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GRI 417: Marketing and Labeling · 2016
Disclosure GRI 417-1

Requirements for 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.

Dr Ross Kurinko, GRI Certified Trainer
Reviewed by Dr Ross Kurinko · GRI Certified Trainer LRA educational guidance · Not issued or endorsed by GRI
To prepare this disclosure
Disclosure focus

This disclosure asks an organisation to explain how it labels and presents information about its products and services, so that customers can understand what they are buying and how to use it safely and appropriately. The focus is on whether the organisation provides the right information in a way that is clear, accessible and relevant to the product or service, rather than only describing a policy in general terms.

In practice, the reporting should cover the organisation’s real-world approach across the business, not just a few well-managed or flagship examples. A useful response shows where product and service information and labelling are applied, how consistently they are used, and whether there are any important gaps, exceptions or differences between operations, markets or product lines.

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
Source details Whether the organisation’s product or service information and labelling process asks for where key components come from. Product labelling rules, packaging copy controls, sourcing specifications, supplier declarations, product information sheets. Product, procurement, compliance
Substance content Whether the organisation’s product or service information and labelling process asks for content details, especially substances that could affect people or the environment. Ingredient or material specifications, safety data sheets, restricted-substance lists, product declarations, label approval files. Product stewardship, compliance, technical, procurement
Safe use guidance Whether the organisation’s product or service information and labelling process asks for instructions needed to use the product or service safely. User instructions, safety notices, training material, packaging artwork, customer guidance documents, approval records. Product, quality, health and safety, compliance
Disposal guidance Whether the organisation’s product or service information and labelling process asks for disposal instructions and any related environmental or social effects. End-of-life instructions, recycling or take-back guidance, disposal statements, product stewardship notes, label approvals. Product stewardship, sustainability, compliance, operations
Other required details Whether the organisation’s product or service information and labelling process requires any additional information beyond sourcing, content, safe use, and disposal. Policy or procedure text, label standards, product information templates, legal or regulatory checklists, approval workflows. Compliance, legal, product stewardship
Other details explained A short explanation of any extra information the organisation’s product or service information and labelling process requires. Procedure notes, label guidance, product information standards, exception logs, approval comments. Compliance, legal, product stewardship
Coverage rate The share of major product or service groups that are both covered by the organisation’s information and labelling procedures and checked against them. Product category inventory, compliance testing log, procedure coverage matrix, audit results, product master list. Compliance, product stewardship, quality
+ Show GRI 417-1 sub-elements (LRA working checklist)

How to prepare it

1Set the reporting boundary first. Decide which product or service lines are in scope, then identify the significant categories that will be used for the coverage calculation.
2Translate the internal rules into plain categories. Separate the required information types you need to test: where components come from, what the item contains, how it should be used safely, how it should be disposed of, and any other information your procedures call for.
3Gather proof for each in-scope category. Use the underlying procedures, labels, specifications, product sheets, and other internal records that show whether the required information is expected and whether it is actually provided.
4Check compliance category by category. For each significant product or service group, confirm whether the required information is covered and assessed against the relevant procedures, then calculate the percentage covered.
5Write up any extra information separately. If your procedures require additional product or service information beyond the main categories, describe it clearly and keep the explanation aligned to the evidence you have.
6Record exceptions and changes, then verify against the source. Note any exclusions, scope changes, or assumptions used in the calculation, and do a final check that your wording and figures match the official source before submission.
Request the data

Request the product and label evidence from Product / Packaging / Regulatory Labelling

Translate the disclosure into an internal business question — then adapt it to your organisation's own language.

Which product or service lines have our label and customer information checks covered, and what evidence shows the relevant information is included where our procedures expect it?

Use your organisation’s own names first for products, packs, labels, inserts, web pages, manuals, and customer notices, then map them to the reporting categories. Keep the ask in business terms your team already uses, and check the source material before sign-off.

Weak request

Can you send the GRI 417-1 evidence showing product and service information and labelling compliance for all significant categories?

Why it fails: It uses framework language, does not tell the owner what internal records to pull, and leaves unclear which systems, category names, and coverage method should be used. It also does not separate the yes/no checks from the coverage calculation or ask for the supporting files needed to verify the answer.

Better request

Please send the current label and customer-information review pack for [reporting period] for [business boundary]. I need the category list, the procedure used, the review results for each category, the supporting artwork/copy or screenshots, any extra information your team includes, and the working for the coverage percentage. Use your team’s own names for products, packs, inserts, web pages, and notices, then map them to the reporting categories. Please adapt this to your organisation and check the source material before sign-off.

Formal email template
Subject: Request for product and label evidence for [reporting period]

Hi [name/team],

I’m pulling together the sustainability reporting pack and need your help with the product and customer information evidence for [reporting period].

Please send, for [business boundary / product lines]:
- the list of product or service categories in scope;
- the current procedure or control used to review customer-facing information;
- evidence showing whether the following topics are included where expected: sourcing details, content/substance information, safe-use guidance, disposal guidance, and any other information your team treats as part of the check;
- a short note explaining any additional information you include and why;
- the percentage of significant categories covered by the review, with the working behind it.

Please use your own internal names for the items and attach the supporting files or links. A possible LRA training template is attached for reference only; adapt this to your organisation and check the source material before sign-off.

Thanks,
[preparer name]
Short Teams / Slack version
Hi [name/team] — could you share the product/label evidence for [reporting period]?

Please send the in-scope product/service list, the current review procedure, proof of what customer info is included (sourcing, content/substances, safe use, disposal, and any other team-specific items), plus the coverage % and working. Use your own internal names. Please adapt this to your organisation and check the source material before sign-off. Thanks.
Industry examples
Consumer goods / FMCG

Context. A packaging team manages carton copy, pouch labels, and website product pages for a household cleaner range.

Adapted request. Please share the label and product-page review pack for [reporting period] for the cleaner range. Include the range list, the current artwork approval process, evidence for sourcing details, ingredient/substance information, safe-use instructions, disposal guidance, any extra pack copy your team uses, and the coverage % with working. Use your own range names and file links.

Example response. Returned table shows 12 ranges in scope; 10 marked checked against the current procedure; 2 pending redesign. Supporting files include approved artwork PDFs, web screenshots, and the coverage calculation showing 10/12 = 83.3%.

Software / digital services

Context. A subscription service team issues customer onboarding emails, help-centre articles, and account notices rather than physical labels.

Adapted request. Please send the customer-information review pack for [reporting period] for the subscription service. Include the service categories in scope, the content review process, evidence for any sourcing-related statements, feature or component information, safe-use guidance, account closure or data disposal guidance, any other customer information your team includes, and the coverage % with working. Use your own names for emails, help articles, and notices.

Example response. Returned table lists 5 service categories; 4 have current review evidence and 1 is excluded with a note. Supporting files include email templates, help-centre screenshots, and the calculation showing 4/5 = 80.0%.

Draft your disclosure

Notes that turn data into a disclosure

LRA training templates — adapt them to your organisation, and check the official source before sign-off.

Method note

State how you defined the product or service categories in scope, what counted as a procedure-based information requirement, and how you determined whether each category had been assessed for compliance.

Context note

Explain that the figures show how far the organisation’s product and service communication rules extend across significant categories, and which kinds of consumer-facing information those rules require.

Fluctuation statement

If the coverage percentage changed, note whether this was due to more categories being brought into scope, a revised assessment approach, or changes in the underlying procedures that set the information requirements.

Content index entry
GRI 417-1 Requirements for product and service information and labeling — [location / page] / [notes]
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Preparation tools & forms

Professional preparation tools for GRI 417-1 — free with an LRA Community membership. Register once (it's free) and every download unlocks, together with the Disclosure Library, templates and the LRA AI-assistant.

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Assurance readiness

For each claim, check the evidence

ClaimRiskEvidence to check
I checked whether our product or service information rules require us to include where key components come from.The assurer may ask whether the coverage figure is based on a complete and current reading of the internal labelling and information rules, rather than a selective interpretation.Documented policy or procedure setting out the information required for product or service labels and customer information; version control showing the rule in force for the reporting period; internal review notes linking the rule to the disclosed figure.
I confirmed whether our internal information rules ask us to disclose what the product or service contains, especially where a substance could have an environmental or social effect.The assurer may probe whether the reporter has correctly identified the relevant content-related requirement and whether any exclusions were made without support.Relevant product information standard, labelling guidance, or technical specification; material composition records; sign-off notes showing how substances with possible environmental or social effects were considered.
I verified whether our procedures call for safety-use information to be included in the disclosed material.The assurer may challenge whether the safety-related content was identified from the governing procedure and whether the disclosed coverage is complete for the period and population reported.Safety instructions, user guidance, or product information procedure; evidence of the products or services reviewed; internal checklist showing the safety-use element was tested before publication.
I checked whether our procedures require us to explain how the item should be disposed of, including any related environmental or social effects.The assurer may ask whether disposal-related information was captured consistently and whether the reporter has evidence for any judgement about associated impacts.Disposal guidance, end-of-life instructions, or product stewardship procedure; records showing which products or services were reviewed; working papers showing how disposal and impact information was assessed.
I identified any further information our procedures require us to provide and documented what that extra material was.The assurer may probe whether all non-standard information required by the internal rules was captured, or whether additional items were omitted from the disclosure.Procedure or checklist listing any extra information fields; internal mapping of required items to the published content; evidence pack showing the additional items included in the report.
I prepared a short explanation of the extra information required by our procedures and kept the basis for that explanation on file.The assurer may ask whether the explanation is supported by the underlying procedure and whether it accurately describes the additional information without overstatement.Draft narrative and final approved wording; source procedure or control document; review comments showing the explanation was checked against the underlying requirement.

Evidence pack to prepare

Common reporting gaps

A percentage is stated without the underlying counts (numerator and denominator).The denominator — what the figure is a share of — is not explained.Partial scope is reported as if it were complete coverage.One-off activities are counted as if they were ongoing programmes.Boundary or period changes that move the figure are not flagged.Exclusions from the reported scope are not listed or explained.
Common gaps

Mistakes to avoid when collecting the data

Wrong owner
Chasing the sustainability team alone misses the people who actually control product labels, packaging copy, safety notes, and disposal instructions.
Framework language only
Asking for answers in reporting jargon instead of the business's own product terms leaves operations teams unsure which labels, notices, or instructions to pull.
Scope left vague
Collecting data without fixing which product or service lines are in scope leads to inconsistent inclusion and gaps in the final population.
Wrong time basis
Using a different reporting period from the one used by the source records creates mismatches between what was counted and what the evidence shows.
Mixed counting method
Combining item counts, category counts, and percentage coverage in one extract makes the figures impossible to reconcile back to the source files.
Source labels lost
Copying information into a summary sheet without keeping the original label text or version means the team cannot prove what customers actually saw.
Separate groups merged
Putting products with different label rules into one bucket hides which lines were checked for sourcing, content, safe use, disposal, or other notices.
Evidence details missing
Saving the answer without the underlying file name, date, owner, and version leaves no audit trail for later review.
No sign-off trail
Recording the data before the responsible business lead has reviewed it creates a gap between the source records and the final submission pack.

Where judgement is often needed

What counts as a covered product line after a buy-in or sale
Set the reporting boundary using the same group of products and services you used for the rest of the period, and if a purchase or disposal changes that group, explain the cut-off date and whether the percentage covers only the time the line was in scope.
When local labelling rules differ from country to country
Use the rules that apply in each market for the same product family, then explain any country-by-country differences in what information is shown, so readers can see why coverage is not uniform.
Whether a borderline item is a product, a service, or both
Decide the classification on the basis of how the item is sold and used in practice, and disclose the rule you applied where mixed offers or bundled packages sit close to the edge of your scope.
How to treat products sold through third parties or marketplaces
Include items only where your procedures actually control the information or label content, and explain any exclusions where the product reaches customers through channels you do not manage directly.
What to do with safety, content, or disposal information that is estimated rather than measured
If you rely on modelled, sampled, or otherwise estimated data, say so and describe the method, the main assumptions, and any material limits on precision.
How to handle rounding in the coverage percentage
Round the percentage consistently across the report, keep the underlying calculation available, and make sure the rounded figure does not overstate the share of significant categories covered and checked.
Whether personal or commercially sensitive details can be aggregated
Group the information at a level that protects privacy and confidential business data, but still lets a reader understand what kinds of sourcing, content, use, disposal, or other label information are included.
How to define the set of significant product or service categories
Use a clear internal rule for deciding which categories are material enough to count in the denominator, and explain that rule if it changes from one year to the next or differs across business units.
When a product has multiple label versions in the same year
Choose a consistent basis for counting coverage where label content changes during the period, and explain whether you used the first version, the latest version, or a weighted approach across the year.
Examples

Illustrative examples

Synthetic, written by LRA — not from a company report, not text from any standard.

Illustrative (synthetic) example — Consumer electronics

*Synthetic example only.* We assess our product information and labelling controls across our main device lines and found that all significant categories were checked for compliance, giving full coverage of the range reviewed. - Our procedures require us to state where key parts come from, to flag material contents that could affect the environment or people, and to give instructions for safe use and end-of-life handling. - They also call for one additional item: battery recycling guidance for portable products, which we explain in our user leaflets and on-pack QR pages.

This example shows a company describing the topics its labelling process must cover, plus the share of significant categories reviewed. The percentage is synthetic and internally consistent: 12 of 12 categories assessed, so 100%.

Illustrative (synthetic) example — Household cleaning products

*Synthetic example only.* Our checks covered most of the significant ranges in our portfolio, and the review confirmed that the relevant labelling rules were applied to 8 of the 10 categories we treat as significant. - The procedures ask for origin details for key ingredients, disclosure of contents that may create environmental or social harm, guidance on safe handling, and disposal instructions with any related impacts. - In addition, we require allergen advice and first-aid contact details on selected packs, which we explain in our product sheets and online labels.

This example illustrates a different reporter with a different mix of required label content and a partial coverage result. The percentage is synthetic and internally consistent: 8 of 10 categories assessed, so 80%.

Company reports

How companies report GRI 417-1

Real reports where this topic is disclosed. These are report practice, not exact disclosure templates to copy.

Companhia Paranaense de Energia - COPEL
Electric Utilities / IPP / Energy Traders · Brazil · 2024
Open report →
Companhia Paranaense de Energia - COPEL’s Integrated Report 2024 covers several relevant aspects of the disclosure, including the proportion of spending on local suppliers as per GRI 204-1 on page 309 and management of social and environmental impacts referencing GRI 203 and 413 standards on page 208. The report also states that 100% of significant product and service categories meet labeling requirements on page 327. However, there is no quotable evidence found for narrative item (a-iii) or other unspecified narrative items, indicating some gaps in coverage.
Thai Beverage Public Company Limited
Food and Beverage Processing · Thailand · 2024
Open report →
Thai Beverage Public Company Limited’s Sustainability Report 2024 provides coverage of several narrative items related to its sustainability reporting, including reporting period, frequency, and contact points (p.182), as well as environmental assessment criteria for new suppliers (p.189). The report also includes some social data and references to management of material topics and anti-corruption measures (pp.180, 189-190). However, there is no clear evidence found for certain narrative items such as item (a-iii) or percentage values related to the disclosure, indicating gaps in the completeness of the reported information.
Fubon Financial Holding Co., Ltd.
Banks / Diverse Financials / Insurance · Taiwan · 2024
Open report →
Fubon Financial Holding Co., Ltd.’s 2024 ESG Report includes coverage of requirements for product and service information and labeling, as noted on page 104, and discusses protecting shareholder rights and environmental impacts on page 16. The report also references environmental responsibility initiatives and the incorporation of environmental, social, and governance factors in investment management on pages 106 and 107. However, there is no evidence found regarding specific narrative item (a-iii) or percentage values related to the disclosure.
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Check your understanding

Scenarios to work through

A business sells three product families: two are fully covered by its labelling procedure, while the third is a new line with no written checks yet. The reporting team is deciding whether to count that third line in the coverage figure.

QShould the percentage include only the product families that are both covered by the procedure and checked against it, or can the new line be counted before those checks exist?
Reveal model answer →

A consumer goods team has labels that mention origin, ingredients, safe handling, and end-of-life disposal. The sustainability lead is unsure whether the reporting note should stop at those topics or also mention a separate allergen warning that is used on some packs.

QWhen listing the kinds of information covered by the labelling process, should the team include only the four core topics or also any other information the organisation’s own procedure calls for?
Reveal model answer →

A service provider has a procedure that covers how customers are told to use the service safely, but the team has not yet checked whether every service category follows that procedure. They are preparing the year-end disclosure and want to know whether the safe-use topic alone is enough.

QCan the team report the safe-use topic as covered without also confirming which significant service categories were reviewed for alignment with the procedure?
Reveal model answer →

A manufacturer has labels that explain sourcing, ingredients, safe use, and disposal. One product group has a short note on disposal, but the team is unsure whether that note is enough because the procedure also asks for environmental and social effects linked to disposal.

QIf the disposal guidance is present but does not mention the wider impacts the procedure expects, should the team treat that product group as fully covered?
Reveal model answer →
Framework references

Related framework references

How this disclosure maps across the major reporting frameworks.

GRI
GRI 417-1
within GRI 417: Marketing and Labeling
Open official source →
Primary
Related & explore
FAQ

Questions this page answers

For GRI 417-1, what data do I need to gather before I start drafting the disclosure?+
How do I use the step-by-step 'how to prepare' section for GRI 417-1 in practice?+
Who should own the GRI 417-1 data collection and sign-off in my organisation?+
What evidence should I keep in the pack for GRI 417-1 assurance readiness?+
What are the six assurance claims I need to check for GRI 417-1?+
What are the common reporting gaps or mistakes for GRI 417-1 that I should avoid?+
How do I turn the GRI 417-1 data into a draft disclosure?+
What should I use from the GRI 417-1 workbook download to prepare the disclosure?+
Can I use the 'From company reports' table to find examples of how other companies disclose GRI 417-1?+
How does the ESRS S4 correspondence help me with GRI 417-1, and can I reuse the data?+
More questions this page can help with