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.
That was a recall from 2022 (https://www.cnn.com/2022/10/06/business/toyota-bz4x-wheel-fi...) for 260 vehicles (their model BZ4X electric SUV).
The Cybertruck recall affects 3,878 vehicles (https://www.caranddriver.com/news/a60538687/2024-tesla-cyber...).