Yes its considered airgapped by everyone I've heard talk about it. NFC might be too... Maybe a gray area. I bring it up because NFC is easier to use than QR.
Discussion
It's a grey area. In my opinion, air gapped simply means using the device without it ever being physically connected to an internet-connected device.
Because, if we define it literally, we will be disagreeing on whether the photons from the QR code act as a wave or as particles. Or whether string theory suggests that the devices are physically attached at any time and space.
I'd argue the main benefit of airgap (possibly part of the definition even) is that you can trivially intercept and monitor the messages being exchanged. QR allows you to record and determine what the messages are pretty easily. Wired methods are trusted in this regard. NFC is harder to do this but is only a temporary connection.