I don't think you would ever get a 201 Created in an eventual consistency scenario. You would get a 202 Accepted. Unless the API is lying to the clients.
Created can mean different things to different people. Maybe an ecommerce order is created in the sense it's been updated in the inventory database and a record added to some sort of fulfilment system but there's still outstanding data warehouse sync jobs, some order analysis/product recommender job, and some anti fraud jobs (that just need to complete before the order picking in the warehouse begins)
Accepted can mean that it will eventually be created though. In the sense that it's validated and guaranteed to be created at a later point ("eventually").