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I suspect this is a case of the prose of the Guidelines not keeping
up with the definition of and common use of the element. We certainly
use <label> in places other than as list labels. See, e.g., 
http://www.wwp.brown.edu/research/publications/documentation/encoding/html/225HeadsAndLabels.html


> I am puzzled by a discrepancy between the content model for the
> label element and its definition and discussion in the Guidelines.
> 
> The definition restricts the use of 'label' quite narrowly to a
> list ('contains the label associated with an item in a list') and
> refers the reader to section 3.7 Lists.
> 
> The content model, however, is much more relaxed. While you can't
> put much into a label, you can validly stick a label just about
> anywhere and use it more or less like an html heading. You can use
> it to label paragraphs, you can also use it as an informal way of
> grouping parts of a div without formally tesselating it into
> sub-divs.
> 
> Are these loose, but valid uses of 'label' proper? If so, the
> Guidelines should say something about it. I have certainly seen
> cases where they come in handy