It's not, no. The Witcher is most definitely a full-on RPG, and so is Witcher 2.
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Also found this in an old discussion of mine. Looks relevant
Once again, my opinion, though if exceptions exist I do not know of them:
I think one interesting point with the different types of RPGs is their approach to world building. In each case, it's totally different:
RPG: the world is built as a place where adventures can happen. This means that building the world is the first step in creating the game. You may have an overall story in mind, but the characters will be created to fit into the world rather than the other way around. RPG worlds tend to have a well developed history, complete with societies, politics and a fairly feasible ecology. They feel real as long as you don't look TOO closely. Best examples: PS:T or The Witcher.
JRPG: the world is built around the characters. The story has clear primacy and the world is an afterthought, being clearly the last thing created and having importance only as something the characters move around on. If there is a history, you can be sure it will have importance to the characters and any societies or politics only matter as far as they involve the characters. Best examples: Final Fantasy games.
Action-RPGs: the world exists to spew out endless hordes of monsters for the characters to hit. Everything revolves around hitting things, so ecology, history & politics are barely if ever touched on, except as a way to generate new things to hit. World building is unimportant, so it's rare that it even gets a look in. Best examples: Diablo or Titan Quest.
All three game types can be fantastic playing experiences, don't get me wrong, but the emphasis on priorities reflects what each type of game does best:
RPG: interactive world, to allow characterisation.
JRPG: story/plot.
Action-RPG: combat.
