That is because arc can't track objects in structs or unions (since they are at that point plain C pointers).
Even though you marked the file/class in question with -fno-objc-arc you might still pass an object controlled by arc to it as parameter, which would most likely result in a memory leak.
If you got this message try __unsafe_unretained. It is only safe, if the objects in the struct are unretained.
Example: If you use OpenFeint with ARC the Class OFBragDelegateStrings says this error in a struct.
Looks like this now works without errors, probably after this change.
i.e., You can put normal (strong) pointers to Objective-C objects in a C struct. It is managed by ARC e.g., it is unretained when the struct is destructed. Verified with:
$ clang --version
Apple LLVM version 10.0.0 (clang-1000.11.45.2)