I think there is a reasonable chance that some older spec sheets were simply written when 2.5" drives larger than that didn't exist, and those docs have never been rewritten. I know from personal experience that this was the case for select pancake PowerMacs which required low-profile RAM DIMMs; the motherboard itself supported higher capacity DIMMs, but the low-profile DIMMs at the highest supported capacity simply didn't exist until well after the release of those Macs.
That said: it may be worth noting that at some point, Boot Camp stopped supporting drives larger than 2TB. Back in 2012 I had purchased a 27" iMac with a 3TB drive, and I noticed early on that Boot Camp did weird things when partitioning: apparently the Windows partition had to be second, but it also had to be entirely within the first 2TB of disk space in order to be bootable. Thus, the MacOS volume spanned across two partitions, with that Windows partition sitting in the middle. (I imagine that was a nightmare for some poor Apple software engineer.) But at some point after that, when I upgraded MacOS, Boot Camp stopped permitting me to manage that disk. That's when I researched and found out about the newly implemented 2TB limit.
So it's possible that it's just out-of-date documentation -- but it's also possible that it's related to Boot Camp.