Sure, but then we start getting in to gray areas. Linux is recommended, but Windows will do. Removing connectivity hardware is recommended, but turning it off will do. Formatting the hard drive first is recommended, but not doing it will be OK since you will be offline anyway. Encrypting your wallet is recommended, but no one will have access to it anyway so it's not necessary. And so on. Soon enough, we are left with someone just turning off their WiFi and thinking they have a safe airgapped wallet.

The problem with airgapped wallets is exactly this - you can seriously mess up if you cut corners or don't really understand what you are doing. This is much harder to do with a hardware wallet. I would say if you can't commit (or don't have the knowledge) to set up an airgapped wallet properly, then you would be safer using a hardware wallet instead of settling for a sub-optimal airgapped set up.