It allows non-ASCII text but does not provide any way to indicate charset within the file, instead requiring it out-of-band. Once the file is saved, the text encoding becomes ambiguous. Likewise for the presence or absence of a header row.

Likewise for whether double quotes (`"`) are allowed in fields (rule 5). This one gets even worse, since the following rule (6) uses double quotes to escape line breaks and commas, but they may not be allowed at all so commas in fields may not be escapable.

It only supports text, not numbers, dates, or any other data, and provides no way to indicate any data type other than text.