212 MAN - 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!
If you are referring to EASA AMC FCL which it looks like you are then simply look at the example log entries on pages 23 and 25 with a combination of different flight types, one of which is a sim entry - the sim entry clearly has no 'Flight Time', 'PIC', 'Operational condition time', or 'Pilot function time.' It has 'sim session time' and that is all - clearly separated from flight time.