I agree, with flight deck this will be impossible to maintain as we start our duty at report time, even with dead heading. So as I understand it on two sectors starting after 22:00 we have 10:15 which is not even enough to go to MUC never mind FRA and back!
As soon as the ASRs come in with a mention of "micro sleep" or "fatigue" the GCAA will stop it.
Of course if we change all our departure times to 08:00 then it is just about possible but with delays, which we can build in of course, then ASRs again!