Not according to the latest version of CAP1789 dated April 29 2020. See below extracts from pages 7 and 8 for reference:
"Unmanned aircraft which do not comply with the requirements of classes C0 to C4 are
able to continue to be operated indefinitely within subcategory
A3 (far from people) and, if
they are less than 250g, within subcategory
A1 (over people)..."
"Unmanned aircraft without a Class marking – any reference to MTOM or ‘take-off mass’
should be taken to mean the weight of the unmanned aircraft at any time while it is in flight..."
(which will be referred to as the ‘flying weight’)
As long as a Mavic Mini weighs less than 250 grams at the time of flight, it will be able to be flown in the
A1 subcategory, unlocking huge potential for MM owners from 1st November (earliest).
Annex D on page 47 provides a clear indication of this.
Source:
CAP1789: The EU UAS Regulation Package – Outline