Concentration camps evolve INTO death camps, but are not themselves death camps. Experts on the matter say they meet the definition of concentration camps. They should be called what they are, and to not do so is to kid yourself about the evil they represent and the even worse evil they could easily become.
It is vanishingly rare that Godwin's Law should be set aside. However, Trump and his racist followers are significantly comparable to Hitler and the Nazis. Trump and Hitler are both pathological liars, demagogues, and seek dictatorial power. A large percent of their followers believe in white nationalism and are drawn from the dregs of society. Separating children from their parents without any thought of reunification except in death... Does Trump and his supporters need to achieve actual death camps and gas chambers before concern is justified?
I don't think you even have to set aside Godwin's Law. In my view, Trump is more analogous to Mussolini than to Hitler. Same vain buffoon vibe going. Same lack of discipline and focus, same casual cruelty, same incompetence. And it's a little appreciated fact that Mussolini had concentration camps too, and even one death camp (Risiera di San Sabba).
If people are being detained under armed guard, for whatever reason...either prisoners of war, refugees or for holding political ideologies, then where they are being held can legitimately be called Concentration Camps according to all dictionary definitions.