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The FSF does not claim that these elements are software, but rather that, although they can be considered software from a design perspective, in practice they are hardware.
Writing instructions on a sheet of paper does not constitute software by itself, but rather a tangible representation of software (like printed source code). That sheet is merely a physical medium. For those instructions to be software, they must be in a format that a computer can interpret or execute.
The base microcode etched into a CPU's silicon is not a program that the processor executes or interprets. Instead, it functions as a finite state machine implemented in hardware — a fixed set of rules and physical connections (states and transitions) that guide the CPU’s internal behavior to execute complex instructions.
