What’s the difference between security updates and safety-affecting updates?

Security updates and safety-affecting updates serve different purposes in product management. Security updates address digital vulnerabilities, data breaches, and cybersecurity threats, while safety-affecting updates prevent physical harm to consumers and address risks that could cause injury, illness, or death. Understanding this distinction helps you navigate EU regulatory requirements and maintain proper documentation for market surveillance purposes.

What exactly are security updates versus safety-affecting updates?

Security Updates	Safety-Affecting Updates
Protect digital systems from cyber threats	Address risks causing physical harm to consumers
Patch software vulnerabilities and strengthen encryption	Prevent death, injuries, illness, or chronic health effects
Focus on information security and digital infrastructure	Governed by General Product Safety Regulation (EU) 2023/988

The key difference lies in the nature of the risk being addressed. Security updates protect against digital threats that could compromise data or system integrity, while safety-affecting updates prevent physical harm to users. Both types can apply to the same product—for instance, a smart home device might receive security updates for its software vulnerabilities and safety updates for hardware components that could overheat.

When substantial modifications occur through either type of update, they might affect the product’s nature and characteristics in ways not foreseen in the initial risk assessment. If these modifications jeopardise safety and are carried out by someone other than the consumer, the person making the modification becomes subject to manufacturer obligations under the GPSR.

When do you need to report each type of update to EU authorities?

Reporting requirements differ significantly between security and safety-affecting updates. The following list outlines the key reporting obligations:

Safety-affecting updates: Must notify authorities immediately when you consider or have reason to believe a product is dangerous
Notification channel: Use the Safety Business Gateway, the mandatory tool for communication with authorities
Serious risks: Require immediate reporting to market surveillance authorities
Required information: Clear description of health and safety risk, corrective measures taken, and quantity of products still circulating by Member State

Safety-affecting updates that address serious risks require immediate reporting to market surveillance authorities. The Market Surveillance Regulation (EU) 2019/1020 (MSR) governs these notification requirements.

The regulatory landscape includes multiple layers of oversight. Organizations like BEUC (the European Consumer Organisation) supplement government enforcement by investigating complaints, testing products, and pushing for recalls when manufacturers fail to meet safety obligations. This comprehensive approach ensures that consumer protection extends beyond formal regulatory channels.

Manufacturers who fail to meet safety standards face real consequences. The EU’s Safety Gate system publicly documents violations, creating a searchable record of companies whose products have been flagged as dangerous and removed from the market. This transparency mechanism serves as both a consumer protection tool and a powerful incentive for manufacturers to maintain rigorous safety standards throughout their product lifecycle.

Security updates typically do not require immediate notification of authorities unless they address vulnerabilities that could lead to physical safety risks. However, if security vulnerabilities could compromise product safety features or create conditions for accidents, they fall under the GPSR reporting requirements.

For products with responsible persons appointed under the GPSR, the responsible person must be informed of any safety issues. They then ensure that authorities are notified appropriately. If you are acting as an authorised representative, you handle direct communication with authorities regarding both security and safety matters affecting your represented products.

How do security and safety updates affect your product documentation?

Both update types require careful documentation management, but with different focus areas. The following requirements apply to each update type:

Safety-Affecting Updates Documentation Requirements

Immediate updates to technical documentation and risk assessments
Current safety information provided to consumers
Up-to-date records showing how modifications address identified risks
Demonstration of continued product safety
Documentation reflecting changes to product characteristics, composition, or safety features

Security Updates Documentation Requirements

Documentation of cybersecurity measures and protection against external influences
Records of how updates affect product behaviour or capabilities
Particular attention to products with evolving or learning functionalities

Technical documentation must reflect any changes to product characteristics, composition, or safety features resulting from updates. Under the GPSR, this documentation must be kept current and available for market surveillance authorities. The required level of documentation detail applies to each product model, not individual units, unless units have different safety-impacting features.

Internal Register Requirements

For both update types, you must maintain an internal register with the following specifications:

Requirement	Details
Content	Document accidents or safety issues
Data storage	Only personal data needed for investigation
Retention period	Maximum five years from entry, then mandatory deletion
Purpose	Balance safety investigation needs with privacy protection

User manuals and safety information must be updated to reflect any changes in product operation, new safety precautions, or modified usage instructions resulting from either security or safety updates. These updates help ensure that consumers can continue using products safely and understand any new risks or protective measures.

Understanding the distinction between security and safety-affecting updates helps you maintain GPSR compliance while protecting both digital systems and consumer safety. Proper documentation and timely reporting ensure that your products remain compliant throughout their lifecycle. At EARP, we help businesses navigate these complex requirements and maintain proper documentation for both security- and safety-related product updates.

If you are looking for support or to learn more, contact our team of experts today.