From reading the manual there's a volume cap on newer models but it's implemented differently. With the newest models if you go past a specific level, 16, you get an alarm and warning you have to cancel before you can continue to increase the volume. After 20 cumulative hours the alarm and warning are repeated and the volume automatically returns to the level that's considered safe. If you turn it off the volume level will automatically be reset to the level that's considered safe.
This seems a much more adult way to implement the volume cap. The way the mandate reads is that the default volume needs to be at or below certain levels. This does that but leaves the final decision to the user. You get warned but you are still able to blow your ears out if that's what you prefer.