From a legal point of view, GLOSM?EUSEC is not in the position to conclude any attack by Russia, that leads to civilian wounded and death, as a war crime. It is to qualified and appointed authorities to do so.

However, there is a right to view and/or to consider these attacks as war crimes because you then just have thoughts in this regard. 

For example:

As of October 9, 2022 GLOSM/EUSEC has documented some 469 cases of attacks by Russian invaders on residential buildings in Ukraine. None of these buildings were found as used by Ukrainian troops for military objectives. 

The majority of the studied residential buildings show that they were hit on the mid section of the construction, leading to no longer safe for habitation of the entire complex.

If such way of targeting is seen on extraordinary regular basis, one can conclude no other than that premeditation exist. In other words: the way of targeting is a mastermind tactic.

Those who premeditate and mastermind have decided to refuse distinction of civilians, civilian objects and military objectives.

It is reason to view and/or to consider these and similar attacks by Russian invaders as war crimes.