Yes, you may apply, but you must still address how you will receive, review, identify, and transfer key aspects of the design package into shop routers/checklists, prepare for the possibility of design changes, and finally ensure the design resulted in a product compliant with the applicable API product specification. API will review these control features that ultimately make up the design package.
In some cases, due to the nature of the products and specifications, API allows an applicant to exclude design and development activities in its quality management system. Casing, tubing, pipe and plate manufacturers, threaders, drilling mud producers, testing agencies, and gage manufacturers that follow the API specification with no deviation, may apply to exclude design development and control. Applicants manufacturing products to one of the other API specifications must be prepared to show the API auditor their design documents.