But what constitutes “RPG elements?” Because most of the time that seems to mean “crunchy stats”, which has absolutely nothing to do with “Roleplaying.” I’ve seen Call of Duty described as having “RPG elements” because you unlock perks.

Your average visual novel is more of a roleplay experience than half the CRPGs I’ve played. If reviewers mean “There’s very little player choice or input and you don’t really get to feel like you’re embodying a character” then yeah, that’s a valid criticism. If their complaint is that they didn’t get to put enough dots next to things, I’m not really sure how that’s a problem.