No it's not a war crime. If memory serves then the prosecution at Nuremberg brought forth instances of u-boats sinking trawlers - as an example of barbarism.
I believe Donitz pointed out that all British ships, no matter their size or purpose, had been ordered to report U-boat sightings. That made them fair game.
I think the prosecution withdrew that charge. Indeed WW2 US Subs in the Pacific sank sampams and other small ships for the very same reason.
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