> Constraint validation: If an element has a maximum allowed value length, its dirty value flag is true, its value was last changed by a user edit (as opposed to a change made by a script), and the length of the element's API value is greater than the element's maximum allowed value length, then the element is suffering from being too long.
Where "the length of" is a link to [2]:
> A string’s length is the number of code units it contains.
And "code units" is a link to [3]:
> A string is a sequence of unsigned 16-bit integers, also known as code units.
I agree with your implied point that this is a questionable definition, though!
[1] https://html.spec.whatwg.org/multipage/form-control-infrastr...