I am definitely referring to super class of the entity listener itself, not the entity listener annotation of the entity.

I am familiar with the spec. It does not define this one way or the other because it is assumed the implementation will search for annotations in a reasonable way. Most other Java technologies handle this by resolving an annotation in a super class. Can you show me in the spec where it states that super classes can't define a listener annotation?

I guess, one man's bug is another man's feature; Call it what you want. All I know is I have over 100 persistent units that each needs boilerplate code because I can't inherit from a common class.