If we are reaching the limit to the number of spells as has been suggested, then every new spells that is made needs to count.
That would honestly depend on how the limit is implimented.

If it's a limit to the number of spells we can actively have in our list, then the option to simply 'forget' unwanted spells can solve that problem easily.

Not arguing that the spells we get shouldn't 'count' but that's highly subjective depending on the content a player plays in the game.