Legal considerations of re-packing commercial ingredients?

A friend of mine has started serving konbini style egg sammies at his establishment, and was complaining that the cheapest shokupan he can find is actually from a local bakery, at $0.40 per slice. 

Out of curiosity i put a little time into trying to reverse engineer their ingredients from the printed ingredients on the bag. It lists an enriched unbleached white flour and with the stated ingredients, I’m relatively certain it’s Central Milling’s “Keith’s Best”. 

It goes on to list both a “Dough Improver” and a “Dough Conditioner”. I’m relatively certain that the “Improver” is SafPro Volume 3.1. Still unsure about the “Conditioner” but it contains both guar gum and xanthan gum and no dairy products or l-cysteine. I have ideas. But that’s not the point. 

Naturally, the SafPro product is sold 10kg at a time. Which is a lot at 0.1% unless his egg sammies really take off. 

And then i realized, the diastatic malt product i have is almost certainly Red Star re-packaged. 

People pay near $20 for 1lb of various bran…