics, was issued by SAMR and SAC on 10 August 2021 and took effect on 1 September 2023 ([PR-CN-003](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/china/pr-cn-003/)). It is a mandatory standard, and clause 6 treats a pack as excessive if it fails any one of three tests: number of layers, void ratio or the cost of packaging other than the layer touching the product ([PR-CN-003](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/china/pr-cn-003/) rule notes). Exhibit 5 sets the base standard against its two amendments.

The amendments did not wait for the base standard. Amendment No. 1 was approved on 24 May 2022 and applied from 15 August 2022 to mooncakes and zongzi, more than a year before the rest of GB 23350-2021 took effect, with goods made before that date allowed to sell through their shelf life (Amendment No. 1 text). Amendment No. 2, organised by MIIT as drafting department, has a planned implementation date of 1 March 2025 on the national standards plan record, and Xinhua, carrying a Guangzhou Daily report of a Guangdong market regulator reminder, reported that its tea coefficient changes applied on release in late March 2024 and its layer limit from 1 March 2025.

The Code did not touch these numbers. SPI has not yet confirmed any amendment to GB 23350-2021 after Amendment No. 2, and found no Code article that sets layer, void or cost limits itself. Article 973 points to "限制商品过度包装的强制性标准" and leaves the content to the standards.

### What a lower coefficient does to box size

The void ratio is calculated as X = (Vn minus k x V0) / Vn, where Vn is the package volume, V0 is the contents counted at 1,000 cubic millimetres per gram or millilitre, and k is the category coefficient from Appendix A ([PR-CN-003](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/china/pr-cn-003/) rule notes). Solving for Vn at the void ratio ceiling gives the largest box a product may ship in. Exhibit 6 runs that for 500 g of product and 250 g of tea, where the ceiling is 30% because net content is above 50 g.

**SPI calculation:**  for 500 g of mooncakes the maximum package volume is 7.0 x 0.5 litres / 0.7 = 5.00 litres, against 12.0 x 0.5 / 0.7 = 8.57 litres under the old pastry coefficient. A 5-litre box is, for example, 25 cm by 20 cm by 10 cm. The three-layer cap removes the usual answer to a small outer box, which was another inner tray or sleeve.

### Where the cost cap bites

The cost test divides the cost of layers 2 and above by the sales price. Amendments No. 1 and No. 2 lower that share to 15% above price thresholds, which creates a band in which a dearer product is allowed less packaging money than a cheaper one (Exhibit 7). The scenario uses three price points in each category, all in CNY.

**SPI calculation:**  below CNY 100 a mooncake box may spend up to 20% of its price on outer packaging, so a box at CNY 99.90 is allowed just under CNY 20.00. Above CNY 100 the cap is 15%, which reaches CNY 20.00 again only at a price of about CNY 133.33 (20 / 0.15). For tea the same gap runs from CNY 200 to about CNY 266.67 (40 / 0.15). A brand that prices a gift range just above a threshold should cost its outer packaging against the lower cap, not the price.

In practice: market regulators' 2022 typical cases.

SAMR published six typical excessive packaging cases in April 2022, as carried by CCTV News and republished by the Beijing market regulator on 29 April 2022. All six failed the void ratio test. The largest fine was CNY 43,746, for a 120 g ejiao cake box, with Article 68 of the Solid Waste Law as the duty breached and Article 105 as the penalty; a 200 g tea box tested under the older GB 23350-2009 drew CNY 5,000.

## The standards family beyond food and cosmetics

GB 23350-2021 is one of four mandatory national standards that now set packaging tests in China. Exhibit 8 lists them with the dates on the national standards records. The topic is sometimes summarised with GB 43284-2023 as the express standard; the national standards record shows GB 43284-2023 covers fresh edible agricultural products, and the express standards are GB 43352-2023 and GB 45186-2024.

GB 43284-2023 brought the excessive packaging tests to fresh produce. SAMR's question-and-answer note, published on gov.cn on 22 September 2023, says it covers the sales packaging of vegetables (including edible fungi), fruit, livestock and poultry meat, aquatic products and eggs, caps vegetables and eggs at three layers and the other groups at four, and allows six months from release to effect. The national standards record gives the dates as 8 September 2023 and 1 April 2024. SPI has not yet confirmed its numeric void ratio and cost limits from the standard text.

GB 45186-2024 is the parcel counterpart. Xinhua reported on 2 July 2026 that it sets three core indicators, box fit, number of layers and tape use, each with three control tiers, sorts contents into two major classes and 25 subcategories with limits of two, three or four layers, and controls tape by both width and length. People's Daily, carried by Xinhua on 4 July 2026, reported that tape use for a box whose length, width and height sum to 700 mm or less should not exceed three times a stated reference, and four times between 700 mm and 1,000 mm. SPI has not yet read the reference length in the standard text.

SPI analysis

GB 45186-2024 shifts parcel rules from qualitative duties to tests. Since 2021, Article 25 of the Ministry of Transport measures had asked carriers to limit tape, layers, voids and filler without numbers ([PR-CN-002](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/china/pr-cn-002/)). From 1 July 2026 an inspector has a layer count and a tape allowance to check, which is closer to the way GB 23350-2021 works on the shelf. The EU's empty-space cap for e-commerce packaging under [PR-EU-009](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-009/) works on a different measure, a single ratio, so a pack built for one market is not proof for the other; the [PPWR format restrictions piece](https://www.strategicpackaginginsights.com/insights/ppwr-2030-format-restrictions/) covers the EU side.

## Single-use plastics: the 2025 milestones

Opinion No. 80, signed by NDRC and MEE on 16 January 2020, set three stages, and its last deadline fell on 31 December 2025 ([PR-CN-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/china/pr-cn-001/)). The 2021 action plan for the 14th Five-Year Plan period added dated 2025 goals for e-commerce and express parcels. Exhibit 9 lists the packaging-relevant milestones and what official sources say about them.

The 2025 goals were written as a system, not only as bans. The 2021 action plan's headline aim reads that by 2025 the plastic pollution control mechanism should run more effectively and "白色污染得到有效遏制" (white pollution is effectively curbed), with source reduction, recycling and disposal goals beneath it (NDRC, 15 September 2021). The policy texts do not publish a national outturn for each item, and SPI has found no NDRC or MEE release that scores the 2025 plastics goals one by one.

The legal basis for the bans moved with the Code. Until 15 August 2026, Article 69 of the Solid Waste Law made the bans binding and Article 106 set an order to correct and a fine of CNY 10,000 to 100,000 for breaching them or failing to report ([PR-CN-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/china/pr-cn-001/)). Code Article 998 now carries the bans and the reporting duty. SPI has not yet confirmed the Code penalty article or its amount from the official text.

What comes after 2025 is open. The 15th Five-Year Plan period runs from 2026 to 2030, and SPI has found no national plastics action plan for it on the NDRC or MEE sites by 22 October 2026. Readers comparing markets will find a sharper contrast with India, which set one nationwide date for a fixed list in 2022 and now runs recycled-content targets; the [India piece](https://www.strategicpackaginginsights.com/insights/india-plastic-packaging-rules-2026/) sets out those rules.

## E-commerce and express packaging rules

Parcels carry most of the weight in China's packaging policy because of their number. The State Post Bureau reported 198.95 billion express items in 2025, up 13.6%, and express revenue of about CNY 1.5 trillion, up 6.5% (State Post Bureau, carried by Xinhua, 22 January 2026). SAMR noted in February 2024 that annual express volume had grown from about 10 billion items a year to about 10 billion a month.

Three instruments now govern how a parcel is packed. The Ministry of Transport measures of 2021 set duties on box size, tape width, filler and staff training, with fines from CNY 1,000 to 10,000 ([PR-CN-002](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/china/pr-cn-002/)). State Council Decree No. 806, signed on 13 April 2025 and in force from 1 June 2025, wrote packaging into the Interim Regulations on Express Delivery: Article 37 requires parcels to avoid excessive packaging and meet mandatory national standards, Article 40 promotes shipping goods in their original packaging to avoid a second layer, Article 42 requires a recovery and reuse system, and Article 43 requires reports on single-use plastics in packaging. GB 45186-2024 then supplied the numbers from 1 July 2026.

Platforms carry the reporting load. The MOFCOM and NDRC measures in force since 20 June 2023 require retail venue operators, e-commerce platforms (including food delivery platforms) and food delivery firms to report single-use plastics use and recovery to the county-level commerce department through a national system, with first-half reports due by 31 July and second-half reports by 31 January of the following year. E-commerce platforms report express plastic packaging use and must obtain self-discipline commitments from merchants (MOFCOM and NDRC Order No. 1 of 2023, Articles 12, 16 and 18).

Exhibit 10 sets the end-2025 express packaging targets against what the State Post Bureau reported in December 2025.

SPI analysis

The targets that were met are the ones carriers control. Same-city reuse, box reuse and tape width are carrier operations; the 10 million reusable units and the original-package shipping goal depend on brands and platforms changing how goods leave the factory. That is where Decree No. 806 Article 40 and the 2023 action plan aim, and where brand owners selling online should expect the next round of pressure.

In practice: SF Express.

People's Daily, carried by Xinhua on 4 July 2026, reported figures from SF's packaging laboratory: in 2025 the company cut paper use by about 46,000 tonnes and plastic use by about 35,000 tonnes, and cut carbon emissions by about 130,000 tonnes. The same report says ZTO's warehouse system recommends box sizes with more than 94% accuracy across nearly 300 warehouses. These are company figures as reported, not audited totals.

## Industry reaction

> "推进快递绿色包装标准化工作，切口虽小，但意义重大。"

In English: "Standardising green express packaging is a small entry point, but it matters a great deal."

***SAMR** , deputy director of the Standards Technology Department, [interview carried on the SAMR website](https://www.samr.gov.cn/xw/mtjj/art/2024/art_8c6aef5176594377b5f67c945b1426e2.html), Legal Daily, 2 February 2024*

In the same report the department said it would work with other departments to issue a mandatory standard restricting excessive express packaging, which arrived as GB 45186-2024 on 31 December 2024.

> "年回收复用纸箱超8亿个，邮政、京东、顺丰、韵达等4家企业在20余个城市生鲜冷链、政务文件等场景试点应用循环包装。"

In English: "More than 800 million cardboard boxes are recovered and reused a year, and four companies, China Post, JD, SF and Yunda, are piloting reusable packaging for fresh-food cold chains, government documents and other uses in more than 20 cities."

***State Post Bureau** , spokesperson and director of the Market Supervision Department, [Q4 2025 press conference](https://www.spb.gov.cn/gjyzj/c106927/202512/2106ed243b7b4227a306baa333873ce7.shtml), 25 December 2025*

The briefing put the e-commerce share of express volume at about 85%, which is why platform rules shape parcel packaging more than carrier rules alone.

> "在源头减量方面，商品零售、电子商务、外卖、快递、住宿等重点领域不合理使用一次性塑料制品的现象大幅减少，电商快件基本实现不再二次包装，可循环快递包装应用规模达到1000万个。"

In English: "On source reduction, unreasonable use of single-use plastic products in retail, e-commerce, food delivery, express delivery, accommodation and other key areas falls sharply, e-commerce parcels basically stop being re-packed, and reusable express packaging reaches 10 million units."

***NDRC and MEE** , [14th Five-Year Plan plastic pollution control action plan](https://www.ndrc.gov.cn/xxgk/zcfb/tz/202109/t20210915_1296580.html), 8 September 2021*

The sentence is the 2025 target that Exhibits 9 and 10 test; of its three parts, only the re-packing goal has an official end-2025 statement in the sources SPI opened.

## Fines in CNY: what SPI can and cannot state

Exhibit 11 lists the fines SPI can tie to an official text, in CNY, and marks which ones rested on the repealed law. Nothing here is summed: each row is one instrument's range for one breach.

Decree No. 806 shows the problem in one sentence. Article 56(1) sends courier breaches of mandatory standards and plastics reporting to the Standardization Law and the Solid Waste Law for penalties, and the second of those laws no longer exists. Article 45 of the Ministry of Transport measures does the same. SPI has not yet confirmed whether the State Council or the ministries have amended these cross-references, or how enforcement bodies are applying them since 15 August 2026.

SPI's three rule notes recorded the same gap on 14 October 2026, and the tracker records for [PR-CN-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/china/pr-cn-001/), [PR-CN-002](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/china/pr-cn-002/) and [PR-CN-003](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/china/pr-cn-003/) give the Solid Waste Law fines only as the position before 15 August 2026. This piece follows that rule.

## What leaders should do now

1. **Packaging development teams, before the 2027 Mid-Autumn and Spring Festival ranges are frozen:**  re-test every mooncake, zongzi and tea pack against the amended layer, coefficient and cost limits in Exhibit 5, using the box volumes in Exhibit 6 as a first screen.
2. **Commercial and pricing teams, at the next price review:**  flag gift products priced just above CNY 100 (mooncakes and zongzi) or CNY 200 (tea), where the 15% cap allows less outer packaging money than a cheaper product (Exhibit 7).
3. **E-commerce and logistics leads, by 31 December 2026:**  collect each carrier's written packaging notice and check own-brand mailers, tape and filler against GB 45186-2024 and GB 43352-2023, asking carriers which test tier applies to each product class.
4. **Platform and retail compliance teams, by 31 January 2027:**  file the second-half 2026 single-use plastics report under MOFCOM and NDRC Order No. 1 as usual, since Code Article 998 keeps the reporting duty.
5. **Legal and regulatory teams, now:**  update internal registers that cite Solid Waste Law Articles 68, 69, 105 and 106, map them to Code Articles 973, 974, 977 and 998, and check with counsel which penalty articles now apply.
6. **Procurement, with each new supply contract:**  require test reports for heavy metals and named substances on express materials and evidence for any degradable claim, since Article 998 now asks that substitutes be harmless.
7. **Boards and investors, at the next risk review:**  ask for China packaging exposure by role, as in Exhibit 4, rather than as one compliance line, because shelf, parcel and plastics duties sit with different regulators.

## Questions for your board

- Which of our China products are tested under GB 23350-2021, GB 43284-2023 or GB 45186-2024, and when was each pack last measured?
- How many of our gift SKUs sit just above the CNY 100 or CNY 200 price thresholds, and what does the 15% cap leave for outer packaging?
- Do our contracts, policies and training still cite the repealed Solid Waste Law, and who owns the update?
- What share of our online orders ships in original packaging, and what would it take to reach the platform and carrier goals?
- Who files our single-use plastics reports, and have any been missed since the measures took effect in June 2023?
- Which penalty articles of the Code apply to our packaging, and when will counsel confirm them?

## What to watch

- **Nov 2026 onward:**  whether the State Council, the Ministry of Transport and MOFCOM amend the express regulations, the 2021 packaging measures and the 2023 reporting measures to cite the Code instead of the repealed Solid Waste Law.
- **31 Jan 2027:**  second-half 2026 single-use plastics reports due to county-level commerce departments under MOFCOM and NDRC Order No. 1.
- **Jan 2027:**  expected State Post Bureau release of full-year 2026 express volumes, on the pattern of the 22 January 2026 release.
- **31 Jul 2027:**  first-half 2027 single-use plastics reports due.
- **2026 to 2030:**  a national plastics plan for the 15th Five-Year Plan period, which SPI has not found published by 22 October 2026.

## Methodology

- **Data used:**  SPI's three China rule notes ([PR-CN-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/china/pr-cn-001/) to [PR-CN-003](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/china/pr-cn-003/)) and China jurisdiction note, written 14 October 2026; official texts and releases from the NPC, NDRC, MEE, SAMR and SAC, the State Council, MOFCOM, the Ministry of Transport and the State Post Bureau, consulted 14 to 22 October 2026.
- **Code text:**  read from the authorised Xinhua text of Parts 4 and 5 and the Jiangmen government summary of Article 1242. English renderings of Code articles are SPI translations; the NPC's English edition was announced on 21 August 2026 but this piece does not quote it.
- **Counting rules:**  fines are per breach as written in each instrument, in CNY, never summed. Box volumes and cost caps in Exhibits 6 and 7 are SPI calculations from the published formula, coefficients and caps.
- **Cut-off:**  22 October 2026.
- **Limitations:**  SPI has not yet confirmed the Code's penalty articles for packaging and plastics, the full texts of GB 43284-2023 and GB 45186-2024, or the text of GB 23350-2021 Amendment No. 2. GB 23350-2021 is read from a Hong Kong government copy. This is analysis, not legal advice; check with counsel where it applies.

## Sources

1. NPC, Presidential Order No. 70: 中华人民共和国生态环境法典, adopted 12 March 2026, in force 15 August 2026, [https://www.gov.cn/yaowen/liebiao/202603/content_7062438.htm](https://www.gov.cn/yaowen/liebiao/202603/content_7062438.htm), consulted 2026-10-22.
2. Xinhua authorised release, 中华人民共和国生态环境法典 (第四编), 13 March 2026, carried by Beijing Daily, [https://xinwen.bjd.com.cn/content/s69b31ec4e4b0687a28927582.html](https://xinwen.bjd.com.cn/content/s69b31ec4e4b0687a28927582.html), consulted 2026-10-22.
3. Xinhua authorised release, 中华人民共和国生态环境法典 (第五编), 13 March 2026, carried by Beijing Daily, [https://xinwen.bjd.com.cn/content/s69b31fdae4b0cd719e9ee9ec.html](https://xinwen.bjd.com.cn/content/s69b31fdae4b0cd719e9ee9ec.html), consulted 2026-10-22.
4. Jiangmen Municipal Government, 法制专刊 2026年第8期: 新法速递 中华人民共和国生态环境法典 (Article 1242), 31 August 2026, [https://www.jiangmen.gov.cn/jmzjj/gkmlpt/content/3/3544/post_3544094.html](https://www.jiangmen.gov.cn/jmzjj/gkmlpt/content/3/3544/post_3544094.html), consulted 2026-10-22.
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