For sure that's accurate. I suspect though that Tesla's approach to regen is more efficient in practice because it enforces the efficiency.
When I drove an ICE vehicle, I tended to be a hard breaker with abrupt stops... and that's as a former hyper-miler long ago, so I knew very well that it was less efficient but drove that way anyways just from adopting bad habit.
When I got the Model 3, it forced me to become a better driver by relearning braking distances and in doing so also improved efficiency.
If Tesla instead implemented a Regen brake pedal and removed regen from the accelerator, I suspect most people would be hard brakers.