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Would my company now be playing a role in the contract manufacture of this finished device?
If on the other hand your actions are solely for customer convenience and have zero bearing on either safety or effectiveness, then (maybe) they're just a distribution action. But, your comments about battery life seem to directly identify that the reason you started doing activation was because of an effectiveness issue.
Why not provide prominent instructions to the end user to activate the battery upon receipt? Many consumer/business/industrial products are distributed in that manner.
