I agree and I think that is the reason this feature is being pitched as "experimental":
In order to have to proper (non-experimental) support for device frames Swift-DocC will need to have some story for out-of-the-box support of frames so that the average user doesn't need to declare them at all. I believe this is being left to a future pitch. (In general we also need a better story for the UX of theming – diagnostics, etc – and I think improvements to declaring custom frames will come with that).