That’s a fine analysis, but most people have a more generally accepted definition of what low-level means in a context of modern systems programming languages. I suppose you have provided an alternate definition, but it’s not really in the context of what most are thinking about in this arena.

It’s a bit like a podcast I listened to recently where someone suggested any language with a proper algebraic sum type can be considered a dynamic typed language in some ways. I mean, if you get philosophical about definitions and lean heavily mainly on historical context, it’s possible to say just about anything.