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This uses a lot of codepoints #11
If you subscribe to the theory that DTLS has to mux with the realtime protocols, this takes a good slice of the remaining codepoints space. Though TLS has between 20 and 63, DTLS 1.3 takes 32-63 and the registration of 4 more would leave just 3: 29, 30, and 31.
I submit that we might be better considering the TLS 1.3 record construction with a single codepoint. That would get us content type encryption and arbitrary padding as a secondary benefit. All for the modest cost of one octet.