That's an interesting question. Irl the question would be what makes those plants well suited for growing in a forest, between trees. In a conifer forest, it might be the soil acidity, but since these kits don't specify, afaik, a particular kind of forest, then that probably isn't the case.
A second, more plausible reason is that the plants prefer the shade of growing between trees, as opposed to being grown in an open field or garden. Irl they would still be sensitive to the soil pH, but that's another matter.
At a stretch a third reason might have something to do with some more specific reason, perhaps having to do with microorganisms like a leaf mold, but that's a reach, and would also be specific to a certain kind of forest, so, presuming the second reason is why they are best suited to growing under a canopy...
Orchards aren't necessarily as shady as a forest. Modern orchards consist of shorter trees somewhat closely spaced, but the lower height, as well as spacing for access by the grower to the fruit, and to permit the tree sufficient access to the sun itself, means they won't be as shady as an average forest. Older orchards would have taller stock, but would have more room between them, and again wouldn't be as shady as a forest.
Still, there would be somewhat more shade than an open garden.
Tldr; maybe, although maybe not quite as well as in a true forest? ^^