If development has yet to start, they are not Change Requests.
They are requirements that were left out.
They are a cause for concern because the delivery is changing before it can be built.
They are a moment to pause and ask the customer what problem you are really trying to solve.
They can be the start of a conversation to get back on track.
But they should never be accepted verbatim because at this point they are not changes to the project, they are redefining what is being delivered.