No, they are not. As an instance, you will find no where in Torah that one cannot cook milk and meat together (There is a really easy one).
Well, the author does label that one specifically as halakhah. But that still leaves 612, except for the handful that Maimonides neglected altogether. I’ll have to dig those up later. So I’d need an app to keep track of 612 commands. Got anything else you can eliminate?