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Do not misunderstand; it is not that bipolar transistors are immune to ESD damage, but that the MOSFETs are particularly susceptible at their gate lead. So it is a good idea to protect any outside connection anyway to some extent depending on the application. Good design practices for handing over-voltage, over-current, and radio frequency interference are usually sufficient.
That much I will accept, especially if it is understood that the transistor is backed up by other circuitry and and adequate layout. However, in my experience that "backup" would have to include ESD protection devices.
I also like your comment about other EMI scenarios. Emission testing usually being done first, is a great indicator for upcoming issues in the imission and ESD tests.
In practice any transistor with a relatively large junction area protects itself, so parts with say a 200 milliamp collector/drain current rating or higher do not require any special protection against ESD, but it may still be desirable to protect bipolar transistors from reverse voltage; power MOSFETs have a built in body diode which does this for them. Larger transistors with larger junctions are even better protected.
A standard ESD test reverses polarity, will exceed ratings of most BJTs or MOSFETs, and inject charge into the rest of the circuit.
Alright, since we still don't know the numbers behind the TO's actual requirements (test level), we might as well wrap it up here. A recommendation would be to include ESD-protection devices at least in footprint and do ESD tests in different configurations.