Absolutely and I recollect the folks ATS have had several counterfeit holders with real (but not the original) coins in them. The people who do this counterfeit ae getting better by the day. I remember when it was only coins and now it's the holders too. I believe, but I'm not sure, one of those PCGS counterfeits was the holder, label, substitute coin, CAC sticker.
I may be wrongs, my memory is not what it used to be but I 'think' even a decade ago if you cracked an NGC holder something turned a different color. Maybe someone from NGC could tell me whether I'm wrong about that.