Honestly, considering the explicit central theme is fetish sex it is really pushing boundaries if not already crossing them. The interpretation by the rules could actually classify it as H considering there is near nothing in terms of plot and you can argue that the artist censored their work. Supporting that theory you get stuff like the C1 P11 censor which is 2 millimetres from porn even to the point of showing the outline of the guy's shween. And then the following pages of light flashes like C1 P21 covering up revealing positions that would otherwise show genitalia.
But I guess it is entirely mod call on this.