A “recall” that does actually involve bringing the car in for service, a.k.a. recalling the car, is not accurately described as a “recall”. Words mean something.
The NHTSA is being idiotic (unsurprisingly) in not distinguishing between a software update and a recall, because legacy auto doesn’t have the software chops to successfully replicate Tesla’s approach.
News agencies that lean into that idiocy in a slanted attempt to denigrate Tesla are only denigrating themselves. It is not good coverage, and it is willfully misleading their own readers.
Call it a mandatory update if you want. But nothing was recalled, so insisting on calling it a recall is like insisting on calling cars “horseless carriages”.