Wine does translate kernel calls. Perhaps youre misunderstanding how that is then exposed?
Wine translates windows calls (including system level/kernel level) but exposes/implements in userspace on linux.
It doesn’t only do windows userspace to linux userspace
Its a design decision from the wine team to not build it as a kernel module and to instead implement as an application in userspace
Have a read here https://werat.dev/blog/how-wine-works-101/