Like with everything else, simple rules are not capable to deal with more complex situations.
Keep in mind that you want to use a mobile phase that does not promote the growth of bugs. pH 7 phosphate buffer is a rather good medium for bug growth. If you make this pH 2, or pH 12, close to nothing will grow in your mobile phase. Similarly, adding 10% of acetonitrile to a pH 7 phosphate buffer prevents bug growth.
In a bicarbonate buffer at pH 10, you may still get away without a chance of bug growth, but maybe you need to add 2% of acetonitrile. Same question at pH 4.5 in an acetate buffer.
Even if you are working with pH 7 phosphate in 100% water, you can prevent the growth of undesirable entities by frequently replacing the contents of the container.