Are you absolutely sure a bout that? I once placed a chest with a very large number of items in it into a cell and got a CTD every time I entered that cell until I deleted the chest.
Define
very.
If a significant number of items in the container had scripts attached to them, that could be a problem.
If a significant number were leveled lists rather than actual items the game could get bogged down resolving them all.
The point in response to the OP is: items in containers aren't references, they are just entries in a linked list with a type, quantity, and possibly some extra data (in an unopened container, generally just a script). So there is none of the performance impact of having actual references to each of those individual items in the gameworld.