Obviously this is extremely speculative, given the premise, but yes
At a trivial level, with 26 distinct smells, you can implement English over scent by having one scent for each letter of the English spelling
Language can be communicated through almost any medium which can distinguish at least two states (this very post goes through such a medium, albeit not in a very human-friendly way, on its way to you) and a language natively used in a particular medium will behave "phonologically" in a different way due to the features of that medium. Unfortunately, we only really have two test cases for this in the real world: spoken language (through the medium of sound and with a fairly small pool of available symbols), and sign language (through a visual medium with a very large pool of symbols)
Writing does not count as there is no language that is natively written but not natively spoken or signed, but it may still be a useful point of comparison. Like sign languages, it's a visual medium with a very large pool of symbols so a purely written language would probably be expected to behave "phonologically" more like a sign language than an oral one. Compare manually-encoded English which is largely analogous to logographic writing (i.e. signs represent words), but with some alphabetic supplements (i.e. finger spelling)
A scent-based language, could behave more like an oral language, or more like a sign language, probably depending largely on the number of available scents