Not all cars have active TPMS. my Volvo xc90 had them but in later models they switched back to passive ones. So it is not even a given for higher end models.
My read through this document suggests that the maximum usable range may be as far as 5 meters, or as little as 1 meter: https://rfid.michelin.com/wp-content/uploads/2024/07/dataShe...
That's not as far as BLE or TPMS can work at, but it's not exactly like the NFC arrangement in a credit card, either. 5 meters is enough for a motivated attacker to do some undetected bulk data collection.