You have to actually examine the real bits on the drive. Resellers don't want to take the time to actually zero a drive, they usually just nuke the partition table.
You also need to physically examine the drive. Corroded fingerprints on the PCB, wear on the port contacts, scratches from mounting rails, etc.
That's how it found out that the last "new" drive I bought on Amazon was actually a used Backblaze drive. It contained terabytes of customer data, and a shit ton of cleartext files. SMART, of course, reported it was a brand new drive with zero hours. Cleartext logs on the drive showed many thousands of hours of runtime.
Physical examination is the only reliable method.