Yes, but the quoted section actually confirms the article’s interpretation. The micro-enterprise exception in the final bullet on page 11 concerns branded packaging when it is initially supplied within a Member State.
"Within a Member State" is an important point here.
The relevant example is the preceding bullet on page 11: when a company fills a box and sends it directly to an end user in another Member State, that company becomes the producer in the destination country. In the article, the Greek maker is that company.
Micro-enterprises receive simplified reporting below 10 tonnes in the regulation, but they are not exempt from registration or destination-country EPR.
"Within a Member State" is an important point here.
The relevant example is the preceding bullet on page 11: when a company fills a box and sends it directly to an end user in another Member State, that company becomes the producer in the destination country. In the article, the Greek maker is that company.
Micro-enterprises receive simplified reporting below 10 tonnes in the regulation, but they are not exempt from registration or destination-country EPR.