This is certainly true. We’ve been discussing this (mostly internally with @klaus.aengenvoort and some other people) since a few years; - as far as I remember we talked about this with @TLiebich in February 2014, also regarding this related topic: How is a IfcPropertySet related to its IfcPropertySetTemplate? - #2 by stegh
From my point of view: GUIDs would certainly help.
@jonm also supports this… How is a IfcPropertySet related to its IfcPropertySetTemplate? - #4 by stegh