Well, they ARE lolis, and must be tagged as such. It's not like we have a non-lewd loli(child) tag. What i don't get is - why something called "Kodomo no Moeoh" only features safe-ish images, regular Dengeki Moeoh has lewder lolis than here. Is there actually a market for cute but not lewd anime loli?
Yes, they are lolis. No, this is not lolicon. The lolicon tag is EXPLICITLY for nude or lewd lolis, not lolis in general. So no, it does not need to be tagged something that it is not. If simply having a loli in a gallery was enough, then any gallery with a single page with a loli in it would require the lolicon tag, as "Galleries only need to contain one picture of this nature to be given this tag." Just like how the non-h category is instantly nullified if there is 1 page involving sexual content within the gallery, 1 page involving nude/sexual lolis is enough to give the lolicon tag. The only case where the lolicon tag is applicable to a non-h category is if the loli is nude, or has their private parts exposed in a non-sexual way. This never happens in this gallery.
As the definition specifically says, "NOT TO BE CONFUSED WITH YOUNG GIRLS IN GENERAL."
This is important, because there are people who use the hidden site that have lolicon blacklisted, but are ok with seeing galleries like this.
And what are the tag for "young girls in general"? Should it be tagless? It's not "explicit", but it's not "safe" either - there are pantsushots, so - it's "questionable". Lolicon is my default tag - i would not have seen this gallery if it didn't have it.