How to change the location of admin notice in html without using Javascript?

I found out by accident recently that all the notices will be moved to after the first <h2> tag on the page inside a <div class="wrap">. This gives you some slight control in that, for example, on a plugin settings page you can put an empty <h2></h2> at the very top if you want to use <h2>Plugin Title</h2> without it messing up the display formatting there.