The Parsing section within the CSS Syntax 3 module defines that the prelude of at-rules and qualified rules contains a list of component values. And component values may contain a simple block.
That allows at-rules like @name {} {} and qualified rules like {} {}, causing ambiguities, as the {}-block might either belong to the component value of the current rule or be part of the next rule.
Therefore, an {}-block should not be allowed in the prelude of the rules.
Sebastian