It seems to be the case that it is. This whole sequence is the first clash.
It seems to just be a drawing error on the first panel, because the two afterwards clearly show he was using CoC on his club. Also it wouldn't make sense that he wasn't using it considering he was going for a killshot on Luffy.
If it is a drawing error, it should get corrected during the volume release. If it doesn't, then it's possible the first swing didn't have CoC, and he imbued after the fact when Luffy used CoC. But again, that's kind of nonsensical, considering Kaido was going for the killshot.