My point was that an ACEA E6 lubricant already is at the correct phosphorus limit for API SN in ILSAC grades, so they have one less hurdle. In more general terms, the main line HDEOs all have ACEA specs of one sort or another, usually E7, E9.
Delvac 1 ESP 5w-40 and Rotella 5w-40 both lack SN in their CK-4 variants, as far as I recall.