Do you have any new info about it?
We have the same problem - our app is web wrapper and the cookie is only for the session. No tracking at all.
Our progress - after long ping-pong with some robot that it is cookie for session, no tracking at all and all responses were like cookies = tracking so you have to implement App Tracking Transparency.
So we decided to add ATT to app and filled the form with tracked info (there is nothing tracked) and the robot answered, that we have to explain how we track the user - because we implemented ATT, so we are tracking.
Exact example of Catch-22.