It's HN - everyone did the latter.
[1]https://op.europa.eu/en/publication-detail/-/publication/ad1...
> The following provide some typical examples of who the producer of transport packaging is: - If Company A fills the cardboard boxes and sells them to an end user in another Member State, then Company A would typically be the producer in that other Member State.
> If Company A manufactures cardboard boxes under the name or trademark of Company B, then Company B will typically become the manufacturer and producer of the boxes in that Member State. However, if Company B is a micro-enterprise, then Company A is manufacturer and the producer in the Member State.
That has the same "typically", so I'd assume it has the same micro-enterprise exemption. Otherwise only branded boxes would be exempt and that'd be pretty weird.