The Li-Ion rechargables are a huge liability for them.
IF they even passively allow the user to use R123s, there have been enough CPFers who brag how they "modded" their L4/L2s by using 2 R123s. Down the road SF will get a prematurely dim L4 and go, "hmm, someone used more than 6 volts in here".(ever wonder why the older L4s and L2s could house R123s, but the new ones can't?)
The other issue is that lack of standard in safety among the Li-Ion makers, who are all in the Far East with little over sight beyond the need to keep exploding cells to a minimum to avoid market backlash. Who makes those nice little blue 17670s? are they protected? or do they just day protected? what protection circuit is used? remember for most SF users they are not CPF addicts and do not want to deal with no-name batteries that can be a small stick of dynamite.
Officially, all manufacturers discourage using rechargables. Streamlight keeps telling their customers that their ProPolymer Lux should only be used with primary Alkalines.
Senerio:
SOme moron with a E2L. the guy puts in two R123s that are unprotected. The light is not locked out, and sits in a hot, enclosed car under the sun. The light shifts and turns on. Upon depletion the cells vented and explode, injuring the passenger sitting there,
next morning in San Francisco Chronicle:
"Fountain Valley Gun Light maker's product explodes, injures preganant woman."
guess who the press and lawyers will go after. You connect the dots.