No. If a distributor [ICH Q7, Section 17.1] of an API contracts out production Steps (e.g., drying, micronisation, milling, or sieving), then the distributor becomes a manufacturer and is subject to the entirety of ICH Q7.
This includes, but is not limited to, appropriate written agreements as stated in [ICH Q7, Section 16.12] defining responsibilities of each party. In addition, these contracted production steps must be described in registration documents, applications, or equivalent as per regional requirements.
