That attitude is misguided. Many people do in fact use JSON as a config file format, so it is a config file format. Real world usage outweighs prescriptions about what is and isn’t correct.
Looking at the first standardized JSON spec, it’s not particularly prescriptive about usage, simply saying:
JSON is syntax of braces, brackets, colons, and commas that is useful in many contexts, profiles, and applications.
Of course, it would be a better config file format if it supported comments, but people use it even despite that. I think we should try to understand the reasons for that rather than just telling people they’re doing it wrong.