However, the categorization again is fuzzy, with definitional overlap between "planet", "sub-brown-dwarf", and "brown dwarfs"
Planets cover spherical objects ranging from 0.001 Jupiter masses to stars at ~80 Jupiter masses. Brown dwarfs range from 3-80 Jupiter masses.
Brown Dwarfs are planets and can form outside of an accretion disk. Planets smaller than brown dwarfs are not thought to be able to form outside of accretion disks.
Wikipedia says "Rogue planets may originate from planetary systems in which they are formed and later ejected, or they can also form on their own, outside a planetary system."
Claims about self formation pertain to rouge planets as a class, which includes brown dwarfs. That does not mean an earth mass object IS a brown dwarf.
If you want to want to focus on Wikipedia text, it also says:
>Pre-JWST observations have shown that objects below 3-5 MJ are unlikely to form on their own.[4] Observations in 2023 in the Trapezium Cluster with JWST have shown that objects as massive as 0.6 MJ might form on their own, not requiring a steep cut-off mass[1]
Those limits are ~1,000 earth masses and ~200 earth masses, respectively
https://en.wikipedia.org/wiki/Rogue_planet#Formation_like_a_...