Interesting question. I don't have a direct answer for it, but looking from the eyes of an auditor, I would like to see traceability to the change such as: Who reviewd it? approved it? Is it compliant to EUMDR? why did the logo change happen? etc, etc. Maybe there are other places to record it, like management review minutes if it is a simple logo update. I know that in my case (Medical device class 2A) when we change any information on the product or shipping labels (like a logo size for example), ECR/ECOs affect everything that has that updated logo or new information. So, my guess is that even if you don't release it through ECR/ECO, there will be a cascading effect to update everything else eventually. Check with your Regulatory Affairs or Tech Pubs department to see what ISO13485 requires. A good auditor may ask for clarification during an audit.