Repackaging and relabeling of a device and specification development are defined as manufacturing in 21 CFR Part 807, Establishment Registration and Device Listing for Manufacturers of Devices.
At least in common USA/Canada/EU practice, distributors and wholesalers don't normally apply/change device regulatory labeling.
Normally US FDA does not regulate distributors and wholesalers, except for their possible roles in tracking; field actions (recall/correction etc.); complaint/adverse-event-report passthrough; radiation device reporting if their products are subject to those rules; and/or if they also have an Initial Importer role.
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