For example, let's say you have formatted an SMR drive, or an SSD. Both support TRIM. This means that they will return zeros for every formatted sector. In order to recover your data, you would need to gain access at the firmware level, using undocumented vendor specific commands (VSCs), and then read each physical sector directly.
Every drive of any type should return zeroes for all formatted sectors in normal operation. With CMR drives and a quick format, the data is still in the sectors and the file table just tells the OS they're empty, but a full format would actively make them all zeroes. The same should happen initially with other drive types, before TRIM has run, though of course with an SSD there is a lot less surety of the specific desired blocks being wiped due to remapping and wear leveling and features like that.
If TRIM/garbage collection was given time to run, an SSD shouldn't even return any data at that point. It should all be physically null, erased blocks, neither 0 nor 1. (I don't know what happens with TRIM on an SMR drive. I think it preps the blocks in a similar way.) The SSD's garbage collection actively goes to each block and erases it so that the block can be quickly written the next time it's needed, rather than having to be erased in the same operation as the data is being written.
Do those vendor specific commands go as far as reporting the specific charge level in every cell, which might then allow the recovery specialist to estimate what the previous charge was before erasure, 0 or 1? I read ages ago about mechanical platters being read with electron microscopes or force microscopes or something to get the exact magnetic charge level of each bit, and that this is why military erasure requirements call for multiple passes with random data, to assure there's no way to pick up any remainders of previous data. Is an SSD controller able to report back at that level, or is it simply yes/no, above or below each threshold for indicating a bit?
Users will always choose convenience over security, unless they have specific needs, and most users just think they're not important enough to need to be extra secure. Recovery specialists obviously will say making the data unrecoverable isn't what their users want, but password/encryption security is vastly different from being able to physically recover the bits in a drive. There's no "backdoor" needed for physical recovery, just knowledge of how the device works (and lack of deliberate destruction like multi-pass wipes). Recovery of encrypted data is a software issue that is independent of the storage medium. You could encrypt your file and then engrave the 0s and 1s onto a clay tablet and then break the tablet, but reassembling it is a separate task from decrypting it.