Proactive, in this case, means “before they are legally required to.”
If they waited until NHTSA performed their investigation and made a recall request (which is how the heavy majority of the recalls in the US are performed), that would be reactive.
Actually it does :-). I get that being pedantic can be fun but if you actually forcibly misinterpret things base on pedantry you might find it doesn't serve you nearly as well as actually thinking about what was "meant".
There's everyday meaning, then there's the meaning as an industry term, and then there's a legal definition. The everyday meaning is the least relevant one in this context.
A behaviour that focuses on results and actions rather than acting when something happens. This type of behaviours aims to identify and take advantage of opportunities and also to prevent potential threats or problems. On the contrary, reactive behaviour works by retaliating when an event or problem has already occured.
If they waited until NHTSA performed their investigation and made a recall request (which is how the heavy majority of the recalls in the US are performed), that would be reactive.