Hm. It seems not ideal to use the EK-championships 2019 to decide quotas. In fact, in 2019 they only used combined results from WC1-4, season 2018/2019 to decide. Communication 2199. The wordings in the Special Regulations are saying that the qualifying rules follow the pratice of the World Allround/Sprint champs, and indeed they are talking about "preceding" championships. But did they interprete it as "preceding year"? No EK allround in 2018.
So, WC1-4 then? No, of course, those Events were cancelled this season.
To me, given the exceptional circumstances this time, it would be wise just looking at qualifying times in approved competitions from the first of july 2019. The ISU Council have slightly more powers in times like these it seems. If possible, I would hence have operated with three different qualifying times to decide whether each european ISU-member would get 1, 2, 3, or none national spots. Each member then decide what skaters they use given that they have fulfilled the same qriteria. I.e. if three skaters from Norway qualify, one entered skater must have achived the slowest qualifying time, one the middle qualifying time and one the fastest. Not too many national champs or international competitions ahead, so one can pretty much calculate so you dont get too many participants.