If it’s obvious, is it a dog whistle?
But these days those words are treated like magical incantations by hacks trying to make it believable when they assign labels to the wrong'uns.
The point of a dog whistle is to be obvious to anyone clued into its subcultural framework, but slip under the radar otherwise.
I think it is valid to call something a dog whistle as long as it's something where a sizable number of people get differing impressions of the meaning of a statement.