I see what you are trying to say.
However, in many suttas, kamma viññāṇa is used instead of dhammā (kamma bija also means the same thing).
– For example, some suttas mention “viññāṇa descending to a womb,” implying a gandhabba (created by kamma viññāṇa) descending to a womb.
– So, one needs to know they mean the same. I think those sentences are fine.
– Furthermore, in the second case (“kamma viññāṇa is not totally mental” – in the sense that it has ENERGY unlike vipaka viññāṇa), I wanted to emphasize the difference between vipaka viññāṇa and kamma viññāṇa.