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Technically, yes, data must transmit to negotiate, but it doesn’t require high throughput. So you’ll get USB 2.0 transfer speeds (480 Mb/s) with most “charging only” USB-C cables. That’s only really useful for a keyboard or mouse these days.
This limitation comes up sometimes when people try to build out a zero-trust cable where they can get a charge but not necessarily transfer data to or from an untrusted device on the other side.