Serhiy Storchaka added the comment:

This note looks outdated.

In 2.x 8-bit file names are written as is, implying cp437 or what your 
consumers expect. Unicode file names are encoded to ascii or utf-8 (with 
setting utf-8 flag). In 3.x only Unicode file names are accepted, and they 
always are encoded to ascii or utf-8. There is no way to write non-ascii 
non-utf-8 file names. cp437 is not used at all.

Maybe just remove this misleading note?

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Python tracker <rep...@bugs.python.org>
<http://bugs.python.org/issue27344>
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