On the one hand, I tend to agree with you. But on the other hand, I think there is a significant nuance - for many users going into recovery mode is beyond what they are comfortable doing with their laptop and so for all intents and purposes a laptop that can only be recovered that way is unrecoverable.
More generally, any issue with a computer can be fixed by a sufficiently skilled and determined user - maybe with some data loss. Even a broken firmware might be fixed by writing a new one, cracking the authentication mechanism, and building a custom rig to flash it to the chip.
It's all a matter of degrees and how much users can be expected to do which makes defining exactly what "bricked" means very difficult.
To be honest, even as an advanced user, I'm not comfortable with recovery modes on any operating system. They tend to be monolithic black boxes and that's a lot scarier than every other recovery method short of desoldering Macbook flash.
More generally, any issue with a computer can be fixed by a sufficiently skilled and determined user - maybe with some data loss. Even a broken firmware might be fixed by writing a new one, cracking the authentication mechanism, and building a custom rig to flash it to the chip.
It's all a matter of degrees and how much users can be expected to do which makes defining exactly what "bricked" means very difficult.