I'm not sure about the particular guidelines for your shop, but, for shops I've done, I've checked for cleanliness, available restroom materials and working facilities.
I've marked off for missing TP, a broken toilet seat, graffiti, and obvious signs of neglect (cleanliness). I've been in restrooms that were so tiny that you had to sit sideways on the commode. I never mentioned that and didn't see it being relevant other than being uncomfortable. For some shops I've done they ask for a rating and then your comments on the rating. It was there where I just said the restroom was very small and difficult for the customer to maneuver.
For the issue you describe, in the comment section, you could mention that the holder is difficult to reach (or something like that). But, i wouldn't mark them off for it.