Only if you exclude the following network transmission, which is the easy part that needs no special code. The privacy concern comes in with those two things together. So yeah if you take away one half of a bad thing such that the bad thing no longer becomes possible, it's not bad anymore. The concern is the whole process, on-device scanning being the key not-yet-implemented component.
> If Apple has a legal obligation to ensure that iCloud does not store CSAM/etc. then either you have to scan on device before upload _or_ you have to store iCloud data without E2E encryption.
Apple does not have that legal obligation. If they can't decrypt the content on their servers, then their only response to a government-issued warrant would be to hand over encrypted data.
Also, CSAM is not the concern. The concern is this would be used against dissidents in authoritarian countries. On-device scanning takes us a step towards becoming one and further empowering the existing ones.