Legally yes.
Morally, I would say they are free range but.....
Instead of labeling it for customers why not just put up a sign that explains your raising habits and let the customer decide.
I sell just a few eggs to co-workers but instead of trying to put labels on it I just let them know.
Mine are fed organic feed but also get a small amount of non-organic scratch.
They get kitchen scraps.
They have access to the outside 24/7 with an enclosed run
They get about 2 hours a day to roam the yard (which doesn't have a fence but even if it did 1 acre is enough range for 11 chickens if you ask me.)
I don't use antibiotics unless absolutely necessary like cocci when chicks (but after they catch it not as a preventative).
I don't use hormones.
I don't routinely give them any medication topical or internal unless they have something wrong that means they need it (to date none needed).
Most my customers consider this organic, cage-free, free range, farm fresh eggs. However, it isn't if you go by the organic certificate I don't have. It isn't if free-range means 24/7. It isn't if 2 days old isn't 'fresh'; It isn't if a predator proof run is a cage. I leave it up to them if I have met their standards. Many of the labels like cage free doesn't mean what people would like anyway. commercial cage free eggs simply mean they can get off the nest. My chickens have a large area in and outside to roam but it certainly is a cage just a large one for their protection. They only range when I'm home, it's daylight and I can keep them out of the neighbors yard