Section 2.1.1 says:

   As stated in [RFC5216], the TLS cipher suite shall not be used to
   protect application data.  This applies also for early application
   data.  When EAP-TLS is used with TLS 1.3, early application data
   SHALL NOT be used.

  I can't find any such statement in RFC 5216.  So where does this requirement 
come from?

  In contrast, RFC 8446 Section 2 says:

   ... Once the handshake is
   complete, the peers use the established keys to protect the
   application-layer traffic.

  Which makes sense.

  My question here is whether the draft needs to be updated to clearer.  Either 
that, or the text in the draft would seem to forbid other TLS-based EAP methods 
from sending application data...

  Perhaps the draft means that the application data should not be protected 
using the same traffic keys that protect the handshake, as defined in [RFC8446] 
Section 7.3

  Alan DeKok.

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