I don't think its too misleading because in both cases that's how many vehicles are affected at very moment by the recall.
Toyota shipped/sold more as mentioned in the article, but those are unaffected. Likewise with the Tesla, any shipped afterward the defect was discovered are unaffected.
> Only 260 BZ4Xs had been delivered to customers before the recall was announced
If they had sold 4000 like the truck, they would have recalled 4000. Both recalls affected all the cars sold for the model.