The Holodomor is considered:

• Genocide by 23 countries and the European Parliament
• Criminal act of Stalin's regime by 6 countries
• Crime against humanity by 5 international organizations

Besides that a lot of the world has no clear stance on it. But straight up saying that it was not genocide is disagreeing with a lot of governments. And the official definition of genocide includes intent:

>acts committed with intent to destroy, in whole or in part, a national, ethnical, racial or religious group

https://en.wikipedia.org/wiki/Genocide_Convention