TDP measurements are not standardized so it is not always when the component (CPU, GPU) is at 100% load.
When researching this topic a few years ago, it seems that AMD does indeed measure TDP at 100% load for their CPUs. However, Intel approach is/was a little different, their measurement of TDP was based on above average CPU usage over time, but not greater than roughly 80% - 85% load to simulate typical "power user" usage.