Something is unclear in "Solaris containers" and "Solaris ZFS" docs

Two extracts :

"Consider the following interactions when working with ZFS on a system with 
Solaris zones installed:

A ZFS file system that is added to a non-global zone must have its mountpoint 
property set to legacy.

A ZFS file system cannot serve as zone root because of issues with the Solaris 
upgrade process. Do not include any system-related software that is accessed by 
the patch or upgrade process in a ZFS file system that is delegated to a 
non-global zone."
"4. Set the zone path, /export/home/my-zone in this procedure.
               zonecfg:my-zone> set zonepath=/export/home/my-zone
Do not place the zonepath on ZFS for this release."

I can't understand why the upgrade process need to have non-global root zone on 
anything else than zfs.      Does the boot cdrom can't mount ZFS volumes ?
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