I am a producer of food packaging. I have been asked by a customer to take in bulk pre-packaged food and place it into my cartons. I may have to hold it for a period of time in controlled conditions. I do not, at any time, open any of the pre-packaged items...do not touch or expose the food itself. I would then ship the cartons back to the customer. Would I be required to register with the FDA? Section 9.10 of the Food Defense Guidance for Industry would imply that I do not, as I am not "placing food in a container that directly contacts the food". However, Section 17.2 implies that I have to because I am "holding" it. It does, however, only directly identifies "produce".