* "proxy-less" is a bad term, it sounds like they're still using a proxy, it's just using https encapsulation along the way to hide this from the first few hops.
* The participating entry-nodes (proxies?) could be systematically determined with a scanner for future blacklisting or investigation by someone trying to stop this circumvention of censorship.
* You have to trust the people running the entry nodes, if they have the key to decrypt your traffic. This sounds like a design that governments can use for monitoring.