Aside from encryption, commodity NVMe SSDs are also really bad at correctly implementing idle power management. The Linux kernel is constantly adding to its list of drives that cannot safely use the deepest idle state because on many systems the drive won't wake back up after being put to sleep. Apple might be able to have a bit of an easier time since they control the host system so tightly, but they would still end up having to accommodate plenty of SSD bugs/quirks.