Apple's hardware is using considerably lower TDPs than other chips of comparable size. For example, Intel's enthusiast-class CPUs have die size comparable to the Mx Pro chips, yet can consume an order of magnitude more power. Heat dissipation does not seem to be a limiting factor for them. I would say the biggest performance limiter is their desire to build systems that perform well on thermally constrained targets, which requires certain architectural and engineering choices.
For laptops - My understanding is, Apple have as lower temperature limit allowed on the underside of their laptops compared to other laptop makers (partly due to corner case issues that can cause a reaction in some people to long term exposure).
But Apple’s keenness to minimise noise - has resulted in extensive research with teams of psychoacoustic experts and engineers : https://www.powerpage.org/apple-patents-point-to-effort-to-reduce-noise-on-macbook-pro-fan-modules/
The 2013 MacPro (trashcan) was an example where (in my opinion) noise limit - acted as a limiter on the maximum average wattage the device could consume.
The standard M2 Studio utilises a chunky aluminium heatsink; the M2 Ultra replaces this with a (more expensive and heavier) copper version. As Apple could have reduced costs by using the same aluminium design, same heat sink - and simply increased the fan speed - I conclude that there is a maximum continuous Noise level limit that Apple is designing the Mac Studio to.
If there is a ceiling on the noise levels, it follows, that based on Apples current level of system-cooling expertise, there is a maximum wattage for a particular volume. The current M2 Mac Stuidio can dissipate 295W continuously. As there are several ways to improve this by changing the surface to PGS (eg pyrolytic graphite) - or a meta material (to change the local impedance of air - which KEF + B&W lead the field) - I speculate Apple will be ‘forced’ to improve this heat dissipation @ lower white noise levels in their next offering. My finger in the air guess is a 21% increase is on the table if they want to get a license from Panasonic (or if they further sculpt the air channel to minimise turbulence).
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