Yes I would guess so. For me I have created a child-theme (for my company), that we reuse for each customer. But I’m thinking of excluding the elements from the theme and putting them into a plugin aswell.
There are multiple examples of people who have put out Bricks Elements Plugins:
There is a rudimentary tutorial on how to build custom elements, with it’s early pitfalls, in this thread you might want to check out:
Cheers Suat