The exact scenario from TFA is listed just before the diagram you're referencing :
"If a farmer packs a few apples in a container (sales packaging) and sells it under its own name or trademark to a retailer or consumer in the same Member State, the farmer is a producer [for the purpose of EPR obligations]"
And :
"If the farmer sells the packed apples under its own name or trademark in another Member State, the farmer is only the producer if the recipient is the end user of the apples."
And :
"If the farmer is a micro-enterprise, which is often the case, and the supplier of the apple container is established in the same Member State, such supplier becomes the producer"
That last exemption is quite restrictive, it can be a problem. I can attest that a French manufacturer of antistatic packaging refused to sell to me as a micro enterprise when I was selling electronics kits a long time ago and I had to buy them from China. Some states might not even have packaging manufacturers. So the concerns from the article are founded.
Under definitions (page 9) there's a big section
> 6) Who is the ‘manufacturer’ of branded packaging? NEW!
And it starts off this blurb:
> According to the PPWR (Article 3(1), point (12)), if a packaging does not bear a name or trademark, the manufacturer will be the natural or legal person who manufactures packaging or packaged products.
Seems pretty obvious to me the generic bubble envelope example from the blogpost doesn't make sense because that is generic packaging where the manufacturer has to handle this.
Edit: The farmer example is a bit bad imho because produce is not like the products in the blogpost and 'under its own trademark' applies to the product packaging (e.g. custom Apple carton frames etc.), best to focus on the more applicable sections imho.