Can 2019 RDS Device CALs be swapped, or activated as User CALs?

I've bought some 2019 RDS Device CAL's and haven't yet activated them.  Before I do, am I able to have them changed to 2019 RDS User CAL's, or simply activate them as User CAL's when I come to add them to the RD Licensing Server?

Part no 6VC-03747.