Some are more accurate than others.
For something like Apple’s Airpods on an iPhone they know the power the headphones can output and they can calculate that against the signal you’re sending them. Accurate enough for this kind of tracking.
When you’re mixing device brands, there may or may not be that knowledge shared ahead of time, in which case it would be a best guess effort using a likely common specification. Probably still fairly decent on the whole but with a few outliers that aren’t properly represented.
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