"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.