No, in my opinion they are not. When you have mother dies with 19 or 197 already on it, the last numbers are applied by hand when a new “working” die is needed, and that's the reason why we find many “varieties” on the last digits on coins.
It's a long and unresolved discussion, if we should say “variant” in the sense of opening a sub-type or not. The collectors of US coins have the same problem with the mint marks, mostly, lucky enough, they are just documented, but NOT assigned sub-types.
Edit: 19 or 195, of course
Globetrotter
Coin varieties in French:
https://monnaiesetvarietes.numista.com