It most certainly can and because the genitalia is visible, it is very likely that it would be considered porn.
Ultimately, it's the viewer that determines whether or not a nude photo is porn. If the viewer thinks that it's porn, then to them it is. More than likely if genitalia is visible, most people would consider it porn. A judge once said "I can't define pornography, but I know it when I see it."
There have been a lot of nude photography over the last century and a half; most of it in black & white, and almost none of it showed genitalia. It's a matter of being classy. Showing a woman's junk is not being classy.