No~.
Wouldn't counting your collection be easier if the system was based on the mold, unit and packaging as determined by Hasbro/Takara?
These new Minicons are sold as gimmicks to the original scout figure - a marketing strategy that involves raising the customer-perceived value of an item(s) that would otherwise have a lesser value/price point. i.e. selling a Scout fig for $14-18AUD and a Minicon for $5-8AUD. So basically in line with the UCM's part on G1 Headmasters/Pretender shells (which I haven't read, but skimmed based on member posts in this discussion).
However, if Hasbro/Takara intends to re-release particular molds into separate packages, I hold that that mold be recounted as a separate fig for UCM purposes. i.e. Releasing Chopshop as an individually packaged fig.
This view will restrain unique molds to their original purpose of being an add-on value to the central figure, until that unique mold is determined by Hasbro/Takara for individual play.
Example 1: TF Cybertron's Vector Prime's Safeguard is only attainable by purchasing a Vector Prime mold (the original TF Cybertron one, the repainted Universe fig, and the Botcon repaint as Alpha Trion).
Example 2: Purchasing a new TF Energon Ultra Magnus with the Reqium Blaster (Minicons Payload, Skyblast and Astroscope) will qualify you for _two_ UCM; even though there are effectively five figs being obtained here, you can only otherwise obtain these five figs though buying TF Armada Overload, and TF Armada Space Minicon team.
Example 3: Minicon 3 packs will have a UCM count as _one unit_, whilst TF Universe Bruticus counts as _five units_; since the former has never been released separately (to my knowledge), whilst the latter was originally released separately (Originally TF Energon Bruticus Maximum - idiot me rigorously searching for the limbs and finally paying 4x $15 and 1x $25 through a lengthy 3 month ordeal, always fearing that I would have an incomplete Bruticus Maximus). Likewise, TF Animated Jetfire & Jetstorm counts as _ONE_.
In line with this view, I wouldn't be counting non-Hasbro/Takara releases part of UCM (quite sadly excluding Knight Morpher Commander/Hearts of Steel Optimus Prime).
I think that counting all these bits and pieces would be over-inflating your collection. Part of the fun in collecting is going out, finding, and buying something awesome and thinking to yourself, "Hey, Awesome!", rather than pushing for a big number to boast.