Hard to tell with a dress like this, I'd say borderline.
Working with this tag I've learned the position of the belly button is less consistent than you'd expect it to be, much more random than other body parts we've designated for these kinds of measurements.
It would be, but that's would also require it to be about a hand's width longer (on average) than the current requirement, belly button was probably chosen to make it a little bit more accessible.