I see what you are getting at. Programs consist of materials that are presented to the implementation, and also of materials that come from the implementation.
So what I mean is that no file matching <winkle.h> has been presented as part of the external file set given to the implementation for processsing.
I agree that if such a file is found by the implementation it becomes part of the program, as makes sese and as that word is defined by ISO C, so it is not right terminology to say that the file is not part of the program, yet may be found.
If the inclusion is successful, though, the content of that portion of that program is not defined by ISO C.