The word "emulate" is overloaded, but because there's often an assumption of ISA emulation, Wine for a time called itself "WINE Is Not an Emulator" to prevent said assumption.
Taking "emulate" at its dictionary-definition, which is to imitate or copy, it's easy to argue that Wine is an emulator, because it copies and imitates the Windows ABI and API (the earliest versions of Wine even called itself a "WINdows Emulator"). They just happen to draw a hard line against emulating x86.
Taking "emulate" at its dictionary-definition, which is to imitate or copy, it's easy to argue that Wine is an emulator, because it copies and imitates the Windows ABI and API (the earliest versions of Wine even called itself a "WINdows Emulator"). They just happen to draw a hard line against emulating x86.