Hello, and welcome to the Cove!
I'm pretty sure some certification body will accept what you did as ok (I've seen crazier stuff accepted
), but ISO 13485 does not have an option for that. You can have NA clauses in clause ˆ, 7 or 8 depending wither in the nature of your device (sterile, for example), or activities you do not perform (such as several if you are not a manufacturer).
Even as a contract manufacturer, you probably have several regulatory requirements applicable to you. For a general example, a contract manufacturer performs manufacturing in the name of the "legal"manufacturer, and thus the contract manufacturer complies with regulatory QMS requirements for the activity they perform (although the full responsibility is still with with the "legal"). That's one of the reasons we added a "quality agreement" to the third party activities requirements in 4.1.5, the most important thing this quality agreement has is a definition of which activities and responsibilities of each party in relation to compliance with regulatory requirements.
So, per 4.1.1 you have to define your role in the applicable regulatory requirements (as I mentioned elsewhere, this is probably the most important clause of the 2016 version of the standard) and contract manufacturer is a clear role in several regulatory systems. Then you have to determine and comply with (per 5.2) the regulatory requirements for each of those roles (probably together with you contracting clients as they will define in quality agreements what regulatory requirements you need to comply with).
So, no, in my opinion, it's not acceptable.