Dear Stefan
Small add on:
if you check e.g.: http://help.sap.com/saphelp_nw04/helpdata/en/12/83e03c19758e71e10000000a114084/content.htm
and make some research regarding change pointer you will find transactions like BD21/BD22
You will in these links and others find the standard SAP tables to store change pointers. I am pretty sure that CG33 / CG02 must support the change pointer writing as EH&S is designed in such a way that ALE distribution is possible for specifications.
So may be use your test example and make first sure that change pointer are writing "similar" (I would expect that this must/will be done).
C.B.
PS: I found this nice link as well:
http://help.sap.com/saphelp_nw04/helpdata/en/0b/2a61bd507d11d18ee90000e8366fc2/content.htm
Interesting here is: first the change document is generated, second the change pointer is generated and the using the change pointers and the corresponding "Master data" (in this case specification data) is transferred to an IDOC
That means: without a "change document" no ALE Distribution take place.
Result: if CG33 really would not create a change document, no ALE distribution would take place;
PPS: e.g. check this as well:
http://scn.sap.com/thread/1538939