Voluntary recalls are actually more common than ordered recalls. Manufacturers usually don’t wait for the NHTSA to get involved.

What makes it a recall is that either the manufacturer or the NHTSA determine that there’s a safety defect or that the vehicle doesn’t confirm to the Federal Motor Vehicle Safety Standard.

So I believe the terminology is required by the NHTSA ic it fits the above definition regardless of how the issue is addressed.

Of course this is for the US and this is a recall in China but I’m assuming similar legal requirements are involved.