不属于这几个角色的话应该就不需要NDC。

因为你没说你提到的经销商是否会在产品上使用它的标签logo等，所以无法直接判断它是否属于这几个角色。21 CFR 207.1对于repacking, relabeling, or private label distribution的行为和角色均有具体定义，你可以再详细对照一下下面看看你说的代理是否属于 repacking, relabeling, 或private label distribution的范畴。

• Private label distribution  means commercial distribution of a drug under the label or trade name of a person who did not manufacture, repack, relabel, or salvage that drug.
  Private label distributor   means, with respect to a particular drug, a person who did not manufacture, repack, relabel, or salvage the drug but under whose label or trade name the drug is commercially distributed.

• Relabel  means to change the existing label or labels on a drug or drug package, or change or alter the existing labeling for a drug or drug package, without repacking the drug or drug package. This term does not include the addition or modification of information affixed solely for purposes of delivery to a customer, customer identification, and/or inventory management.
  Relabeler means a person who owns or operates an establishment that relabels a drug. When not modified by “domestic” or “foreign,” the term includes both domestic relabelers and foreign relabelers.

• Repack or repackage means the act of taking a finished drug product or unfinished drug from the container in which it was placed in commercial distribution and placing it into a different container without manipulating, changing, or affecting the composition or formulation of the drug.
  Repacker means a person who owns or operates an establishment that repacks a drug or drug package. When not modified by “domestic” or “foreign,” the term includes both domestic repackers and foreign repackers.