Mounting root file system might nowadays conceivably involve some non-trivial userspace code that never even was implemented in kernel space. Few examples:
- Searching for root filesystem based on it's contents (in simple case UUID, but mechanisms like "contains this file" are used sometimes) instead of "physical" location
- Encrypted root filesystem (requires some kind of UI for entering the passphrase)
- LVM2 (which is set of userspace utilities that configure more general kernel modules that know nothing about the actual on-disk format)
- while there is slightly hackish kernel support for configuring network interfaces before having userspace and mounting rootfs from NFS, such thing cannot possibly deal with all variants of network configuration (eg. VLANs, 802.1x, ...) and possible network filesystems/block devices.
- root on ramdisk, copy-on-write overlay filesystem or something like that.
To summarize: it's entirely possible to have the system boot of PXE, authenticate via WPA-EAP on wifi and fetch it's own root filesystem into ramdisk via HTTPS while storing writes onto NFS somewhere. Implementing all which is required for that in kernel space is neither possible nor useful.
By the way, the point of initramfs is that it is loaded into memory by bootloader using whatever means the bootloader has and the image does not have to be on rootfs accessible to kernel (for PXE it typically isn't).