This particular situation is ... different. It's clearly still causing pain to children. It's using their likeness without their consent and in a sexually violent way.
But ... I can't get behind the idea of equating it to child pornography.
It should absolutely be considered a crime, and come with its own set of punishments for those found guilty.
Again, making it absolutely clear that I personally find this act to be vile, unacceptable and highly antisocial, I also think that it should be published much less severely than producing/distributing .. err ... "actual" child pornography...?
We treat manslaughter and murder as different things, perhaps that's a suitable analogy here?
This also seems similar to the whole issue of deepfaked porn involving celebrities. When folks said "AI is gonna usher in societal problems we have no idea how to deal with", I never imagined it would get this bad, this quickly.