* Sustained energy throughput, aka thermodynamic disequilibrium - depends upon the substrate in which our Turing machines operates
* Sufficient degrees of freedom to perform computation - Turing machines compute, therefore any substrate that supports Turing machines has this. This includes autocatalytic Closure.
* Dissipative Non-linear reactions - not supported in conventional substrates that support turning machines. Are there perhaps some more exotic substrates that DO support this item?
So no, a Turing machines BY ITSELF does not qualify. That said, it's a step in the right direction. That's probably why Alan Turing pivoted away from digital computers and towards Morphogenesis towards the end of his life.