I am not sure tbh, I know it was Italy and Germany and dissolved during the Napoleonic wars, but beyond that my knowledge of its history is thin.

I guess it also depends how and for what purpose you are defining it as an empire or not.

Wikipedia calls the holy Roman empire a polity, but refers to the first french empire under Napoleon as an empire for whatever that’s worth?

Possibly the naming was aspirational, or a throwback to the Roman empire that controlled most of Europe?