No, I think it's widely regarded as engine limitations even when people continually claim it's up to individual game devs to optimize their games.
If that were the case then why do nearly all UE5 games suffer from the same engine stutter issues. And to OPs point, even if it can be optimized away, why isnt the engine in a state where the baseline performance for realtime rendering does not exhibit these stutter issues on the majority of games.
Unreal’s limitation is that it doesn’t know how a shader will be used until it actually tries to render it on the target hardware. This is a trade-off to gain flexibility and rendering performance. The engine has to compile shaders on the fly when it is first used, which is fine if the shader is simple, but nowadays that usually is not the case.
There are ways to make a player’s PC compile shaders before realtime play begins, but it takes some setup and smaller devs might not know how to do it. This is most likely the reason why stuttering happens.
On fixed hardware targets (consoles, Steam Deck) you can ship precached shaders as you know everything about the target hardware.