Any work made to convey a concept and/or emotion can be art. I'd throw in "intent", having "deeper meaning", and the context of its creation to distinguish between an accounting spreadsheet and art.
The problem with AI "art" is it's produced by something that isn't sentient and is incapable of original thought. AI doesn't understand intent, context, emotion, or even the most basic concepts behind the prompt or the end result. Its "art" is merely a mashup of ideas stolen from countless works of actual, original art run through an esoteric logic network.
AI can serve as a tool to create art of course, but the further removed from the process a human is the less the end result can truly be considered "art".
They really aren't: it's just going to add a little thickness, weight, and cost to the phone. Screws and gaskets aren't exactly rocket science.