With Advanced Data Protection enabled (it's not available globally but it is in the US), Photos is E2EE.
Also insofar as ADP is off by default the whole system can NOT be said to be “privacy oriented”, which was the claim I was refuting.
Apple, for the most part, does not care about the privacy of their users. ADP would not be built today, and it will probably eventually be quietly removed (like it was in the UK), because ~nobody uses it.
I assume customers were notified?