Entisols: "C horizon on topsoil"

In the case of recent eolian sands (dunes), whose profiles are classified as Entisols and have a surface horizon rich in organic matter, dark brown in colour and of massive structure, followed by other horizons of different texture. The sequence can be described as C1 / 2C2 / 3C3 etc ?. That is, without "A" horizon ?.
According to the definition of "horizon A", it should not show the structure of the rock or sediment. That is, if we consider the massive structure as sedimentary, it would not be an A horizon (as long as it is not cultivated). In this case we would have a horizon or layer "C" on the surface?.