Hard to say based on one comparison.
My friends Star Wars 1200 PS4 is pretty quiet. You can just barely hear the high pitch whine of the fan here and there. His console sits horizontal. He bought his a few weeks before I bought mine from the same store.
My Uncharted 1200 PS4 is quite a bit louder and the whine is much louder and comes and goes a lot more often. It sat horizontal as well. I've applied new MX4 paste and that helped a little. I tried the console in a vertical position and its just as loud as before, but the whine is basically gone now.
The stock paste on my 1200 PS4 was decent quality and was in good shape after a year. I also had the better quality, supposedly quieter fan brand as well, which was odd since I assumed that my buddy probably had the better fan and I had the worse one. The whine my fan made, only started after a couple months of use btw.
I even had a good look at the heatsink to see what kind of imperfections it might have and it was very flat and machined very well. I could have polished it down and allowed slightly better contact, but I don't think it would have made much difference since it was pretty smooth already.
I've heard a couple other PS4's close up, a 1000, 1100, and 1200. The 1000 was fairly quiet, the 1100 was as loud as mine, and the 1200 was jet engine and had a super loud whine. I really do wonder if it has to do with a mixture of day to day assembly, fan brand and quality, as well as varying chip quality.
My PS2 and PS3 slim were both dead silent. My PS4 never goes jet engine, but makes noticeable noise. The whine was irritating and bothered me, but now that its gone and just the natural fan noise exists, its not really a big deal.