I think it does imply that that cold forming is better. Imagine two heads built from the same material to the same final dimensions, one CF and one WF. If the ELE is between 5-40% and none of the other conditions of UCS-79(d) are exceeded then the WF head would need stress relieved while the CF head would not. This implies that CF is better than WF.
Perhaps since the yield stress is lower in the warm forming temperature range that the strain pattern is different in a way that raises concern.