Not the case for radios certified under the 2017 rules.A radio can have Part 95E type acceptance and still transmit on other frequencies. I use a Icom LMR radio for years that had Part 95E type acceptance and I had it programmed to work on 70cm amateur frequencies, also. All totally legal.
No GMRS transmitter will be certified for use in the GMRS if it is equipped with a frequency capability not listed in § 95.1763, unless such transmitter is also certified for use in another radio service for which the frequency is authorized and for which certification is also required. No GMRS transmitter will be certified for use in the GMRS if it is equipped with the capabilities to operate in services that do not require equipment certification, such as the Amateur Radio Service. All frequency determining circuitry (including crystals) and programming controls in each GMRS transmitter must be internal to the transmitter and must not be accessible from the exterior of the transmitter operating panel or from the exterior of the transmitter enclosure.
So a manufacturer could (in theory) submit for certification under Parts 80 and 95E, but it explicitly excludes a radio that can do Part 97 from certification.
Of course the Internet is full of "hints and tricks" to unlock just about every GMRS radio to do 2m and 70cm, but ....