Because it says that demons can't touch Cinematic Records yet can eat souls. If those two are separate things, doesn't it mean that the new Ciel is soulless but moves because of memories inserted in him? Because that was basically the concept with the zombies in book of Atlantic. Does that mean that Ciel is a Soulless!Sam?
Well, Cinematic Records aren't souls. Grim Reapers collect souls, but corpses were shown to still have their Cinematic Records (like Margaret Connor). If Cinematic Records and souls were the same, this wouldn't be possible.
And yes, the real Ciel (or how you called him, the "new" Ciel) is soulless and moves because of memories (which were, I suppose, built on his desires and wishes for his future before his death or so) inserted in him.