Armitage won the last of his five England caps in 2010 when he played for London Irish.
He joined Toulon a year later and has subsequently not been involved with England as the Rugby Football Union holds a strict policy of not selecting overseas-based players unless there are "exceptional circumstances".
England head coach Stuart Lancaster recently met with Armitage, and he continues to produce world-class performances, underlined by a brilliant display as Toulon retained their European title in the last Heineken Cup final through a 23-6 victory over Saracens.
It appears unlikely, though, that the 28-year-old flanker will be involved in next month's demanding three-Test series against world champions New Zealand.
"Steff has really been phenomenal, and it is sad that because of where he plays he is not going to go on and achieve high honours," Toulon and South Africa wing Habana said.
"He gets vital turnovers that get the scoreboard ticking - three, six, nine points - and our team thrives on that. He is a crucial part of the team.
"He has put his hand up this whole season. People write him off at their own peril. He has been absolutely wonderful - he can dominate games.
"As a player, you understand the commitments the countries need to grow their own game and you understand their logic. You respect the decisions made by the administrators.
"The decision is out of our hands, but I think a guy like Steffon, with the season he has had, probably deserves to be playing international rugby. He is a great team man."
While Armitage made the final's dominant individual contribution along with centre Matt Giteau, it was Toulon skipper Jonny Wilkinson who inevitably took centre-stage in his last appearance on British soil before retirement.
England World Cup winner Wilkinson will bow out of the game after next weekend's French Top 14 final against Castres in Paris, and he kicked 13 points as Toulon became only the third team after Leicester and Leinster to successfully defend European rugby's major club crown.
"Jonny is a once-in-a-career, once-in-a-lifetime player," Habana added.
"You look at sporting greats, and he will probably rank up there with some of the greats in any formula of athletic ability.
"It's never going to be nice saying goodbye to him. He has had an impeccable career, and the humility he has shown, the way he puts work ethic into a whole different category has been outstanding.
"I don't think he will ever be able to be replaced. There is only going to be one Jonny Wilkinson, only one guy who has achieved what he has.
"We are going to miss Jonny, what he brings to the team, what he brings to the whole environment. How he lifts the whole team and whole city is something immense."
Even without Wilkinson next season, it is difficult to envisage Toulon not featuring prominently in the new European Rugby Champions Cup, such is their all-round strength, quality and character.
"Four months ago after we lost to Grenoble (in the Top 14) everyone had sort of written us off, but the character and leadership shown in this team from people like Jonny, Matt Giteau and Juan Lobbe is outstanding," Habana said.
"People throw it out about players going to Toulon to retire and for the money. People call us mercenaries, but I see the work ethic of the guys, the work that gets put in on the training pitch and in the gym.
"But over and above it, there is the team spirit, the vibe in the playing group and the ability to overcome a disappointing mid-point of the season.
"When you are involved in a team where the guy next to you is willing to go that extra yard, not for himself, but for the jersey and his team-mate, it makes it really special.
"It has been a massive honour for me to go to Toulon. Winning the Heineken Cup final was the first step, and there is another big one for us next week."
- Sports & Recreation
- Jonny Wilkinson
- Heineken Cup
- Rugby Football Union