When I say “the US and the EU are effectively the same on this matter” then I talk about the legal framework that is allowing this to happen. Snapchat can scan in the EU as they did in the US.
You say this is not happening, and honestly I don’t know if anyone is currently scanning under Chat Control 1 or not. It sounds to me though they could if they wanted to. Has nothing of interest come up yet? Are they scared of GDPR? If they find something, maybe they are reluctant because the public sentiment towards privacy is different and this would blow up in their face? Maybe you are right and they simply don’t scan. I would not rely on it though.
Of course the lived situation in the US is significantly more oppressive than in the EU. The crimes of ICE, the constant surveillance with flock, the fcc threatening free speech… it’s insane. We need to make sure that in the EU the situation won’t escalate as quickly as it did in the US, because there are plenty political parties and some governments who are trying.