Could be...except we only know
Eru made
Tom at some point; we don't know when that was... pre-Ainulindalë? post-Ainulindalë?
And here's so something to think about: what if Eru brought Tom into being
during the
Ainulindalë? in the midst of The Music?
Tolkien is silent about Tom's specific place in creation.
Until that unpublished (1964) letter to Prof. Przemysław Mroczkowski turned up, we always thought he was part of Eä ; but he isn't.
So we can speculate about Tom until Mount Doom freezes over 🙄, but we'll never get any closer to figuring out his origins.
Fun to do... but we end the way we begin: in ignorance.