Even on NES a lot of games use CHR-RAM so arbitrary bitmaps are at least possible, though only a small part of the screen is unique without some rarely used mapper hardware. Zelda and Metroid mostly just use this to compress the graphics in ROM, Qix is a simple example with line drawing, Elite is an extreme one.

I made a demo of the Mystify screensaver using the typical 8KB CHR-RAM. Even with a lot of compromises it has pretty large borders to avoid running out of unique tiles. https://youtube.com/watch?v=1_MymcLeew8