Googled quite a lot and did not found explicit mention of it, except in 
embperl.
Perhaps because use utf8 is alike use encoding (i.e. not lexically scoped) ?
No more clue.
 

> It's not mentioned explicitly in the doc, but seems to be tacitly assumed 
> that 'use utf8' must be at the top of the code. Looks like "at the top" 
> also means "before use open..." that is frequently the case 
> http://goo.gl/3bABVr
>

 

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