At that point, you are trying to remove the ability to read the old files on the disk you are about to use for new encrypted data. Wiping with all zeros will make it extremely difficult to recover files and random will be even more so. But by writing down zeros, you leak metadata about the encrypted parts of your drive. Zeros almost certainly don't contain data, but the noise will. If I can see you have 30gb of noise on a drive, rest zeros then I know something I probably shouldn't, namely that you have written at least 30gb to that drive. But that same 30gb of noise wouldn't be discernible in a drive full of random data.
What you might be thinking of is when decommissioning the drive after having encrypted it. At this point, I don't think it matters. I'm not sure drives come with all zeroed status from the manufacturer anyways.