Should this be a &lt;textarea&gt; element rather than a  &lt;div&gt;? It looks like the element probably gets enhanced by an editor plugin's UI, but without the enhancement, a backup &lt;textarea&gt; element would ensure users can input data/copy. 

If you're keeping it a &lt;div&gt;, I'm not sure you need a &lt;label&gt; as its not semantically correct to provide labels for non-form HTML elements. It may also provide no value or even confuse users with assistive DOM-reading tech (we'd have to proof that).