Well, it's not clear cut. What can constitute "racism" or not is quite open to interpretation.

Even statements of fact or plain arguments can be interpreted as racist.

For example, if you are against illegal immigration in my country (and many others) you are labeled as "racist", even if the reasons you are against it have nothing to do with race, but say, with border control, lack of supporting infrastructure for too many immigrants, possible use of minorities as a political weapon from surrounding countries, etc.