> RFC 4180 doesn’t guarantee that a new line is a new record
Correctly. A good parser should step through the line one column at a time, and shouldn't even consider newlines that are quoted.
If you're naively splitting the entire file via newline, that isn't 4180's fault, that is your fault for not following the standard or industry norms.
I'll happily concede the UNICODE point however; but I don't know if that makes it controversial.