That is exactly what I was referring to. An HTML file has no empty space to hide something in.
For those not familiar with the terminology, "rubber hose" in a cryptography context is a euphemism for torture. I know of two approaches to counter it.
Plausible deniability, where you can give out a password that unlocks some of the data, but your adversary has no way of knowing whether that's all of it. Useful if you can expect that you'll be let go if you're 'innocent'.
A self-destruct function, e.g. you give out the wrong code 3 times and your device wipes the data. Useful for military use cases where the data is worth more than the life of the person holding it.