AMC1 FCL.050 Recording of flight time
GENERAL
(a) The record of the flights flown should contain at least the following information:
(1) personal details: name(s) and address of the pilot;
(2) for each flight:
(i) name(s) of PIC;
(ii) date of flight;
(iii) place and time of departure and arrival;
(iv) type, including make, model and variant, and registration of the aircraft;
(v) indication if the aircraft is SE or ME, if applicable;
(vi) total time of flight;
(vii) accumulated total time of flight.
(3) for each FSTD session, if applicable:
(i) type and qualification number of the training device;
(ii) FSTD instruction;
(iii) date;
(iv) total time of session;
(v) accumulated total time.
(4) details on pilot function, namely PIC, including solo, SPIC and PICUS time, co-pilot, dual, FI or FE;
(5) Operational conditions, namely if the operation takes place at night, or is conducted under instrument flight rules.
If they did not consider it flight time, surely they would not have included it in the section that describes how you record flight time!