Except that I did learn about that in high school.

It doesn’t feel misleading, it is misleading. We understand that use of the term “recall” in reference to cars happens to include over the air software updates in its legal definition. However many people likely do not. I’d also wager that many people who do know occasionally forget when they first see the headline. So while the use of the word “recall” here is technically correct it leads people to assume that they are physically recalling the cars.