AirTags have a lot of privacy protections. The stalkers were only caught because they were dumb enough to use their own identifiable Apple IDs.

Just creating one with a fake protonmail email will make it quite difficult, though you will also have to purchase an iOS device just for that. Still not unthinkable.

You can even build your own tracker for some apple's network: https://github.com/seemoo-lab/openhaystack