I think it is. The limited-edition toys from the first Mission: Impossible movie didn't have the rights to his likeness, and I can't think of any other movie he's done that had figures (aside from the unofficial variety). Kudos to Medicom, who have taken a back seat to Hot Toys in recent years but actually got one up on them this time.
It's a shame, then, that this one is so scene-specific. The goggles-strap appears to be sculpted to his head, which is going to make customizing tougher. And the sculpted gloves don't look like they allow for multiple outfit changes that would look right.
Still, it proves that no likeness is necessarily an impossibility. If only Eastwood would quit holding out...
More pictures and specs (though they're in Italian!) at itakon.it.