Yeah, but then I don't really see what purpose the first rule serves. I'd maybe put it last and rephrase it to something like "Good design is innovative when necessary".
The comments here that disagree with Rams' first rule seem to me to be putting the cart before the horse and assuming that Rams is offering a prescriptive list for would-be designers. I think he's just describing what he thinks constitutes good design. It is not an injunction to innovate: it is an observation that "design" which does not innovate is inconsequential.
If the purpose of design is to solve a truly valuable problem or introduce pleasure to a process, and if these possibilities—if we're honest with ourselves—do not exist to be solved, one cannot innovate, therefore one cannot design.
A honeypot to the those who see design as surface, a challenge and call to arms to those who see it as more?
(*I'm curious if anyone knows what this type of phrase is, one that can be interpreted in two different, opposing ways. Best I can tell is _polysemy_)
Design, as the op even says, is not just (although it definitely also is) about utilitarianism! The world of successful products should at least suggest that to you, if you won’t take it as proof.