The docs for libraries still mentions @ccallable: "The library is expected to provide C-callable functions for the functionality it is providing, defined using the Base.@ccallable macro". From the upgrade instructions, this seems to no longer be true? Also, the code following the sentence doesn't use @ccallable.
I could make a PR, but I'm not sure how this behaviour changed: "All C-callable functions will be exported and made available to programs that link to the library."