Structures to be treated as tunnels in relation to the rules are those listed as such in the Sectional Appendix. Regardless of length, name or construction.
The length bit comes in for bridge inspection by the Civil Engineer, structures under 2 chains in length usually bridges (exact length may differ over time and between different railway companies) are inspected as one item. Longer structures are inspected in sections, most structures inspected this way are tunnels, so for inspection if it is over 2 chains long it is a 'tunnel'.
For strict engineering useage if it is dug through something it is a tunnel, if it is built over something it is a bridge, and if you build a structure then bury it you have a covered way.