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You've got in backwards. The ContentFilterExclusionList was itself a hack. It never should have existed.It might or might not be a hack, but that's orthogonal to the functionality or whether it uses a ContentFilterExclusionList.
The fact that it wasn't there before, or that it is a misguided feature idea, doesn't mean it was done as a quick and dirty implementation or that it's hastily made feature done via cutting corners.
If you accept the need for your own apps to bypass user application filtering (eg. because you consider your traffic/apps integral to the OS operation) then that's the kind of thing you'd implement -- and you could do it with a team of 100, working for months with fine specs, to deliver the same thing.
There's nothing inherently hacky about it.
>There was no problem with that until Apple decided to exempt itself from getting blocked.
That's neither here nor there though, as to whether it was done as a hack - or, to get back to the point, as to whether they could just rip it off trivially.
People forget this is not just a single feature, but part of a change to how network filtering is done (not through a third party kernel extension anymore), accompanied with new APIs.