Certiainly from a consumer to consumer conversational standpoint I think it's safe to expect that the measurement is C-C. There are some manufacturers that measure from center of steerer tube to clamp face, though. Also some road stem manufacturers who make 90deg stems actually list the stem length as an effective length, a length determined as if the stem were the classic 15-17-19deg or so, and assuming quill exposure or steerer tube exposure of 30mm or so. Basically they are calculating the length of the stem as it relates to that particular model's rise.
Much like frame sizing, where there are many possibilities for determining size, the more information you can get the better, and it's always a good idea to ask "is that C-C?" before you leap.