1. a) are engaged in the packaging or labeling of such commodities, or

2. b) prescribe or specify by any means the manner in which such commodities are packaged or labeled as to:

   1. 1) identity,
   2. 2) quantity,
   3. 3) responsibility.

The rules of Subpart A and the penalties assessed under the Act shall not apply to persons engaged in business as wholesale or retail distributors of packaged commodities except to the extent that such persons: