Maybe it’s semantics, but no, I would not consider these Pokemon cards. In my opinion, these are licensed cards with Pokemon printed on them, but not “Pokemon cards.”
Pokemon cards are made by The Pokemon Company / The Pokemon Company International (TPC/TPCi) for official play. This would make Japanese Base Set the first Pokemon cards.
But if your question is, “What unofficial, licensed cards first had Pokemon on them?” then sure, you can look at non-TCG products like Bandai Carddass.