Not if it isn't connected to a network. But its hardly as if devices with manufacturer-paid cellular connectivity built in and preconfigured don't exist, so there's no reason that it has to be your network.
To the extent that manufacturers are either monetizing networked services or deriving useful data from them, making them independent of end-user networking choices has a pretty clear benefit, and I wouldn't be surprised to see it become a common thing in Smart TVs.
And if some manufacturer decides to clutter things, I just won't buy it. Problem solved.
This is getting well into ad absurdum (a common problem on HN). Smart TVs are perfectly fine for the person who doesn't want a smart TV. Just don't use any of the smart TV features and don't connect it to the network. Problem solved.