Seeing red

[Angrboda]

According to my definition of intentionality, the intentional representation is part of a recurring, self-sustaining feedback loop in which the thing has behaviors triggered by the representation.  In the sense that DNA triggers behaviors such as molecule building, its molecular chain would be about those molecules it is building.  However there is no feedback involved, so the DNA molecule isn't properly a representation of the molecule it is building under my definition.  But here, in which DNA gives rise to molecule building, is one area that shows the crossover between representation happening and "just stuff happening."  In that sense, looking at DNA as 'encoding' the building of certain molecules is a case in which the interpretation of what is happening is firmly "in the eye of the beholder."  It is a conceptualization of what is occurring, and that requires high level intentionality of a kind not available to the DNA molecule.

I'd say by definition an evolved DNA code represent a long-term interaction among DNA and the environment, no?

The DNA by itself doesn't represent any specific interaction. Only by embedding it in a system (the living cell inside the living body) does it achieve any level of "long term interaction" at all. So once again we see that it isn't the 'idea' or representation in memory or the sequence of DNA that represents — these are all shorthands for the system which makes their content refer to other things. Without the system, they are nothing on their own.