Well, not exactly — at least not in any jargon I’m familiar with. It’s only called a dieline if a die needs to be made/used to make the cut. In those instances, the dieline, as you already know, is typically placed on a non-printing layer and serves to determine both where the cut will take place and the shape of the cut itself so the die can be made and positioned. In a straight-forward trim, like this one, no die is involved, so even if a non-printing line is drawn in, it’s not really a dieline.
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