Nope, not solely for pri keys pertaining to "imported BIP39 seed", but for those ones served by Ledger for example, though fundamentally that is not too far from "imported" directly via UI, but still.
As far as Electrum is concerned, it is the same thing. It is using an externally created BIP39 seed phrase to create a wallet. It doesn't matter if the seed was generated and communicated via a hardware wallet, or was generated via some other piece of software and manually entered. It's still an imported BIP39 seed phrase.
You can also change the passphrase instead of the derivation path. I'd create a new wallet every year with same seed and new passphrase like "2020", "2021", etc.
Doing so robs you of the ability to use a random and secure passphrase, an important feature providing additional security and plausible deniability, which everyone should be using on their main wallets. I would only suggest using passphrases to achieve additional wallets if you use a different random and secure passphrase each time. Passphrases like "2020" are utterly trivial to brute force.