Possibly, but probably not. More likely it means they had sufficient seed remaining from the previous crop years that they didn't bother purchasing more, they just re-tested the older seed and updated the labeling for the packets. That's why you generally see the phrase 'packed for' on the label. Tomato seeds retain their viability for many years, incidentally.
Also, most retail seed providers don't grow their own, they purchase from third-party sources.
I worked for a regional seed company years ago. We were the distributors of bulk seeds from many major and minor seed companies. If you wanted to buy any of their seeds in bulk, you didn't buy direct from the producers, you bought from one of their regional distributors. They sold us the same seed they sold to all the companies that package and sell the very same seeds under their private labels. Burpee, Ferry-Morse, etc. - as long as it's the same variety name, it's all the same seeds coming from the same sources. Only the package and the price differ.