Magee footnote 2, note kha, p132

Are all forms composed of elements? Vasubhandu's Treasury of Knowledge identifies eleven divisions of forms (See Meditation on Emptiness, 232 and Perdue, 191).The first five are the ear, nose, tongue, and body sense powers. These sense powers are clear matter located in the coarse organs of eye, ear, etc. They are inner matter, and thus not tangible sense spheres.

Sixth is visible form. Then sound, odor, taste, and tangible objects. The four elements, which are together in every particle, are tangible objects.

The five sense powers and the five objects are called the ten obstructive physical objects. These can be divided into demonstrable and undemonstrable obstructive objects. Colors and shapes are the first and the other four objects along with the five sense powers are the latter.

Forms for the mental consciousness are undemonstrable and non-obstructive. They are form aggregates which are objects only of a mental consciousness and thus are not form-sources but \phen-sources. (See Meditation on Emptiness, 232-3). Hopkins lists five types of these forms:

Are all of these forms composed of the elements? It is not the case that Jam-yang-shay-ba is referring only to obstructive forms as fully qualified forms. This is because in the Presentation of Tenets, Jang-gya rol-pa'i-rdo-rje states, ``Those who assert non-revelatory form [probably here meant to refer to all forms for a mental consciousness] as fully qualified form are definitely the two, Proponents of the Great Exposition and Consequentialists" (See Perdue, Debate in Tibetan Buddhism, 191.). Thus, Consequentialists do assert such non-revelatory forms to be fully qualified. Even if this implies that all forms are composed of elements, it would still not follow that such forms are composed of matter. This is because Jam-yang-shay-ba asserts matter doesn't exist even conventionally. For him, if something is atomically established it is truly established. (Other authors such as Jetsunba assert matter.)