For distributor who involves only storage and distribution, I think it is obviously not appropriate the following, unless otherwise required,
"e) implementation of defined operations for labelling and packaging;".
Even this case, is it required to document a justification?
As I mentioned, although the "document" was removed due to other reasons, the expectation was to have any justification documented. So yes.
The problem with the "obvious" stuff in an audit is that it's impossible to verify oif the something was not done because it was obvious or simply forgotten.