While writing this comment, I decided to investigate whether or not speed control is even possible on a 5V fan with 3V3 logic and found this: https://noctua.at/pub/media/wysiwyg/Noctua_PWM_specification...
The answer is: I still don't know. They say that the PWM voltage is pulled up to "3.3V/5V" internally but the spec says the PWM signal has to be 5V, so I suppose the results are undefined (and they just left 3.3V in their document accidentally).
But, a first-party fan could make this work, so I'm kind of sad that they just chose some off-the-shelf fan that was cheap today in Shenzhen. If you could do better than Noctua, then there's value in making it first-party. If you can't, why bother? Everyone that wanted a fan already has one.