There's a lot going on for it to be Dubstep. My own definition of dubstep is very pronounced bass, nothing gets in the way of the bass hits, then everything dances inbetween.
The bubbly-whistle melody is very sharp, which on top of everything else is very out of sync at times, kind of hard for me to sense the groove when so many other effects are going on at their own will.
The drums are simple enough and have kind of a modern hip hop appeal to them. Tssssssk tada CLAP. Tssssk ssst CLAP, but again the drum pattern is very sporadic and makes it hard to discern where the song wants to take my emotionally.
When I listen to it, I get hints of that tasty dark, gritty ominous feel but is overwhelmed with the sharpness of the melody, kind of like being abducted by aliens only to find out they're the friendly childhood cartoon aliens.