Lets try and calculate the absolute maximum itm lvl for a f2p (attainable ofc...)
Example : Warrior
There are all together 15 pieces of gear that are taken into account ( i excluded tabard and shirt )
9 pieces are attainable through Invasion chests ( 8 pieces of gear + weapon ) - 9 x 35 = 315
Back + neck slots are looms - 2 x 25 = 50
2 x rings ( lets say Band of Argas + Silver Piffeny Band ) - 32 + 30 = 62
2 x trinkets ( AGM + Old insignia of the Horde ) - 55 + 60 = 115
When added and divided......... 542 / 15 = 36.13 - lets say 36
Now some classes use an offhand - e.g. Bouqet of Black Roses - that's another 60....542 + 60 = 602 / 16 = 37,625 - lets say 38
So lvl 41 seems not possible for f2p...