That is the opposite of what is going on. Let me explain some background.
Multitone was created not as a new way to discover audibility of distortion but to speed testing of products in time sensitive manufacturing line. Traditional sweeps are slow and require multiple ones for different measurements. Multitone test on the hand, is very quick and generates not only distortion results but also frequency response.
But the above comes at a cost. To get the same SPL as a single tone, you would have to spread the energy across the number of tones you use for multitone. For this reason, distortion seen in multitone is lower than what you see in a THD analysis. You can see that in for example, amplifier measurements where I show the distortion and multitone results.
Further, the intermodulation products are many and hence, once again divide the distortion products into smaller components. This means if you apply psychoacoustic theory to them, they will result in them being deemed inaudible. From Fielder's paper:
"The previous section has concerned itself only with the analysis of harmonic distortion and has ignored intermodulation (IM) effects. This simplification is acceptable because IM produces products that are less or equally audible compared with the harmonics of sine waves. This is true because difference IM products for subwoofers lie in the first critical band with the masking signals and have their presence masked. The sum products are no more audible than the harmonics of a single sine wave with equivalent level and average frequency because they are less than or equal in frequency to the appropriate harmonic and are at a lower level since IM divides the amplitude between components."
Multitone testing was obsoleted with advent of CHIRP signals which is modern way of testing transducers and room. And what I and others use for headphone and speaker testing. It is a continuous signal where many other components just "fall out" of the signal making it ideal for fast test but also getting granular distortion products. Look at the clarity it provided in the last test I ran:
There is no need to perform any analysis. Something is seriously wrong here with the source known. Designer could have used this measurement to eliminate or reduce the impact. We are of no need of any other measurement.
If we wanted to, we could look at the harmonic order and assess audibility. Our hearing has radically different masking/threshold for each frequency band. That makes the comparison of distortion against audibility vastly simpler and a possibility. Such doesn't exist in multitone where all the distortion products are mixed together.
To emphasize, whatever non-linearity causes IMD distortion, also caused HD distortion. A totally linear product has neither.
Fielder's specialty is psychoacoustics of audio signals. Nothing there is specific to "digital" signals. He has written some of the most authoritative papers on this front and covers both speakers and headphones. This is his bio:
"Louis Fielder received a BS. degree in electrical engineering from the California Institute of Technology in 1974 and an MS. degree in acoustics from the University of California in Los Angeles in 1976.
During the period between 1976– 1978 he worked on electronic component design for custom sound‑reinforcement systems at Paul Veneklasen and Associates. From 1978 – 1984 he was involved in digital-audio and magnetic recording research at the Ampex Corporation. At that time he became interested in applying psychoacoustics to the design and analysis of digital-audio conversion systems. From 1984–2018 he has worked at Dolby Laboratories on the application of psychoacoustics to the development of audio systems and on the development of a number of bit-rate reduction audio coders for music distribution, transmission, and storage applications, i.e. AC-1, AC-2, AC-3, Enhanced AC-3, AAC, and Dolby E. Additionally, he has investigated perceptually derived limits for the performance for digital‑audio conversion, low-frequency loudspeaker systems, distortion limits for loudspeakers/headphones, loudspeaker-room equalization, and headphone virtualization. He managed the Sound Technology Research Department at Dolby Laboratories in San Francisco from 2005 – 2009.
Louis Fielder is a life fellow of the AES, a recipient of the AES Silver Medal, a senior life member of the IEEE, a life member of the SMPTE, and an emeritus member of the Acoustical Society of America. He was on the AES Board of Governors during 1990–1992, President during 1994 – 1995, and Treasurer 2005 – 2009."
And where is the reference, or research for this? Remember, the corpus of music out there will be wildly different than multitone with equal loudness tones. That "grass" that you see is not what you will see with real music spectrum. So don't assume that you see the same with music and hence, is "congested."