First, we are talking ender 3.
Second, most art and trinket prints do not warp because of thin wall, large and heavy walled technical prints warp. PEI, glass, garlite, It warps just like abs but not quite as bad. Its well documented, just google PETG warping.
Third, my bed even on my ender 3 is level, and on my railcore II its about as level as any printer could be. And with the railcores enclosure warping is greatly reduced, but i don't print it often any more due to lack of heat resistance and the superiority of abs printed in a chamber.
I've never used an ender 3, but I've had plenty of bed slingers, and never had any warping issues with PETG.
I mean, I certainly believe it's possible, but I've just never seen it on my end, and I've printed at least 50kg of PETG over the past few years. There's a bunch of variables that could cause warp. There's also no telling what's actually in the blend of plastic that your supplier sells you, as there's no accountability for that kinda stuff.
The only time I've actually seen PETG warp was when a buddy of mine was trying to print on a bed that was too cold. I always use 80-90C on the bed for PETG.
I've also printed in a cold ambient garage on an unenclosed printer and PETG didn't warp. And this is for large prints as well.
Not trying to be contrarian or anything like that, but I just don't think that's the common experience. Then again, a lot of people have difficulties with PETG (and I remember initially having those as well), but it prints just as well as PLA for me (the very few times I do use PLA).
These days, I mostly print with ABS though. I cheat for adhesion by using Visionminer nano on my build sheets. That stuff works amazing to keep stuff stuck to the build plates.