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It is not a penalty to execute a tackle that is not textbook. There is no way that it is a penalty to have your head down when you tackle. Poor fundamentals but not a penalty in any way.
I agree, it is not a penalty to execute a poor tackle or have your head down during a tackle.
However, it appears he's leading with his head. That's the part that could be spearing.
It's pretty close and I could see the shoulder. I also think he is leading with the helmet though.