You could quibble about what counts but the core is "yeah".
Ppf3-with-undo stores literal "hey, we expect byte n to be 'foo'. on apply, replace it with 'bar'. on undo, put 'foo' back. remember: the copyrighted byte is 'foo'". Touch every byte in some way and your undo data is the entire original.
Some patches literally touch one byte. Their undo is, indirectly or indirectly, a recipe for retrieving one byte of copyrighted data. Is that fragmentary enough that it is entirely in the clear? I have no idea.
So around 30 years now.
Playing the title you backed up and patched is a different matter entirely
You could design a system that generates undo info while you're patching. But it's easier to make a full backup copy of the original rom, and have no way to actually reverse the patching process.