Not really. Shocks are big investment and they can be controlled very effectively by a 240 MP unit. They are after all very specific and specialised infantry which means that you can exploit it. Especially the fact that they have to close in to do the damage. Use this to set a trap.
Multiple Shocks means less other infantry on the field and vulnerability to T2 vehicles. FHT especially. You could have seen this in the recent SNF tournament.
I usually build 3x Conscripts, Molotov, Shocktroops, I use the Cons to screen and the shocks to flank and close in on weapon teams, simple and very effective. I know it's a big advantage to have them this early because I regularly use them.
Once more, this is less about how well they can be countered but more about the immanent gamplay design.
Ciez summed it up very nicely here;
All that being said - sure Shocks can be beaten that early in the game, but I personally dislike the effect that 1 CP shocks/guards on have on the pace of the game. The past few patches have eroded the sense of "early game" that is so dear in CoH. I personally love/enjoy playing and seeing vanilla Grenadiers fighting vanilla Conscripts for the first few minutes of a game. (Don't read this as me justifying gren spam or con spam, I'm not). I love seeing the "dance" for cover and better positioning, trying to lure enemy squads into MG fire, or into bad positions. These early game engagements can really set the tone for the rest of the match, and have the potential to make matches more unique and dynamic. You can be aggressive and go for early cut-offs, you can play more defensive and try to control your own half of the map etc etc.
Elite infantry coming so early really negates this aspect of the game. Shock troops fighting vanilla grens really don't care about cover or positioning, you just right click them next to the Gren squad and watch them shred the grens to pieces. The only thing you have to really worry about is an MG42, and even then you have smoke grenades and Oorah on your Cons to flank.
So yes, they may be counter-able this early in the game, but it isn't fun to play against, it erodes the early game to being even shorter than it already was, and simplifies the game even further.