(https://grapheneos.org/faq#cellular-tracking)
Whether there is a sim enabled/disabled/installed is irrelevant. The question is whether this feature is Airplain Mode or if it is just disable cellular.
Instead you are referring to the fact that the radio may remain on even if it has no active SIM card.
Given that the primary concern of connected vehicles is changes over time and manufacturer control, I don’t see any reason to make that distinction for most people.