Not necessarily. Nintendo’s variant is built by Macronix under their XtraROM service; a variant of NAND flash designed to be a reliable Mask ROM substitute (including only being writable once, automatic repair afterwards, etc). Officially, their chips are rated to last 20 years at 85 degrees Celsius, which is insane.
This isn’t your off the shelf SD card chip built by a no-name Chinese design company that fails after 3 years of not receiving power. Combine the niche flash with a custom security chip (Lotus3) on every game card; that’s not cheap.
While we don’t know the exact pricing, the rumors are that 64GB is somewhere in the $15-$25 range per cartridge. At those prices, even if I ran a game company, I’d be reserving the non-game-key versions for a Deluxe Collector’s edition.