Electronic components have 30+ fields, 10 or so fields have different values from part to part. So the number of product variations are about 10 where each variation might have field values different from its sister part in one or two of the 10 fields.
example:
fields: A B C D E F G H I J K L M N
part 1 d r u p a l c o m m e r c e
part 2 d r v p c l c o m m e r c e
part 3 g r u p a l v o n m e r c e
part 4 d r u p a l b j m m e r c e
etc

To make it simple for the store owner, I use the product entity for all 30+ fields (as they are all characteristics of the part, not marketing fields) and he can use the feeds from excel sheet csv to input the product. That way he can copy and paste most of the fields conveniently and he is familiar with excel.

The question is: Can I use drupal commerce with product entities alone so he doesnt have to upload a second csv file for product display nodes?

It seems product display nodes are necessary for admin tasks ( products don't appear unless they have product displays) and I can't seem to make product search api ranges work with entities. Is there a help page on a case of using entities with no product display nodes?