I know it previously switched from <noscript /> because it was unreliable, but <script /> seems to suffer from similar issues, repro: http://dev.cetrez.com/jsx/2/scriptfail.html
I went through all the different elements (link, meta, etc), but none of them seems to work, so <span /> is seemingly the best alternative it seems to me, especially since it is already kind of special in React (i.e, React can wrap text in <span />). But it's not great.