I'm not sure where you get 3C from on 3x16340. The emitter (3.5V worst case) gets 4A, which is 14W. If the buck circuit wastes 15% of the power fed to it, then we need 14*1.15 = 16.1W of input power. 3 RCRs means each one needs to deliver ~5.37W. At 4.2V, that would put the current at 1.28A, which is below 2C. Even at 3.6V, the current would be ~1.5A, which is the safe max. Of course, if you do let it drop further, you're in trouble, as at 2.5V, the draw is over 2.1A. So, as long as the user is careful, 3xRCR should work ok, but unprotected batteries will fall into a death spiral as their voltage drops off (unless the light falls out of regulation at 10.8V, thus becoming an unregulated light on 18650s).
The real problem is primaries. 3x CR123As starts with a draw of ~1.8A for each battery, well over the "safe" threshold, and (if the regulation circuit keeps regulating) pushes the current to ~2.7A at 2.0V. At that current, unless I'm mistaken, you're one partially discharged CR123A* away from holding an aluminum-bodied road flare. I'm surprised that Jetbeam is willing to accept that kind of liability...
* If accidentally mixed with 2 fresh ones