Upside-Down Reinforcement Learning (UDRL) is an approach for solving RL problems that does not require value functions and uses only supervised learning, where the targets for given inputs in a dataset do not change over time. Ghosh et al. proved that Goal-Conditional Supervised Learning (GCSL) -- which can be viewed as a simplified version of UDRL -- optimizes a lower bound on goal-reaching performance. This raises expectations that such algorithms may enjoy guaranteed convergence to the optimal policy in arbitrary environments, similar to certain well-known traditional RL algorithms. Here we show that for a specific episodic UDRL algorithm (eUDRL, including GCSL), this is not the case, and give the causes of this limitation. To do so, we first introduce a helpful rewrite of eUDRL as a recursive policy update. This formulation helps to disprove its convergence to the optimal policy for a wide class of stochastic environments. Finally, we provide a concrete example of a very simple environment where eUDRL diverges. Since the primary aim of this paper is to present a negative result, and the best counterexamples are the simplest ones, we restrict all discussions to finite (discrete) environments, ignoring issues of function approximation and limited sample size.