For group headers, yes, one reasonable design would be the same as
standalone labels but bold.

However, a different reasonable design would be using small caps and a
different color.

Whatever the design is, the theme designer should be able to change the
style of all group headers at once, without affecting standalone labels.
This suggests to me that it should be a separate element.

If this was HTML, an intro label would be <p>...</p>, while a group
header would be <h2>...</h2>. People sometimes use <p><b>...</b></p> for
headings, but that's a bad idea because it's hard to restyle them later.

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https://bugs.launchpad.net/bugs/1242666

Title:
  Standalone labels as an element distinct from group headers

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