Heh, I definitely shouldn't have used the word any, that was dumb as I don't even have any PAL games. But certainly for NSTC-U/C and NTSC-J, this is true. In fact, you can even observe two different trends that change together in the PS2's timeline.
Last NTSC-U/C PS2 CD game I own to have -647 write offset: Gauntlet Dark Legacy
First NTSC-U/C PS2 CD game I own to have -12 write offset: Guilty Gear X
release dates: 2001-05-01 vs 2001-09-30
Surely, I have holes in my collection, I only own a couple hundred game out of many thousands. I don't have every old game. But, I would like to see a game released past 2001-05-01 that has -647 write offset. You can do a little bit of checking here if you'd like, though I checked them all. Yes, only EXE date is given. But, doing some research:
High Heat Major League Baseball 2002: 2001-03-26
4x4 Evolution: 2001-02-26
And then I found my own example, Gauntlet Dark Legacy, which is 2001-05-01. These games were found from EXE date. There may be one later one, but you'd be hard-pressed to find it. This is because the timeline of NTSC-U/C PS2 games, as well as NTSC-J, follow a pattern, and you can observe how the pattern makes a consistent and permanent change over time. My NTSC-J games past that Gauntlet date also use -12 offset. But if I get a very old NTSC-J CD game, I bet you money it has -647 offset.
Now observe this same pattern in DVD games.
Last NTSC-U/C PS2 DVD game I own to not have IFPIs: Klonoa 2 Lunatea's Veil
First NTSC-U/C PS2 DVD game I own to have IFPIs: Devil May Cry
release dates: 2001-07-25 vs 2001-10-16
Of course, if you get a reprint, like with Orphen Scion of Sorcery, then you can get IFPIs since it was printed after the time they started including them. Something different about my copy of Orphen: I bought it brand new, and on the security strip along the top of the case, the UPC number was put under the barcode. But in other older games I bought brand new, there is no UPC number. This is because another trend to observe is that old NTSC-U/C PS2 games did not include the UPC number under the barcode. Lo and behold, my copy of Orphen does put the UPC number, and it also includes IFPIs because it is a reprint.
If you observe these patterns over the timeline of games, then you'll know that what is "quite unlikely" is really that Evergrace does have IFPI codes, since it is one of the first games