Sure most Europe falls well under that, but warheads tend to be deployed on solid rocket motors as they're comparatively low maintenance. Solid rocket motors can't be shut off once they're started, so you have very little control over its burn time once its started (this is one of many reasons why the Space Shuttle had so many black zones where an abort would result in the death of the crew). All you can control is its trajectory, but targeting europe, would mean either a very shallow trajectory, relying on air resistance to sufficiently slow the missile at the target, potentially resulting in the missile and warhead burning up or tearing up from g-forces in the lower atmosphere; or an extremely steep trajectory, resulting in, again, either strong g-forces or incredibly high temperatures meaning the missile burns up or tears up in the lower atmosphere.
Given the reluctance toward a first strike, I'm not convinced that russia can strike most counter-value targets in Europe with its fixed deployments. I think of the few missiles it has that can reach europe, they're likely aimed at counter-force locations, with the rest aimed at the significantly larger nuclear force in the US. Its subs are a different question though.