The short answer is it involves manufacturing tolerances.
When I was deploying marine sensors Duracell batteries were far more consistent both in terms of capacity and mass. Neutral buoyancy was crucial for us, and the variance between Duracell batteries was less than 1%. IIRC Rayovacs had a variance of 4-6%, and ‘generic’/off-brand were even higher. We couldn’t buy Energizer batteries in bulk where we were but it’s my understanding they are of similar tolerances as Duracell.
I’m a bit surprised that a smoke detector would have that tight requirements, but it could matter.