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.