Manufacturer of ESD Static Control Products
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No. To remove ESD sensitive items [ESDS] from packaging and laying the ESDS on the packaging on top of the ESD mat is very poor practice.
ANSI/ESD S20.20 Table 3 requires the worksurface to be less than 1 x 10^9 ohms. The worksurface standard recommends that for electronics the worksurface be at least 1 x 10^6 ohms. Without testing we do not know what the resistance is of the packaging is, but antistatic bubble wrap and metal in shielding bags typically measure 10^10 ohms.