GRI 417: Marketing and Labeling 2016 · Topic Standard · Cross-sectoral
Disclosure GRI 417-2
Incidents of non-compliance concerning product and service information and labeling
Practical guidance for preparing this disclosure. Use this card to identify datapoints, verify claims and organise supporting evidence. For exact requirements, always refer to the official GRI source.
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Reviewed by
Dr Ross Kurinko · GRI Certified Trainer
To prepare this disclosure
4 datapoints ↓
4 claims to verify ↓
5 evidence areas ↓
3 report examples ↓
Disclosure focus
This disclosure asks an organisation to report any confirmed cases where its product or service information, labelling, or related communications did not comply with the relevant rules or requirements. In practice, the focus is on actual incidents, not policies or intentions: what happened, where it happened, and whether it involved products, services, packaging, instructions, warnings, or other customer-facing information.
The practical emphasis is on coverage across the organisation, not just a few flagship sites or a single business unit. A complete response should consider incidents arising anywhere in the reporting boundary and explain the scope used to identify them, so readers can see whether the organisation has looked across all relevant operations, markets, and channels rather than only the most visible ones.
* This LRA educational guidance supports disclosure preparation. For the exact requirements, always refer to the official GRI source.
Before you start
A quick mental checklist before you prepare this disclosure — tick each as you settle it.
Preparation
Key datapoints to prepare
| Datapoint | What to capture | Evidence hint | Owner |
|---|---|---|---|
| Prior-period breaches | Capture any breach or non-compliance event that happened in an earlier reporting period but is relevant to the current report, if there is one. | Incident logs, compliance case files, legal correspondence, and prior-period close notes that show the event date and when it was first recorded. | Compliance |
| Non-compliance occurrence | Capture whether any non-compliance event occurred in the reporting period, and the basic facts needed to describe it. | Compliance register, incident tracker, investigation notes, and any internal or external notices tied to the event. | Compliance |
| Labeling breaches count | Capture the total count of non-compliance events linked to product or service information and labelling rules or codes during the reporting period. | Product compliance logs, quality assurance records, customer complaint files, regulatory notices, and issue trackers that can be counted once each. | Product compliance |
| No breaches statement | Capture a short statement confirming that no non-compliance with relevant rules or codes has been identified, where that is the case. | Signed compliance review, legal sign-off, and the final incident register showing no recorded cases for the period. | Compliance |
Show GRI 417-2 sub-elements (LRA working checklist)
- State briefly whether you have found no breaches of laws or voluntary commitments, where that applies.
- Record the number of compliance breaches identified.
- If relevant, separate out any breaches linked to events that happened before the reporting period.
- Give the total count of breaches tied to product and service information or labelling rules, including voluntary codes where relevant.
LRA working checklist - paraphrased; see official source
How to prepare
- Set the reporting boundary first: decide which business units, products, markets and time period you are covering, and make sure the same scope is used for every figure or statement you prepare for this disclosure.
- Agree what will count as a reportable issue before you start counting: use one clear internal rule for identifying a breach or other non-compliance linked to product or service information and labelling, so the team applies the same test throughout.
- Gather the source material that supports the disclosure: incident logs, compliance reviews, legal or regulatory correspondence, and any internal records that show whether a case was found, when it happened, and whether it sits in the current period or an earlier one.
- Compile the output in the form needed for the report: provide the total number of relevant incidents, and if there were none, prepare a short statement saying no such issue was identified. If any case relates to an earlier period, capture that separately in the narrative.
- Record any exclusions, restatements or scope changes clearly: explain what was left out, why it was left out, and whether the way you counted or classified incidents changed from the previous cycle, so readers can understand the basis of the number or statement.
- Check the draft against the source records before sign-off: confirm the count, the no-issue statement if used, and any note on earlier-period cases all match the underlying evidence and the official reporting source, with no gaps or double counting.
Request the incidents log and supporting evidence from Legal / Compliance / Product Labelling
Translate the disclosure into an internal business question — then adapt it to your organisation's own language.
During the reporting period, what labelling- or product-information breaches were identified, how many were there, and do any relate to earlier periods?
Use your organisation’s own terms first, then map them to the reporting disclosure. For example, ask for your breach, complaint, recall, claims review, or packaging sign-off records rather than using framework language in the first instance. Keep the request aligned to how the business actually tracks product and service information, labels, and related non-compliance.
Weak request
Please provide the non-compliance data for GRI 417-2, including the evidence needed for GRI 417:GRI 417-2.
Why it fails: This asks in framework language and does not tell the owner what records to pull, which systems to use, how to count incidents, or how to flag matters linked to earlier periods. It is also too abstract for a business team that tracks issues as complaints, breaches, claims, or packaging errors.
Better request
Please send the labelling, claims, packaging, and product-information issue log for [reporting period], including any regulator findings, customer complaints, or internal breaches recorded in the period. For each case, include the incident reference, date identified, date first occurred if known, internal category, short description, affected product or market, status, and links to the supporting files. Also flag any matter identified this year that relates to an earlier period, and confirm if no issues were found.
Formal email template
Subject: Request for product labelling and information issue records for [reporting period] Hi [name/team], We are preparing the sustainability reporting pack and need your help with the records you hold on product and service information, packaging, claims, and label-related issues for [reporting period]. Please send a short extract or summary covering: - any breaches, findings, or other non-compliance cases recorded in the period; - the total number of incidents recorded; - any matters first identified this year that relate to an earlier period; - confirmation if no issues were identified; and - supporting evidence or links to the underlying files. Please use your team’s own terminology in the response, then we will map it to the reporting disclosure. A possible LRA training template is attached below for reference only; please adapt this to your organisation and check the official source before sign-off. If helpful, you can return the information in the table format below. Many thanks, [preparer name] [role] [contact details]
Short Teams / Slack version
Hi [name/team] — could you share the product/packaging/claims issue log for [reporting period], plus any supporting files? We need: incidents recorded, total count, any older-period matters picked up this year, or a clear note if none were found. Please use your internal terms first; we’ll map them for reporting. A possible LRA training template is attached for reference only — please adapt this to your organisation and check the official source before sign-off. Thanks, [name]
Industry examples
Consumer goods / FMCG
Context. The business tracks packaging artwork approvals, on-pack claims, and customer complaints in separate systems.
Adapted request. Please pull the packaging claims review log, artwork approval exceptions, and complaint cases for [reporting period]. Include any label or claim issues, the total number of incidents, and any cases first identified this year that relate to an earlier period. Use your own issue categories and attach the supporting emails, sign-off notes, or regulator correspondence.
Example response. We found 3 incidents in total: 2 packaging claim errors and 1 allergen statement correction. One of the 3 was first identified in [reporting period] but related to artwork approved in the prior year. No other issues were identified.
Pharmaceuticals / life sciences
Context. The business manages pack copy, patient information leaflets, and market-specific artwork through quality and regulatory review.
Adapted request. Please provide the quality and regulatory deviation log for pack copy, leaflet, and label issues in [reporting period], including any findings from authorities or internal review. Return the incident count, whether any case relates to an earlier period, and the evidence file links for each item. Please use your internal deviation and change-control terms rather than reporting terminology.
Example response. We recorded 1 deviation involving a leaflet wording correction. It was identified and closed in the reporting period, and it did not relate to an earlier period. Supporting change-control records and approval emails are attached.
The full request pack — response form, data table, evidence metadata and sign-off — is in the Download Centre.
Draft your disclosure
LRA training templates — adapt them to your organisation, and check the official source before sign-off.
Method note
State how you defined a reportable case, what sources were used to count it, and whether you included matters first found now but linked to an earlier period.
Context note
Explain what the figures say about the quality of product and service information, and whether the organisation identified any cases at all in the period.
Fluctuation statement
If the count moved up or down, note whether that was driven by new findings, closure of older matters, a change in scope, or a genuine shift in performance.
Content index entry
GRI 417-2 Incidents of non-compliance concerning product and service information and labeling — [location / page] / [notes]
Download Centre
Professional preparation tools and forms for GRI 417-2. Each download includes a concise “How to use” guide.
Assurance readiness
For each claim, check the evidence
| Claim | Risk | Evidence to check |
|---|---|---|
| We checked whether any older-period issue needed to be brought into the coverage figure, and we only included it where our records showed it was relevant to the current reporting cut-off. | An assurer may test whether prior-period items were missed, double-counted, or brought in without a clear basis for inclusion. | Issue logs, case files, period-end review notes, reporting cut-off memo, and the working paper showing how older items were assessed and either included or excluded. |
| We built the disclosed count from the underlying incident register and then reconciled it to the source records before sign-off. | An assurer may probe whether the figure is complete, whether duplicates were removed, and whether the final number matches the source population. | Incident register, reconciliation worksheet, duplicate-check evidence, sign-off sheet, and any exception list explaining adjustments to the count. |
| We used the same internal tracking records that capture product and label-related breaches, and we reviewed each entry to confirm it belonged in the final total. | An assurer may question whether the population was defined consistently, whether all relevant cases were captured, and whether any unrelated matters were wrongly included. | Compliance tracker, case classification notes, supporting correspondence, review checklist, and evidence of management review of the final tally. |
| Where we stated that no issues were found, that statement was based on a documented search of the relevant records and a final management check before publication. | An assurer may test whether the no-issue statement is supported by a complete search, whether the search covered the right sources, and whether the conclusion was approved before release. | Search methodology note, source list reviewed, negative confirmation from responsible teams, management approval, and publication sign-off pack. |
Evidence pack to prepare
- The governing policy or written commitment behind this disclosure
- A methodology / definition note setting out how the disclosure was scoped and prepared
- Source-system exports the figures or facts were drawn from
- The internal approval / sign-off record for the disclosure before publication
- Minutes or records evidencing the relevant engagement or consultation
Common reporting gaps
- Figures are stated without the supporting narrative, or narrative without figures.
- Scope is inconsistent between the text and the numbers.
- The reporting boundary is left undefined.
- Material changes since the previous period are not disclosed.
- Estimates and measured values are not distinguished.
- Source records for the figures are not identified.
Mistakes to avoid when collecting the data
- Wrong owner
The team asks Legal or Compliance in framework language instead of the business unit that actually tracks label, pack copy, and product information issues.
- Scope left vague
People start collecting cases without first agreeing which products, brands, channels, and legal or code-based rules sit inside the count.
- Period basis mixed up
Old cases are pulled in or current-period cases are missed because the cut-off date and treatment of earlier events were not set before collection began.
- Counting rules not fixed
Some teams count each complaint, others count each separate breach, so the same issue is recorded on different bases across sources.
- Source labels lost
The original case tags, breach descriptions, or system codes are stripped out, making it impossible to trace each item back to the first record.
- Populations merged
Issues about product facts, packaging claims, and label wording are lumped together even though they were tracked separately in the source systems.
- Evidence details missing
The collector saves the incident list but not the date, owner, system extract, or other metadata needed to show where each figure came from.
- No sign-off trail
The final tally is shared without a named reviewer or approval record, so no one can show who checked the numbers before disclosure drafting.
Where judgement is often needed
- Set the reporting boundary after a buy-in or sale
Decide whether to include incidents from businesses added or removed during the year, and explain the cut-off you used so readers can see which operating units sit inside the count.
- Handle different local rulebooks consistently
Where countries use different labelling or product-information rules, use one clear counting approach across the group and disclose how local differences were normalised before the total was built.
- Treat near-boundary products and channels the same way each time
If an item is sold through a partner, marketplace, franchise, or other indirect route, state whether it is inside your scope and apply that rule consistently to avoid shifting the tally.
- Choose one timing basis for when an incident is counted
Explain whether you count when the issue is first found, when it is confirmed, or when the external authority closes it, and keep that timing basis stable from period to period.
- Separate older-period issues from current-period issues
If a case relates to a past reporting period, show whether it is included in the current count and describe the rule used for linking the incident to the year being reported.
- Decide how to count grouped or linked breaches
Where one investigation covers several products, labels, or markets, disclose whether you count each breach separately or as one case, and use the same method throughout the dataset.
- Use estimates only where the underlying record is incomplete
If the incident log is missing detail, explain any estimate or proxy used, why it was needed, and how you checked that the final number still reflects the evidence available.
- Round the total without obscuring the underlying count
State the rounding rule for the final number and make sure the disclosed figure can be traced back to the unrounded internal tally used for sign-off.
- Aggregate carefully when privacy limits the detail you can show
If naming a case, country, or business line would risk confidentiality, combine the data at a higher level and say how that aggregation affects the reader’s ability to interpret the total.
Examples
Illustrative examples
Synthetic, written by LRA — not from a company report, not text from any standard.
Consumer goods manufacturing · synthetic · written by LRA
This example shows how to describe the count of labelling-related breaches, distinguish current-year findings from older matters, and state the position when there are no additional non-compliance findings to disclose.
Synthetic example for training only. During the year, we recorded 2 matters where our product labelling and related information did not meet the relevant rules or our own voluntary commitments; both were identified in the reporting year and none carried over from earlier periods. This means our rate of non-compliance was 2 incidents in total, with 0 linked to prior years and 0 cases where we found no issue to report. - Of the two matters, 1 was closed with corrective relabelling before year-end and 1 remained under review at the reporting date.
Online retail and distribution · synthetic · written by LRA
This example shows a clean disclosure where the organisation states that no relevant breaches were found, confirms there were no prior-period matters to carry forward, and gives the total incident count as zero.
Synthetic example for training only. We identified 0 breaches in the year across our customer-facing product details and label content, so our total count of such incidents was 0. We also did not uncover any older cases from before the reporting period that needed to be carried forward, and we have no separate statement of non-compliance to add because none was found. - In short, our review of product and service information showed no incidents to report for the period.
Draft output & visualisation ideas
How to turn the collected data into a draft disclosure. Suggested visuals and a GRI content-index line generated from this disclosure's datapoints.
Suggested visuals
- Overall count of product-labelling compliance issues — table: A simple count of all recorded breaches or lapses linked to product or service information and labelling, including the total for the period.
- Issues by reporting period and earlier periods — stacked bar: A split between matters first identified in the current period and those that relate to earlier periods, if any are present.
- Trend in non-compliance incidents — line: How the number of recorded compliance incidents changes across reporting periods, where more than one period is available.
- Current-period incidents versus no-issue statement — donut: The balance between periods with recorded incidents and periods where no such issues were identified, if the reporter chooses to present the absence of findings.
- Compliance issues by location or business unit — map: Where the organisation can attribute incidents to countries, sites, brands or operating units, a geographic or organisational spread of the recorded cases.
From a number to a disclosure
What separates a figure from a disclosure.
Basic
I recorded 3 labelling-related breaches this year.
Better
I recorded 3 labelling-related breaches this year, all linked to our product information checks and counted on the basis of confirmed cases.
Best
I recorded 3 labelling-related breaches this year across our product information and labelling controls, all confirmed in the reporting period and none carried over from earlier periods; the number was unchanged from last year because our review found the same small set of issues in the same channels.
Real reports where this topic is disclosed. The confidence label shows how closely each match maps to GRI 417-2 — these are report practice, not exact disclosure examples.
| Company | Sector · Country | Year | Match | Page | Report | Assurance | ||||||||||||||||
|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|---|
 |
Zydus Lifesciences Limited | Pharmaceuticals / Biotech / Life Sciences · India | 2025 | Partial | p. 154 →p. 134 →p. 135 → | ESG Report FY24-25 → | — | |||||||||||||||
Evidence in Zydus Lifesciences Limited’s reportWhat the report shows Zydus Lifesciences Limited's ESG Report FY24-25 includes a numeric value indicating zero incidents of non-compliance concerning product and service information and labelling on page 135. The report also discusses materiality issues and their impact, as well as risk management aspects, on page 148. However, there is no clear or quotable narrative specifically addressing other aspects of the disclosure, and some relevant information appears to be missing or unclear.
Evidence-based summary of this company’s own report — not a disclosure template to copy, and not a compliance verdict. Datapoint coverage
Source trail
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Owens Corning | Building Products · United States | 2024 | Partial | p. 374 →p. 184 →p. 21 → | 2024 Sustainability Report → | EY | |||||||||||||||
Evidence in Owens Corning’s reportWhat the report shows Owens Corning’s 2024 Sustainability Report provides a 98% return-to-work rate for employees who took parental leave, by gender, indicating strong retention (p.300). The report also notes no material incidents of non-compliance with regulations or voluntary codes, including anti-corruption policies, with specific mention of zero incidents related to insider trading (p.184, p.36). However, while there is some context on employee health screening, no headline values or detailed data on occupational disease incidence are provided (p.76), and the extent of governance disclosures related to sustainability topics is not fully clear from the available evidence.
Evidence-based summary of this company’s own report — not a disclosure template to copy, and not a compliance verdict. Datapoint coverage
Source trail
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Thai Beverage Public Company Limited | Food and Beverage Processing · Thailand | 2024 | Partial | p. 187 →p. 186 →p. 93 → | Sustainability Report 2024 → | LRQA | |||||||||||||||
Evidence in Thai Beverage Public Company Limited’s reportWhat the report shows Thai Beverage Public Company Limited’s Sustainability Report 2024 includes coverage of incidents of child labor and forced or compulsory labor, referencing GRI 409-1 on page 189 and related policy statements. The report also provides data on non-compliance with health and safety regulations concerning products and services on page 93, and details on occupational health and safety management system coverage on page 178. However, some narrative items relevant to the disclosure are not found or unclear elsewhere in the report, and certain sections such as supply chain management and corporate governance are referenced but without explicit detail on this disclosure beyond page citations (p.189-190).
Evidence-based summary of this company’s own report — not a disclosure template to copy, and not a compliance verdict. Datapoint coverage
Source trail
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Check your understanding
A customer complaint from last year is still being investigated when you close the current reporting year. The issue concerns a product label that may have overstated a feature, but no final finding has been reached yet.Should this matter be counted in the current year’s incident total, or handled separately because it started earlier?
Model answer. Treat it as a current-year incident only if the organisation has identified a non-compliance event in the reporting year. If the matter relates to an earlier period, note it separately as an incident tied to a prior period when that is applicable, rather than folding it into the current-year count without basis.
Why this matters. Separate the timing of the event from the reporting year, and distinguish current-period incidents from matters linked to earlier periods.
During the year, the business records two breaches of labelling rules and one breach of a voluntary product-information code. Each case is closed and supported by internal case files and regulator correspondence.What should be reported for the incident count, and what evidence should the preparer be ready to show?
Model answer. Report the full number of identified incidents across both legal rules and voluntary codes, so the total here is three. Keep evidence that shows each case was identified and how it was classified, such as investigation notes, correspondence, or other records that support the count.
Why this matters. Count every identified breach in scope, whether it comes from law or a voluntary code, and back the number with traceable records.
The compliance team reviews all product and service information issues for the year and finds no confirmed breaches. There were a few customer queries about unclear packaging, but none became a substantiated non-compliance case.What wording should the disclosure use when no non-compliance has been identified?
Model answer. Use a short statement saying the organisation has not identified any non-compliance in the area covered by the disclosure. Do not describe the customer queries as incidents if they were not confirmed as breaches.
Why this matters. If no breach has been identified, say so plainly and avoid inflating concerns into incidents.
A retailer discovers that a supplier’s leaflet used last year contained a misleading claim, and the leaflet remained in circulation into the current year. The issue was first identified now, but the underlying error began before the reporting period.How should the preparer decide whether this belongs in the current incident count and whether it also needs a prior-period note?
Model answer. First decide whether the organisation has identified a non-compliance incident at all; if it has, include it in the incident count for the year in which it is identified. If the facts show the event itself belongs to an earlier period, add a separate note that it relates to a prior period, where that is relevant.
Why this matters. Use the year of identification for the count, then add a prior-period note only when the facts show the event started earlier.
Analyse this disclosure across real reports
See how companies actually report GRI 417-2 — drawn from their own published reports, with the exact pages, and an LRA AI-assistant that works through it with you. Available to LRA Community members and to students throughout their platform access.
Related framework references
How this disclosure maps across the major reporting frameworks.
→
ESRSRelated
ESRS S4
Consumers and End-users — closest topical match (post-Omnibus ESRS catalogue).
→
IFRSNo equivalent
—
No direct IFRS S1/S2 topical equivalent.
Related & explore
Questions this page answers
How do I prepare a GRI 417-2 Marketing and Labelling disclosure using this page in practice?
Start with the plain-language explainer, then work through the step-by-step preparation section and the listed datapoints: prior-period breaches, whether any non-compliance occurred, the count of labelling breaches, or a no-breaches statement. The page also gives draft-output prompts and a content-index line to help turn the data into a first draft. ↑ section
What data do I need to collect for GRI 417-2 Marketing and Labelling?
The page says to prepare four datapoints: prior-period breaches, whether non-compliance occurred, the count of labelling breaches, and a statement if there were no breaches. It also points you to an evidence pack and assurance claims so you can collect support at the same time. ↑ section
How should I decide the scope for the GRI 417-2 Marketing and Labelling data?
Use the page’s step-by-step preparation section to define what you are counting and what period you are covering, then align that with the datapoints listed on the page. The page does not add extra scope rules, so the practical approach is to keep the scope consistent with the evidence you can assemble. ↑ section
Who should own the GRI 417-2 Marketing and Labelling disclosure in my organisation?
The page is written for sustainability/ESG managers, HR or data owners, and assurance reviewers, so ownership should sit with the person who can coordinate the data, evidence, and sign-off. The workbook and evidence-pack sections are there to help that owner track tasks and responsibilities. ↑ section
What evidence pack do I need to make GRI 417-2 Marketing and Labelling assurance-ready?
The page includes an evidence pack with five items for assurance readiness, plus four assurance claims to verify. Use those together so you can show the claim, the risk, and the supporting evidence in one place. ↑ section
What are the common mistakes when drafting a GRI 417-2 Marketing and Labelling disclosure?
The page lists common reporting gaps and mistakes, so it is useful as a pre-submission check before you draft. In practice, use it to spot missing datapoints, weak evidence, or a mismatch between the narrative and the underlying records. ↑ section
How do I use the Prep & Assurance workbook for GRI 417-2 Marketing and Labelling?
The Download Centre includes a Prep & Assurance workbook in .xlsx format, which is meant to support preparation and assurance readiness. Use it to organise the datapoints, evidence, and draft output before you finalise the disclosure. ↑ section
What can I do with the synthetic example disclosure for GRI 417-2 Marketing and Labelling?
The page includes synthetic illustrative example disclosures, including a quantitative table, so you can see how the information might be presented in a draft. Treat it as a formatting and structure aid only, and keep any real figures internally consistent. ↑ section
How do I turn the GRI 417-2 Marketing and Labelling data into a draft disclosure?
Use the draft-output section, which gives visualisation ideas, narrative starters, and a GRI content-index line. That lets you move from collected data to a first draft without having to build the wording from scratch. ↑ section
Can I reuse my GRI 417-2 Marketing and Labelling data for ESRS S4 (Consumers and End-users)?
The page says ESRS S4 (Consumers and End-users) is the closest correspondence, so the same underlying data may be reusable across both. The page does not say the requirements are identical, so you would still need to check the other framework separately. ↑ section
What is the printable Library Card in the GRI 417-2 Marketing and Labelling Download Centre for?
The Download Centre includes a printable Library Card in PDF format alongside the workbook. It is there as a practical companion to the page content, so you can keep the key points to hand while preparing the disclosure. ↑ section
More questions this page can help with
- GRI 417-2 Marketing and Labelling checklist for sustainability reporting teams
- GRI 417-2 Marketing and Labelling evidence pack items for assurance
- GRI 417-2 Marketing and Labelling workbook download xlsx
- GRI 417-2 Marketing and Labelling example disclosure table
- GRI 417-2 Marketing and Labelling common reporting mistakes
- GRI 417-2 Marketing and Labelling prior-period breaches data point
- GRI 417-2 Marketing and Labelling no breaches statement wording help
- GRI 417-2 Marketing and Labelling draft narrative starters
- GRI 417-2 Marketing and Labelling content index line example
- GRI 417-2 Marketing and Labelling ownership and evidence pack
- GRI 417-2 Marketing and Labelling ESRS S4 data reuse
- GRI 417-2 Marketing and Labelling assurance claims to verify
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Sources, status and disclaimer
This LRA assistance tool is designed for educational and internal data-collection purposes. It is not an official interpretation of the GRI Standards, IFRS Sustainability Disclosure Standards or EU CSRD/ESRS requirements. When applying these frameworks in professional practice, users should consult and double-check the official standards, guidance and applicable regulatory sources.
