More that the authors are conveniently getting tons more clicks by making no attempt to denote the low-impact of the recall when it's obvious that 95-99% of the population will only see the headline or will associate it with "like when Toyota's accelerator pedals were getting stuck".
I should probably complain loudly too, then, considering "Audi vehicles recalled" was an article title when mine had a recall for "passenger side camera may get foggy in cold weather".
Or when Lincoln sent me two pieces of paper "to be inserted into your owner's manual" as another safety recall.
The word, "recall", has a myriad of definitions. In this particular use of the word, it has a historical basis in physical vehicle recalls to the service center. That an agency has since decided it also applies to OTA patches does not change this fact or how it is perceived by people at large.
It sounds like you should be upset at the agency and not the fact based reporting.
Are you OK with Tesla calling stuff auto pilot or Full Self Driving even if it is not a real auto pilot not a real full self driving ? For consistency with your argument I suspect we agree it should be called lane assist and SSD Sometime Self Driving.