Thanks for the clarification John. We are a rather large transfusion service so the idea of not being registered is rather foreign to me. I read this statement from the 2004 CFR:
(d) Manufacture means the collection, preparation, processing or
compatibility testing by chemical, physical, biological, or other
procedures of any blood product which meets the definition of a drug as
defined in section 201(g) of the act, and including manipulation,
sampling, testing, or control procedures applied to the final product or
to any part of the process. The term includes packaging, labeling,
repackaging or otherwise changing the container, wrapper, or labeling of
any blood product package in furtherance of the distribution of the
blood product from the original place of manufacture to the person who
makes final delivery or sale to the ultimate consumer.