My iPhone 14 is 1081 days old, charged every night, battery capacity is reported as 81%. So in Apple's own measurements this is possible.

I guess there is some built in spare capacity, but that may still qualify for the exemption?

My experience with an Apple battery saying ~81% longevity remaining is that it'll die when it still reports half full and you open a demanding webpage

It's a genuinely hard problem to measure battery capacity with existing smartphone hardware, also because it's a matter of opinion how much to factor in the peak load capacity (how do you count the bottom 40%, where it can't handle peak draw anymore? Should one include half of it because the phone is still usable but in a degraded state?), so I'm not faulting Apple here at all. They choose to display this estimate and it's better than nothing / better than most manufacturers. Just that you can't take it at face value, even if you charged your phone from 0% to 100% for >=1000 days

If you charge every night from say 50%, that's not a full cycle.

The exemption is about ensuring customers get what they paid for. It shouldn’t care how the manufacturer achieves that; driving the batteries less hard is an obvious tactic, and actually also makes them safer to use.