Yes it is, but what I mean is that the term is subject to interpretations. Its definition is subjective, even if it's well established now.
It's not a problem presently because it's well regulated, but under a more extreme government, say a conservative religious one, it might be abused to punish blasphemy.(only an example)
I admit we're far from that case now, and that it's better than have no regulations, but i can conceive it raise concerns.
That can't happen here since the justice system is (supposedly) separate from the legislative/executive body.
A recent law was struck down by the constitutional council because it changed how the law was interpreted regarldless of precedent.
Considering we've got more than enough precedent regarding hate speech that's not happening till a change of constitution at least.