Code change:
Key updates MUST be initiated before usage limits on packet protection keys are exceeded.  For the cipher suites mentioned in <del> this document, the limits in Section 5.5 of TLS13 apply.  Other cipher suites MUST define usage limits in order to be used with QUIC. </del> <ins> this document, the limits in Section 5.5 of TLS13 apply.  TLS13 does not specify a limit for AEAD_AES_128_CCM, but the analysis in ccm- bounds shows that a limit of 2^23 packets can be used to obtain the same confidentiality protection as the limits specified in TLS. The usage limits defined in TLS 1.3 exist for protection against attacks on confidentiality and apply to successful applications of AEAD protection.  The integrity protections in authenticated encryption also depend on limiting the number of attempts to forge packets.  TLS achieves this by closing connections after any record fails an authentication check.  In comparison, QUIC ignores any packet that cannot be authenticated, allowing multiple forgery attempts. Endpoints MUST count the number of received packets that fail authentication for each set of keys.  If the number of packets that fail authentication with the same key exceeds a limit that is specific to the AEAD in use, the endpoint MUST stop using those keys. Endpoints MUST initiate a key update before reaching this limit.  If a key update is not possible, the endpoint MUST immediately close the connection.  Applying a limit reduces the probability that an attacker is able to successfully forge a packet; see AEBounds and ROBUST. Due to the way that header protection protects the Key Phase, packets that are discarded are likely to have an even distribution of both Key Phase values.  This means that packets that fail authentication will often use the packet protection keys from the next key phase.  It is therefore necessary to also track the number of packets that fail authentication with the next set of packet protection keys.  To avoid exhaustion of both sets of keys, it might be necessary to initiate two key updates in succession. For AEAD_AES_128_GCM, AEAD_AES_256_GCM, and AEAD_CHACHA20_POLY1305, the limit on the number of packets that fail authentication is 2^36. Note that the analysis in AEBounds supports a higher limit for the AEAD_AES_128_GCM and AEAD_AES_256_GCM, but this specification recommends a lower limit.  For AEAD_AES_128_CCM, the limit on the number of packets that fail authentication is 2^23.5; see ccm-bounds. These limits were originally calculated using assumptions about the limits on TLS record size.  The maximum size of a TLS record is 2^14 bytes.  In comparison, QUIC packets can be up to 2^16 bytes.  However, it is expected that QUIC packets will generally be smaller than TLS records.  Where packets might be larger than 2^14 bytes in length, smaller limits might be needed. Any TLS cipher suite that is specified for use with QUIC MUST define limits on the use of the associated AEAD function that preserves margins for confidentiality and integrity.  That is, limits MUST be specified for the number of packets that can be authenticated and for the number packets that can fail authentication.  Providing a reference to any analysis upon which values are based - and any assumptions used in that analysis - allows limits to be adapted to varying usage conditions. </ins> 6.7.

Related discussion:
text: Good catch, yes, the double passing over the message requires a factor 2 here. (The AD a may also be up to 3 blocks if I understand the header format correctly, but I guess that's negligible compared to the conservative 2^10 message size.)
Good point about the AD. The AD - at least for QUIC - is always sent, so that fits in the same space. We don't necessarily need to double count the tiny number of blocks, but as you say, counting that only once yields a negligible difference. If we had a large AD that wasn't also transmitted, that would be different.
Agreed. To be precise: if I'm not mistaken the AD isn't counted at all right now ( accounts for the max. payload blocks), but of course the difference is still negligible as long as the AD is small.
Thanks for the edits!