I am under the impression that DOT exemptions are time-based and must be renewed every few years (every 5 for this one, I believe?) for the cylinders manufactured under that exemption to still be legal.
As far as I can tell, the cylinders manufactured under the exemption are perfectly fine...the only reason they would be "illegal" to fill is if the exemption paperwork expires.
DOT3AA cylinders (2250psi and 2400psi LP cylinders) are not under an exemption and will be good until the cows come home.
Personally if I owned any E971 cylinders and it looked like there was no way to have them remain "legal" I would have them hydro'd right before the exemption expires, get my own compressor, and fill them as I wanted to, giving Uncle Sam the finger...but that's just me...