No, in the comment you reply to, I am using safe/unsafe in the Rust sense. E.g. signed overflow changed to trap avoids the UB.
Also "If .. are implemented soundly" sounds harmless but simply means there is no safety guarantee (in contrast to Fil-C or formally verified C, for example). It relies on best-effort manual review. (but even without "unsafe" use anywhere, there are various issues in Rust's type system which would still allow UB but I agree that this is not that critical)
In C UB is part of the ISO language specification, but not necessarily part of a specific implementation of ISO C. If you argue that the ISO spec matters so much, I like to point out that Rust does not even have one, so from this perspective it is completely UB.