You can write an entire game like super mario in an html file. Is a super mario game not a program? And no, this is not an archaic way to use html files, it is pretty common to share smaller games as html files. You play them by loading them into your browser.
Remember that html files are not just html. The way we use them today they are fully functional programs.
You are arguing against a statement I didn't make. Look back at the last sentence of my original comment[1] where I distinguished HTML from HTML+CSS3+JS.
It seems we agree that HTML (a language, not a file that also includes other languages) cannot create a game like Mario or even Pong.
Neither can an ELF binary. It needs a loader to execute it.
> It can't run or be executed.
Yes it can, with a runtime that understands HTML.
> It doesn't transform state or even have state. It's not Turing complete.
That's not a requirement for a program.