Apple is claiming to have a visual equivalent to a cryptographic hash -- one which won't change with a single byte, but only if the image is substantially different.
At least their security analysis relies on that.
From their whitepaper: "The threshold is selected to provide an extremely low (1 in 1 trillion) probability of incorrectly flagging a given account"
If your claim is that their hash algorithm isn't cryptographic, their security analysis is incorrect.