There are a lot of factors. Manufacturing process, head, lubrication, insulation, material thickness.
Nobody can give you a specific answer without a forensic teardown. I would say it's probably the casing, refinements in head size, and noise canceling insulation inside the drive.
Drive noise measurement is always a frustrating thing to keep track of. It's much easier to just find a solution to isolate the drive noise completely and not worry about it.