FDA registration requirements

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". 

Comments?   Thanks!

Are you labeling your cartons?

I print and process a cardboard container...then insert a plastic form and the prepackaged food item inside the container.  Then I place a number of the assembled containers in a bulk carton for shipment to a customer.