Interesting. I can’t imagine what about a drive would prevent APFS formatting. At its core, every SSD is just a block storage device. The OS reads and writes 512 byte blocks based on whatever organization the software wants.
I think the biggest potential issue here might be the partition type. Unless things have changed recently, I think you can expect most devices (especially those 2TB and smaller) to come pre-formatted with an MBR-style partition table. This is because MBR is compatible with any device up to 2TB, and old PC operating systems (e.g. Windows XP and older) can’t support other partition types.
Apple’s file systems (HFS and APFS) are incompatible with MBR-type partition tables. Well, they could probably be made to work with them, but Apple has never done so. If your device ships with an MBR partition table, you need to blow it away and replace it with another. These days, that would be a GUID partition table (GPT). A drive that needs to be compatible with old Macs (and we’re talking PowerPC or older) should use the now-deprecated Apple Partition Table (APT) format and format partitions as HFS+.
Drives larger than 2TB probably come pre-formatted with a GUID partition table, because neither MBR nor APT can support drives larger than 2TB.