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Part of the reason is that the protocol that's uses for retrieving emails (IMAP) is pretty old and doesn't support end-to-end encryption. JMAP is supposed to be a modern replacement, but it's not widespread yet, and also intentionally doesn't support E2EE.
E2EE is hard, for example searching has to be done client side rather than having a search index on the server side (since the server is not able to decrypt the data to index it). I haven't tried Proton but I'm curious as to how they solve this... I guess they'd sync the entire mailbox and index it locally, like what (non-mobile) Thunderbird does.
I really question the value of E2EE for emails, though. Communication between servers (e.g. someone on Gmail sending an email to a Proton user) uses TLS but is not, and will likely never be, end-to-end encrypted. Emails you send to other providers are also not likely to be encrypted on the other provider's end.